StableLens

Methodology classification · not legal advice

Stablecoin Regulatory Framework Alignment

Methodology classifications under the CLARITY Act (H.R. 3633), GENIUS Act, and MiCA frameworks. StableLens evaluates public-data alignment with statutory and regulatory frameworks — we do not certify compliance, eligibility, registration, or issuer authorization. Audit-trail defensible. Updated weekly.

Framework status

CLARITY Act

Proposed legislation
H.R. 3633

H.R. 3633 cleared the Senate Banking Committee 15-9 on May 14, 2026 (bipartisan — Gallego + Alsobrooks joined Republicans). Awaiting a full Senate floor vote, targeted ~August 2026 by Sen. Gillibrand; would still need 60 votes to overcome filibuster. 100+ amendments filed.

StableLens tracks the published draft as of 2026-05-18. Per-coin classifications populate the matrix below once owner + counsel review of the proposed draft completes. CLARITY is NOT yet enacted law.

GENIUS Act

Enacted

Enacted. Effective January 18, 2027 (or 120 days after final regulations, whichever comes first). Prohibits stablecoin issuers from paying yield to holders for holding the token; OCC proposed rules would extend the prohibition to affiliates and third parties.

StableLens encodes the current published framework. The Approved / Watch / Avoid / Insufficient Data classification on the matrix below reflects GENIUS-framework alignment as scored by the StableLens methodology v2.0.

MiCA (EU)

In force
Reg. (EU) 2023/1114

In force across EU member states since 2024-06-30. Stablecoin-specific provisions (Title III + Title IV) apply to e-money tokens and asset-referenced tokens. ESMA white-paper registration status surfaced in the matrix below.

Per-coin alignment matrix

Top stablecoins by market cap with their current methodology classifications across the three frameworks. CLARITY classifications populate as F-4.b data ingestion completes.

SymbolIssuerMarket capCompliance gradeGENIUS alignmentCLARITYMiCA
USDT
Tether
Tether$184.08BBWatchPendingSee issuer
USDC
USD Coin
Circle$73.19BAApprovedPendingSee issuer
USDS
USDS
Sky (formerly MakerDAO)$9.75BC+WatchPendingSee issuer
DAI
Dai
MakerDAO$4.62BC+WatchPendingSee issuer
USD1
USD1
World Liberty Financial$4.61BCWatchPendingSee issuer
USDE
Ethena USDe
Ethena Labs$4.45BCWatchPendingSee issuer
USDG
Global Dollar
Paxos$3.01BB-WatchPendingSee issuer
PYUSD
PayPal USD
Paxos / PayPal$2.75BA+ApprovedPendingSee issuer
XAUT
Tether Gold
Tether$2.52BDAvoidPendingSee issuer
USDY
Ondo US Dollar Yield
Ondo Finance$2.16BB-WatchPendingSee issuer
PAXG
PAX Gold
Paxos$1.86BDAvoidPendingSee issuer
RLUSD
Ripple USD
Ripple$1.58BAApprovedPendingSee issuer
USDF
Falcon USD
Falcon Finance$1.42BB-WatchPendingSee issuer
USDD
USDD
TRON DAO Reserve$1.38BBWatchPendingSee issuer
BFUSD
BFUSD
Binance$1.32BB-WatchPendingSee issuer
U
United Stables
$1.02BDAvoidPendingSee issuer
USDGO
USDGO
$871MCWatchPendingSee issuer
USDTB
USDtb
Ethena Labs$727MBWatchPendingSee issuer
GHO
GHO
Aave DAO$598MC+WatchPendingSee issuer
YLDS
YLDS
$559MDAvoidPendingSee issuer
USD0
Usual USD
Usual Protocol$553MB-WatchPendingSee issuer
USX
USX
dForce$511MC+WatchPendingSee issuer
TUSD
TrueUSD
Archblock (TrustToken)$493MB+WatchPendingSee issuer
A7A5
A7A5
$487MFAvoidPendingSee issuer
EURC
EURC
Circle$434MDAvoidPendingSee issuer
FDUSD
First Digital USD
First Digital Labs$349MB+WatchPendingSee issuer
APXUSD
apxUSD
$324MCWatchPendingSee issuer
KAU
Kinesis Gold
Kinesis Money$315MDAvoidPendingSee issuer
BUSD
Binance-Peg BUSD
Binance (Paxos)$283MB-WatchPendingSee issuer
FRAX
Frax
Frax Finance$237MC+WatchPendingSee issuer
KAG
Kinesis Silver
Kinesis Money$231MDAvoidPendingSee issuer
USAT
USAT
$187MDAvoidPendingSee issuer
AUSD
AUSD
$173MCWatchPendingSee issuer
CRVUSD
crvUSD
Curve Finance$172MC+WatchPendingSee issuer
SATUSD
Satoshi Stablecoin
Satoshi Protocol$158MBWatchPendingSee issuer
GUSD
GUSD
$149MCWatchPendingSee issuer
EURCV
EUR CoinVertible
$143MFAvoidPendingSee issuer
USDC.N
Noble USDC
$135MCWatchPendingSee issuer
CASH
CASH
$121MDAvoidPendingSee issuer
AIDAUSDC
Gaib AI Dollar Alpha USDC
$115MCWatchPendingSee issuer
FRXUSD
Frax USD
Frax Finance$114MBWatchPendingSee issuer
USDAT
Saturn Dollar
$111MCWatchPendingSee issuer
AVUSD
Avant USD
$108MCWatchPendingSee issuer
DUSD
StandX DUSD
$106MCWatchPendingSee issuer
USDA
USDa
Angle Protocol$96MC+WatchPendingSee issuer
USDON
Ondo U.S. Dollar Token
$80MCWatchPendingSee issuer
PGOLD
Pleasing Gold
$80MFAvoidPendingSee issuer
MUST
Mustang
$78MFAvoidPendingSee issuer
SUSDA
sUSDa
$76MDAvoidPendingSee issuer
CGUSD
Cygnus Finance Global USD
$76MCWatchPendingSee issuer
FEUSD
Felix feUSD
$75MCWatchPendingSee issuer
LISUSD
Lista USD
$75MCWatchPendingSee issuer
USDX
USDX
$73MDAvoidPendingSee issuer
NUSD
Neutrl USD
$72MCWatchPendingSee issuer
BRLV
Crown BRLV
$70MFAvoidPendingSee issuer
XDAI
XDAI
$69MCWatchPendingSee issuer
CUSD
Cap USD
Cap Finance$66MBWatchPendingSee issuer
PMUSD
Precious Metals USD
$66MCWatchPendingSee issuer
JUPUSD
JupUSD
$52MCWatchPendingSee issuer
BRZ
Brazilian Digital
$51MFAvoidPendingSee issuer

Methodology vs. CLARITY — alignment + gaps

Explicit map of where the StableLens 6-dimension compliance methodology aligns with CLARITY classification criteria, where the bill is silent, and where our framework goes further. This page tracks the published draft — read with the methodology versioning in mind.

StableLens dimensionCLARITY treatmentAlignment
Treasury & Reserves
StableLens weight 25%
Reserve composition + qualifying-asset rules are central to CLARITY classification criteria.Aligned
Methodology inputs (cash, T-bills, attestation cadence) map directly to the bill's qualifying-asset framing.
Regulatory Status
StableLens weight 20%
Issuer-licensing requirements feed the CFTC vs SEC classification path.Aligned
NYDFS Trust Charter, FinCEN MSB registry, MAS DPT, and MiCA white-paper status all feed this dimension.
Peg Stability
StableLens weight 20%
Peg-maintenance language present but specific deviation thresholds not codified.Methodology extends
Methodology specifies a 75bps 24h deviation threshold; published draft is silent on exact bps.
Audit & Code Security
StableLens weight 15%
Smart-contract audit posture is not directly addressed in the published draft.Bill silent
StableLens grades audit firm tier + exploit history; bill leaves this to operational supervision.
Issuer Operational Health
StableLens weight 10%
Engineering continuity + redemption infrastructure not codified.Methodology extends
Methodology surfaces operational signals (GitHub activity, redemption uptime) the bill does not.
Historical Behavior
StableLens weight 10%
Past peg defenses + attestation-vs-reality reconciliation not codified.Methodology extends
Methodology surfaces depeg event archive + statement-vs-outcome history beyond statutory minimum.
Yield-source taxonomy
F-4.c — pending
Tillis-Alsobrooks distinction (passive balance yield vs activity-based rewards) under consideration.Partial
Yield-source classification surfacing in F-4.c; aligns with the bill's reward-taxonomy framework once seeded.

Yield-source distinction under CLARITY

The Tillis-Alsobrooks compromise (Section 404, finalized May 5, 2026) distinguishes interest-like payments from rewards tied to user action. The compromise text is settled; the permissible-reward definitions and anti-evasion rules are not — they require joint SEC / CFTC / Treasury rulemaking due within 12 months of enactment, and CLARITY is not yet enacted. The framework below describes how StableLens reads the current draft language; treat all yield classifications as provisional pre-rulemaking.

Passive balance yield (likely banned)

Payments “economically or functionally equivalent” to bank-deposit interest — paid to holders just for holding the token, with no user action required. The Section 404 text directly targets this category. Examples include holder-rewards programs and interest-bearing wrapped stablecoins paying yield without an associated activity.

Activity-based rewards (generally permitted)

Rewards tied to “bona fide activities” — providing liquidity to an AMM, lending through a money-market protocol, participating in governance, or staking with genuine slashing risk. The draft text generally preserves these. Caveat: banking trade associations (ABA, BPI, CBA, Financial Services Forum, ICBA) flagged reward structures based on duration, balance, or tenure as a potential loophole on May 4, 2026 — anti-evasion rulemaking is expected to scrutinize those structures specifically.

What this means for allocation

Treasury desks evaluating stablecoin yield benefit from making the Tillis-Alsobrooks distinction explicit in IC memos. StableLens encodes it via the yield_source_type + clarity_yield_status columns on public.yield_pools (F-4.c migration). Per-pool classifications are unseeded pending owner + counsel review; until seeded, all pools render a methodology classification of unclear. Rewards tied to duration / balance / tenure carry elevated banned risk pending joint rulemaking.

Filter the live universe by CLARITY treatment at /yields?clarity=allowed. Each pool’s persisted reasoning is exposed via the row tooltip on /yields. This is methodology classification, not a legal determination — see the disclaimer below.

What this is — and is NOT

StableLens evaluates how stablecoins and yield mechanisms align with the current text of selected regulatory frameworks. The CLARITY Act (H.R. 3633) is proposed legislation, not enacted law — it cleared the Senate Banking Committee 15-9 on May 14, 2026 and awaits a full Senate vote. Classifications track the published draft as of 2026-05-18 and will change as the bill moves. The GENIUS Act is enacted (effective January 18, 2027); CLARITY is not.

Yield-source classifications reflect StableLens’s reading of the Tillis-Alsobrooks compromise text. The permissible-reward definitions and anti-evasion rules require joint SEC / CFTC / Treasury rulemaking that has not yet occurred. Treat all yield classifications as provisional.

StableLens does not certify legal compliance, eligibility, registration, or issuer authorization. Classifications are methodology outputs, not legal determinations, and create no attorney-client relationship. Use as one input among many in regulatory diligence; always confirm with qualified counsel before any material decision. Methodology version, last-reviewed timestamp, and data-source disclosure: /methodology.

View full methodology →·Browse all stablecoins·llms.txt

Page last reviewed 2026-05-18. Framework status reviewed weekly. Per-coin classifications refresh on the 10-minute cron cadence shared by the rest of the StableLens platform.