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 2026-07-18. 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 July 18, 2025. Its one-year statutory rulemaking deadline falls July 18, 2026 — six federal agencies (OCC, FDIC, NCUA, Treasury, FinCEN, OFAC) are finalizing implementing rules. The Act takes effect the earlier of January 18, 2027 or 120 days after final rules. OCC's proposal sets a $5M minimum capital floor and same-day redemption liquidity tiers; the FDIC confirms stablecoin holders receive no deposit insurance. Issuers are prohibited from paying yield to holders for holding the token; OCC proposed rules would extend that 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$183.01BBWatchPendingSee issuer
USDC
USD Coin
Circle$71.81BAApprovedPendingSee issuer
USDS
USDS
Sky (formerly MakerDAO)$9.79BC+WatchPendingSee issuer
DAI
Dai
MakerDAO$4.57BC+WatchPendingSee issuer
USD1
USD1
World Liberty Financial$4.01BCWatchPendingSee issuer
USDE
Ethena USDe
Ethena Labs$3.96BCWatchPendingSee issuer
USDG
Global Dollar
Paxos$3.47BAApprovedPendingSee issuer
PYUSD
PayPal USD
Paxos / PayPal$2.78BA+ApprovedPendingSee issuer
XAUT
Tether Gold
Tether$2.67BDAvoidPendingSee issuer
USDY
Ondo US Dollar Yield
Ondo Finance$2.14BB-WatchPendingSee issuer
PAXG
PAX Gold
Paxos$1.91BDAvoidPendingSee issuer
RLUSD
Ripple USD
Ripple$1.72BAApprovedPendingSee issuer
USDD
USDD
TRON DAO Reserve$1.54BBWatchPendingSee issuer
USDF
Falcon USD
Falcon Finance$1.34BB-WatchPendingSee issuer
BFUSD
BFUSD
Binance$1.32BB-WatchPendingSee issuer
U
United Stables
$1.24BDAvoidPendingSee issuer
USDGO
USDGO
Anchorage Digital Bank N.A.$1.19BA-WatchPendingSee issuer
GHO
GHO
Aave DAO$698MC+WatchPendingSee issuer
YLDS
YLDS
$679MDAvoidPendingSee issuer
USD0
Usual USD
Usual Protocol$551MB-WatchPendingSee issuer
TUSD
TrueUSD
Archblock (TrustToken)$494MB+WatchPendingSee issuer
EURC
EURC
Circle$469MDAvoidPendingSee issuer
A7A5
A7A5
$462MFAvoidPendingSee issuer
USDTB
USDtb
Ethena Labs$358MBWatchPendingSee issuer
FDUSD
First Digital USD
First Digital Labs$351MB+WatchPendingSee issuer
KAU
Kinesis Gold
Kinesis Money$336MDAvoidPendingSee issuer
APXUSD
apxUSD
$303MDAvoidPendingSee issuer
BUSD
Binance-Peg BUSD
Binance (Paxos)$284MB-WatchPendingSee issuer
KAG
Kinesis Silver
Kinesis Money$239MDAvoidPendingSee issuer
FRAX
Frax
Frax Finance$217MC+WatchPendingSee issuer
CRVUSD
crvUSD
Curve Finance$215MC+WatchPendingSee issuer
AUSD
AUSD
$213MCWatchPendingSee issuer
USAT
USAT
$185MDAvoidPendingSee issuer
EURCV
EUR CoinVertible
$163MFAvoidPendingSee issuer
GUSD
GUSD
Gemini Trust Company$150MAApprovedPendingSee issuer
AVUSD
Avant USD
$127MCWatchPendingSee issuer
JPYSC
JPYSC
$126MFAvoidPendingSee issuer
CASH
CASH
$122MDAvoidPendingSee issuer
AIDAUSDC
Gaib AI Dollar Alpha USDC
$115MDAvoidPendingSee issuer
USDC.N
Noble USDC
$114MCWatchPendingSee issuer
FRXUSD
Frax USD
Frax Finance$113MBWatchPendingSee issuer
CUSD
Cap USD
Cap Finance$102MBWatchPendingSee issuer
USDAT
Saturn Dollar
$95MCWatchPendingSee issuer
USDA
USDa
Angle Protocol$95MC+WatchPendingSee issuer
PGOLD
Pleasing Gold
$85MFAvoidPendingSee 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
$75MDAvoidPendingSee issuer
BRLV
Crown BRLV
$72MFAvoidPendingSee issuer
USDON
Ondo U.S. Dollar Token
$70MCWatchPendingSee issuer
TRUSD
Tori trUSD
$64MDAvoidPendingSee issuer
FXUSD
f(x) Protocol fxUSD
$62MCWatchPendingSee issuer
REUR
Royal Euro
$62MFAvoidPendingSee issuer
DUSD
StandX DUSD
$61MCWatchPendingSee issuer
CHFAU
AllUnity CHF
$59MFAvoidPendingSee issuer
PMUSD
Precious Metals USD
$57MDAvoidPendingSee issuer
XDAI
XDAI
$56MDAvoidPendingSee 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.

GENIUS Act — frequently asked

Common questions about the GENIUS Act and how StableLens reads it. These are methodology explanations, not legal advice — see the disclaimer below.

When does the GENIUS Act take effect?
The GENIUS Act was enacted July 18, 2025. Its implementing rules were due at the one-year statutory deadline of July 18, 2026, with six federal agencies — the OCC, FDIC, NCUA, Treasury, FinCEN, and OFAC — responsible for finalizing them. The Act itself takes effect the earlier of January 18, 2027, or 120 days after the final rules are issued.
Is a specific stablecoin like USDC or USDT 'GENIUS Act compliant'?
StableLens does not certify legal compliance, eligibility, or issuer authorization. What we publish is a methodology classification of how each stablecoin's public data aligns with the GENIUS Act framework — shown as the GENIUS alignment column in the per-coin matrix above. Treat it as one diligence input, not a legal determination, and confirm any compliance question with qualified counsel.
What is a permitted payment stablecoin issuer (PPSI)?
Under the GENIUS Act, a permitted payment stablecoin issuer (PPSI) is an entity authorized to issue a payment stablecoin in the United States — for example a subsidiary of an insured depository institution, a federally qualified nonbank issuer approved by the OCC, or a state-qualified issuer under an approved state regime. Treasury rulemaking treats PPSIs as financial institutions for Bank Secrecy Act and anti-money-laundering purposes.
Do stablecoin holders get FDIC deposit insurance under the GENIUS Act?
No. The FDIC has confirmed that payment stablecoin holders do not receive deposit insurance, regardless of whether the issuer is affiliated with a bank. A stablecoin is a claim on the issuer's reserves, not an insured bank deposit — a structural distinction the StableLens methodology weights under reserves and regulatory status.
Can a stablecoin pay yield to holders under the GENIUS Act?
The GENIUS Act prohibits permitted issuers from paying yield or interest to holders simply for holding the token, and the OCC's proposed rules would extend that prohibition to affiliates and third parties. Yield tied to bona-fide activity — such as lending or liquidity provision through a separate protocol — is a distinct question that the StableLens yield-source taxonomy tracks on the /yields surface.

See each coin’s GENIUS alignment in the per-coin matrix above, or browse all stablecoins.

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 2026-07-18 and will change as the bill moves. The GENIUS Act is enacted, with implementing rules due at its one-year statutory deadline (July 18, 2026) and the Act effective the earlier of January 18, 2027 or 120 days after final rules; CLARITY is not enacted.

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 2026-07-18. Framework status reviewed weekly. Per-coin classifications refresh on the 10-minute cron cadence shared by the rest of the StableLens platform.