The GENIUS Act became law on July 18 after Congress settled that stablecoins should be regulated.
What happens next is a two-year rulemaking war that determines whether $250 billion in existing stablecoins flows into bank-wrapped structures or fragments into offshore silos, and whether Bitcoin and Ethereum capture the fallout or get buried under it.
Justin Slaughter, Paradigm’s VP of regulatory affairs, stated on Nov. 6:
“Little known fact—after the legislation is enacted, the real battle begins.”
His firm just filed comments on the Treasury’s advance notice of proposed rulemaking. The central fight is whether affiliates of stablecoin issuers pay yield to holders through separate products, and Congress already decided they can. Yet, Treasury might try to rewrite that.
The ability to offer yield via wrappers is where the next battle will take place. If regulators win, stablecoins become neutered bank products. If the industry wins, they compete with banks on rates.
Although the law is done, the rules are not. And the rules decide everything.
When compliance becomes mandatory
GENIUS builds a perimeter over three years, then locks the gates. The framework takes effect on Jan. 18, 2027, or 120 days after the final regulations are published, whichever comes first.
Federal agencies have one year from enactment to issue those regulations.
A three-year grace period expires July 18, 2028. After that, US exchanges, custodians, and most DeFi front ends cannot offer “payment stablecoins” unless a permitted payment stablecoin issuer or a Treasury-blessed foreign equivalent issues them.
Issuers under $10 billion can use approved state regimes, while larger issuers must migrate into the federal track. Foreign issuers need “comparable regime” determinations, OCC registration, and US-held reserves.
This timeline means that regulators will publish the rulebook by early 2027. By mid-2028, anyone touching US customers will either comply or exit.
What “into banks” actually means
GENIUS defines a protected category called “payment stablecoins” and restricts US distribution to coins issued by permitted issuers.
Those issuers must be bank subsidiaries, federally licensed nonbanks supervised by the OCC, or state-qualified entities under tight federal oversight.
Reserves must be held in cash, bank deposits, or T-bills, with no rehypothecation allowed. Disclosures submissions are made monthly, and issuers must be compliant with full prudential supervision, as well as BSA/AML compliance.
The coins are pulled into a banking-style regulatory perimeter without being called banks.
For the $304 billion stablecoin market, this creates a fork. US-touching liquidity migrates into bank-like wrappers, while everything else gets fenced off.
Offshore issuers can exist globally, but US platforms will drop them to avoid liability. There is $300 billion at stake, split between entities that meet federal standards and those that do not.
The rulemaking fight: yield, definitions, and scope
Slaughter’s comment zeroes in on affiliate yield. GENIUS prohibits issuers from paying interest but says nothing about affiliates doing so. Paradigm argues that banning affiliate yield would violate the statute’s plain language.
This matters because, if affiliates can pay competitive rates, users get high-yield savings accounts with instant settlement. That creates pressure on banks actually to return interest.
If regulators block affiliate yield, stablecoins become worse than bank deposits, with a full compliance burden, but no upside.
Other battlegrounds include the definition of the term “digital asset service provider” and whether DeFi protocols are exempt from statutory carve-outs, as well as what constitutes a “comparable regime” for foreign issuers.
Regulators could implement GENIUS as written or twist it into bank protectionism that chokes anything not wearing a federal charter.
Winners and losers
Large US banks and quasi-bank stablecoin issuers emerge as winners. GENIUS creates the first clear federal pathway for regulated institutions to issue dollar tokens with preemption over state rules.
Circle, Paxos, and PayPal rush to secure permitted issuer status. The expectation is that major banks will launch tokenized deposits and move directly onto public blockchains, rather than staying behind with ACH.
The US dollar and Treasury market also win. GENIUS mandates one-to-one backing in T-bills, making every compliant stablecoin effectively a mini T-bill fund. If this scales into the trillions, it deepens global demand for US debt.
Ethereum and layer-2 blockchains capture settlement infrastructure. US-regulated issuers overwhelmingly choose mature EVM environments.
According to rwa.xyz, Ethereum, zkSync, and Polygon have the largest participations on the real-world asset (RWA) market, amounting to $15.7 billion (44%).
Ethereum becomes the neutral rail for bank-grade dollar tokens, gaining fee flow and legitimacy as “regulated plumbing.” A large, compliant tier of DeFi builds on permitted stablecoins, coexisting with the permissionless global layer.
On the other hand, offshore issuers lose US distribution. After mid-2028, US platforms will not be able to offer any “payment stablecoin” that is not issued by a permitted issuer. Tether and similar players can serve non-US customers but lose seamless integration with Coinbase, Kraken, or major US venues.
Smaller or experimental issuers get crushed. Algorithmic stablecoins, undercollateralized experiments, and thinly capitalized startups either pivot into niche markets or shut down.
As a result, DeFi faces a split. GENIUS exempts underlying protocols and self-custody, but rulemaking will define what counts as “offering” to US persons.
If regulators stretch definitions, large parts of DeFi either filter to permitted-stablecoin-only pools for US traffic or drift into geofenced offshore silos.
How flows reroute
The first phase, from now to mid-2026, is characterized as a positioning period. Issuers and banks lobby over eligible reserves, foreign comparability, affiliate yield, and definitions. Draft rules circulate, and industry war-games compliance paths.
The second phase, spanning 2026 and 2027, is when regulatory sorting takes place. Final rules are released, early approvals are granted to large, compliant entities, and names are revealed. US platforms migrate volume toward “soon-to-be permitted” coins, while noncompliant issuers file, geo-fence US users, or lean into offshore venues.
The third phase, spanning from 2027 to 2028, is the hardening of routes. US-facing exchanges, brokers, and many DeFi front ends primarily list permitted stablecoins, with potential for deeper liquidity on Ethereum and layer-2 blockchains.
Noncompliant stablecoins persist on offshore exchanges and gray-market DeFi but lose connectivity to fully regulated US rails.
The expected result is a larger share of “crypto dollars” becoming fully reserved, supervised, KYC’d, and sitting inside or adjacent to bank balance sheets. On-chain settlement starts to look less like a pirate market and more like Fedwire with APIs.
| Stage | Date / Window | Key Action | Lead Agencies & Milestones |
|---|---|---|---|
| Passage (GENIUS Act becomes law) | July 18, 2025 | GENIUS Act (Public Law 119–27) signed. Establishes “permitted payment stablecoin issuer” regime, bans yield on payment stablecoins, sets 3-year distribution clock, and hardwires the effective date as the earlier of (i) 18 months after enactment or (ii) 120 days after final regs by primary regulators. | Treasury + “primary Federal payment stablecoin regulators” (Fed, OCC, FDIC, NCUA) are formally tasked with building the rulebook (Section 13). |
| ANPRM – Implementation Kickoff | Sept 19, 2025 | Treasury issues Advance Notice of Proposed Rulemaking (ANPRM) on GENIUS Act implementation. It asks detailed questions on issuer eligibility, reserves, foreign/comparable regimes, illicit finance, tax, insurance, and data—this is the opening shot in defining how strict or flexible GENIUS will be. | Treasury leads docket TREAS-DO-2025-0037 and signals coordination with Fed, OCC, FDIC, NCUA, and state regulators. Those agencies begin internal workstreams (FSOC/FDIC/NCUA speeches flag GENIUS implementation as a priority). |
| Proposed Rules (NPRMs) | Expected 1H 2026 | Next step: Treasury plus each primary regulator publish proposed rules (NPRMs) translating GENIUS into concrete requirements: licensing standards for PPSIs, capital/liquidity, reserve composition, examinations, foreign issuer “comparability,” and conditions for digital asset service providers. These must come early enough to finalize within the statutory one-year rulemaking window. | Statute (Sec. 13) requires Treasury, Fed, OCC, FDIC, NCUA, and state regulators to “promulgate regulations” within 1 year of enactment → practical pressure to get NPRMs out in early 2026 so finals can land by July 18, 2026. This is the core battleground Justin Slaughter & others are pointing to. |
| Final Rules | Statutory deadline: by July 18, 2026 | Final regulations by the “primary Federal payment stablecoin regulators” + Treasury lock in who can be a PPSI, how reserves work, supervision expectations, and how foreign and state regimes are recognized. These final rules also start the 120-day clock that can accelerate GENIUS’s effective date. | Fed, OCC, FDIC, NCUA each finalize regs for issuers under their jurisdiction; Treasury finalizes cross-cutting rules (safe harbors, comparability, illicit finance). Collectively, these rules are what can start the effective-date countdown under Sec. 20. |
| Earliest GENIUS Effective Date | Earlier of: (a) Jan 18, 2027 (18 months after enactment), or (b) 120 days after final regs | GENIUS framework (and amendments) “turn on” at whichever comes first. If regulators slip on final rules, the 18-month mark (Jan 18, 2027) becomes the default effective date. If they move fast and finalize early, the 120-day rule can pull the effective date forward. | Practically: this is the pivot point your article should highlight—when stablecoin issuance and U.S.-facing distribution must begin lining up with PPSI rules, and when markets start rerouting toward bank-like, GENIUS-compliant |
What it means for Bitcoin and Ethereum
For Bitcoin, GENIUS is a narrative tailwind. As stablecoins become more bank-like and subject to regulation by US authorities, Bitcoin stands out as the censorship-resistant asset that remains outside this perimeter.
Short-term liquidity is fine, as permitted stablecoins will be everywhere US-regulated BTC venues are. If noncompliant stablecoins shrink, some high-friction flows will pivot to BTC pairs.
In the long term, GENIUS domesticates the dollar side of crypto, making Bitcoin the cleanest way to step outside the new perimeter.
For Ethereum, GENIUS potentially brings a new level of scale if things remain as they are today. Permitted issuers prefer EVM chains with mature infrastructure and deep DeFi capabilities.
That is structurally supportive of ETH as gas and settlement infrastructure for regulated stablecoin payments and tokenized assets.
As a result, a two-tiered DeFi ecosystem might emerge. One tier consists of permissioned, GENIUS-compliant pools with institutional capital, and permissionless global pools hosting any coin. Censorship risk exists in this tier, but that increases the value of credible neutrality at the protocol level.
The other tier is formed by bank-grade, trillion-scale dollar tokens settling on Ethereum, making blockspace a valuable infrastructure.
The fight is over the rules. Treasury, the Fed, and the OCC write them between now and mid-2026. By 2027, the market learns what GENIUS actually built. By 2028, capital will flow into banks, onto Ethereum, or offshore.
