Treasury Proposes State-Regime Test as GENIUS Act Stablecoin Rules Take Shape

Treasury published a proposed rule on April 3, 2026 setting broad-based principles for deciding when a state stablecoin regime counts as substantially similar to the federal framework, per the Federal Register, 91 FR 16844. Four other GENIUS Act dockets remain open across the OCC, FDIC and NCUA, with a statutory deadline of July 18, 2026.

Nuv Media publishes information, not financial advice. Payment stablecoins target par value, but they are digital assets in volatile markets, and losses are possible.

What Does the April 3 Treasury Proposal Do?

It implements section 4(c) of the Guiding and Establishing National Innovation for U.S. Stablecoins Act, the July 2025 statute that created the federal framework for payment stablecoin issuance. Treasury's test decides which state-level regimes qualify as substantially similar, which determines the supervisory path for issuers chartered under state law.

Comments are due June 2, 2026, per the Federal Register notice. The proposal is procedural in nature, establishing comparison principles rather than reserve or redemption rules, and it arrives after Treasury's September 19, 2025 advance notice of proposed rulemaking on GENIUS Act implementation, which closed for comment on October 20, 2025.

Which Agency Dockets Are Still Open?

Five proposals now sit open between the banking agencies and Treasury, each mapped to a different slice of issuer charters. All dates below are from the Federal Register.

The NCUA proposal shows how the statute divides jurisdiction: it would govern payment stablecoin issuers that are subsidiaries of federally insured credit unions, and it recites the Act's requirement that the NCUA issue implementing regulations by July 18, 2026, at 91 FR 6531.

What Is Driving the July 18, 2026 Deadline?

The calendar comes from the statute itself. The GENIUS Act was signed into law on July 18, 2025, and it directed agencies to produce implementing regulations within one year, a deadline the NCUA recites in its February 12, 2026 proposal. Agencies that miss it leave issuers waiting on applications with no final processing rules.

Treasury's September 2025 ANPRM framed the shared assignment: regulations that encourage innovation in payment stablecoins while protecting consumers, mitigating illicit-finance risk and addressing financial stability risk, per the notice at 90 FR 45159. The April 3 proposal is the first Treasury document to convert that mandate into a concrete legal test.

What Should Payment Stablecoin Issuers Do Now?

Map the charter first, then the docket. An OCC-supervised entity comments through the March 2 proposal; an insured state bank planning subsidiary issuance uses the FDIC's December 2025 procedures; a credit union subsidiary faces the NCUA licensing track; and a state-chartered issuer's treatment depends on how Treasury's comparability test treats its home regulator.

Three comment windows are still open as of April 9, 2026: NCUA until April 13, OCC until May 1, and Treasury until June 2. Final rules have not been issued on any docket, so no issuer is yet operating under a completed GENIUS Act rulebook.

The stakes are operational, not just legal. These dockets will set application procedures, supervisory expectations and the boundary between state and federal oversight for a market that already settles real payment volume. Payment stablecoins aim to hold par, but crypto markets are volatile and losses remain possible regardless of which regulator supervises the issuer.