The Stablecoin Law Starts in 116 Days. No Rule Is Final.

The American law that governs dollar stablecoins takes effect on 18 January 2027. That is 116 days from today. Not one of the rules that is supposed to make it work has been finalised.

HaiPay counted the Federal Register, the official journal in which US agencies publish rules. Since the GENIUS Act was enacted on 18 July 2025, agencies have published 19 proposed rules that use the statutory term "payment stablecoin". Sixteen of those comment periods have already closed. The number of final rules implementing the Act is zero.

Why the date arrives anyway

The Act sets its own start. It takes effect on the earlier of two dates: 18 months after enactment, or 120 days after the federal stablecoin regulators issue final implementing regulations.

The second route is now out of reach. A final rule published today would not take effect until late January anyway, and nothing has been finalised. So the law starts on the 18-month clock, on 18 January 2027, with the rulebook still in draft.

The Office of the Comptroller of the Currency spells the mechanism out in its own proposal of 2 March 2026, which cites the statute directly.

Who is writing what

The work is spread across most of the federal banking apparatus.

Counting every Federal Register document that mentions stablecoin in 2026, and noting that each document can be tagged to more than one agency, the Treasury Department appears on 18, the Securities and Exchange Commission on 11, the Federal Deposit Insurance Corporation on 10, the Office of the Comptroller of the Currency on nine, the Federal Reserve on six, the Financial Crimes Enforcement Network on five and the National Credit Union Administration on three. The OCC and FinCEN sit inside Treasury, so those tags overlap.

The proposals cover the parts a stablecoin business actually needs settled: who may be approved to issue, what reserves and capital look like, how anti-money-laundering programmes must work, what a customer identification programme must contain, and the test for whether a state regime is substantially similar to the federal one.

The core issuance rule, Treasury's "GENIUS Act Regulations on Payment Stablecoin Issuance, Offer, and Sale", was published on 18 August. Comments close on 19 October, three months before the statute bites.

The volume is real, the output is not

The rulemaking is not slow because nobody is working. Federal Register documents mentioning stablecoin rose from 16 in 2023 to 20 in 2024, 27 in 2025 and 47 so far in 2026. Use of the statutory phrase "payment stablecoin" went from three documents in 2025 to 30 this year.

Only three documents published in 2026 with the word stablecoin in them are final rules, and none of them implements the Act. One is a crypto-asset securities rule, one is a tax rule about tipped occupations, and one is a supervisory practices rule.

That gap between activity and finality is the whole story. Comment letters have been filed, hearings held and proposals stacked up, and an issuer looking for the finished requirements still has nothing to read but drafts.

What this means for a payments business

Anyone planning to issue a dollar stablecoin in the United States, or to distribute one, is now choosing between two uncomfortable options: build to the proposed text and accept that final rules may differ, or wait and lose four months of runway.

The Act's other dates keep running regardless. The prohibition on digital asset service providers offering stablecoins that are not issued by compliant issuers begins on 18 July 2028, and the approval process for issuers sits in proposals that are not yet law.

What this count is not

HaiPay counted documents, not pages or importance. A Federal Register document that mentions stablecoin once is counted the same as one devoted to it, which is why the article separates the broad count from the 19 proposals that use the statutory term.

A missing final rule is not evidence that any agency has missed a legal deadline. HaiPay found no statutory deadline in the Act requiring final rules by a given date; the 18-month clock sets when the law applies, not when regulators must finish.

Rules can also be finalised quickly once comment periods close, and several closed months ago. HaiPay did not contact any agency.

What to watch

Whether any agency publishes a final GENIUS rule before 18 January, and whether it uses the 120-day route or simply lands after the statute is already in force.

The Treasury issuance rule after 19 October, the one proposal whose final text decides most of what an issuer must do.

And whether agencies use interim final rules, which take effect without a further comment round, as the date closes in.