The GENIUS Act, enacted July 18, 2025, created a federal framework for payment stablecoins, but it does not give every business a three-year transition period. In an op-ed for Kelman.Law, Michael Handelsman says the Act generally takes effect on the earlier of 18 months after enactment or 120 days after federal regulators issue final implementing rules; Treasury expects January 18, 2027. A separate restriction on certain offers and sales to U.S. persons begins July 18, 2028, subject to statutory qualifications and exceptions. That later date does not postpone existing legal duties or other provisions taking effect sooner.
Handelsman says requirements depend on whether a business issues stablecoins, distributes them, holds them or accepts them as payment. Federal Reserve rules announced September 24, 2026 remain proposals. An interim final rule effective September 30, 2026 established procedures for state-regime certifications, but acceptance of certifications still depends on information-collection approval and a Treasury notification.
