GENIUS Act's $10 Billion Rule: State or Federal Stablecoins

The first binding rule under the GENIUS Act arrived on 30 September 2026. The US Treasury published an interim final rule that sets up the committee deciding which stablecoin issuers may be supervised by a state instead of by federal regulators, and the line it works from is $10 billion of coins in circulation. Below it, an issuer can choose a state regime that has been certified. Above it, the issuer moves to the federal framework.

Key facts

• The rule: an interim final rule from the Treasury, published in the Federal Register on 30 September 2026.
• The line: $10 billion in outstanding stablecoins.
• Below it: an issuer may opt for state regulation, if that state's regime is certified as "substantially similar" to the federal one.
• Above it: the issuer has 360 days to move to the federal framework, unless it gets a waiver.
• Who certifies: the Stablecoin Certification Review Committee — the Treasury Secretary in the chair, with the heads of the Federal Reserve and the FDIC.
• Deadlines: comments close on 30 November 2026; the Act itself takes effect on 18 January 2027.

Why is there a line at all?

Because the United States has two layers of financial regulation, and the Act had to say where each applies.

States already license money transmitters and trust companies, and some built stablecoin regimes before Congress acted. The GENIUS Act keeps that route open for smaller issuers, on the condition that the state's rules are close enough to the federal ones. The committee decides what "close enough" means. This rule is its procedure.

An interim final rule takes effect when it is published and collects comments afterwards. That is unusual, and it reflects the timetable: the Act starts to bite in January, and the machinery has to exist before then.

Who is on which side?

The two largest issuers, Tether and Circle, are both far above $10 billion, so the state route is not for them. The rule matters for everyone else: the newer dollar tokens from fintechs, banks and exchanges, most of which are well below the line and would like to stay with a regulator they already know.

It also sets a ceiling on growing quietly. An issuer that succeeds under a state regime crosses the line and then has under a year to change supervisor.

What else is being written?

The reserve rules. On 24 September the Federal Reserve proposed that issuers hold their reserves almost entirely in short-term Treasury bills or assets that are comparably liquid, with standard capital and risk-management requirements on top.

In plain terms: a payment stablecoin is to be backed by the safest short-dated assets there are, and the issuer must hold a cushion of its own. Total stablecoin supply stood at $311.6 billion on 26 September, on DefiLlama's count, so these rules decide where a very large amount of money is parked.

What does it change for someone holding a stablecoin onchain?

Directly, nothing. The rule is about who supervises an issuer. The token in your wallet behaves the same.

Indirectly, it sharpens a distinction that already existed. The regulated thing is the issuer's own token on the chains where the issuer mints it. A bridged copy on another network is a different contract with a different party behind it — the argument made in full in what the GENIUS Act changes onchain. Nura Chain's USDT is of that bridged kind: an ordinary ERC-20 minted by the bridge, which creating an ERC-20 token on Nura Chain uses as a worked example.

None of this is legal advice. The rule is published in the Federal Register and the comment period is open; the US Treasury is the source for dates.