An Interactive Guide to GENIUS Implementation

Last summer, Congress passed the GENIUS Act, the first-ever federal crypto law, which establishes a framework for the issuance of payment stablecoins in the United States. It was a historic moment, but passage of this law only kicks off the next part of the process: rulemaking.

The rulemaking process is where agencies translate Congress’s mandate into the binding rules that will govern how stablecoins are issued, reserved, and overseen. 

This is why we’ve built the GENIUS Act Tracker. It started as an internal tool for the Paradigm Policy team, a way to keep tabs on which agencies were doing what and when. Then, we kept hearing the same questions from founders, lawyers, Hill staffers, and policy watchers across the space. So: we’re making it public.

How rulemaking works

When Congress passes a law, it grants agencies broad authority rather than explicit instructions. The binding rules come to life through a process governed by the Administrative Procedure Act (APA). The Act requires agencies to publish proposed rules and open them for public comment, and take into account those comments before issuing a final rule. This process is designed to ensure participation and transparency, but can take months to years to complete.

Zoom

There are up to three stages in the rulemaking process. Agencies typically begin with an Advance Notice of Proposed Rulemaking, or ANPRM, which is an early request for input before a formal proposed rule is drafted. Some agencies, on some rules, skip the ANPRM process and go straight to a proposed rule, or NPRM. This puts a specific proposed rule out for public comment, typically for 30 to 60 days. Anyone (companies, universities, retail users, lawmakers, the general public) can weigh in, and agencies then are legally required to consider what they say. The Final Rule then follows, (sometimes months later, sometimes years) and includes an effective date that sets when the finalized requirements kick in.

The problem, however, is that there is no central place tracking all of this for any given law. This tracker is meant to address this very issue, specifically for the GENIUS Act.

What’s in the tracker

The GENIUS Act requires 21 rulemakings from agencies spanning the Treasury and the prudential regulators: the OCC, the NCUA, the FDIC, and the FRB. The rulemakings to watch closely are those touching reserve requirements and permissible backing reserve assets. The OCC's rules around federal non-bank charters are equally consequential: how broadly or narrowly the agency defines eligibility will shape who can issue in the first place. And then the most politically fraught subject matter is the ability of intermediaries to share stablecoin backing reserve yield with users and ecosystem participants.

The tracker lists all rulemakings, sortable by agency, publication status, and type. Each entry includes the relevant bill section, the responsible agency, whether the rule is required or discretionary, Paradigm’s commentary on rules with which we engaged, a full progress timeline from ANPRM through effective date, and public comments submitted on each rulemaking.

A note on timing

Federal agencies have one year from enactment (until July 18, 2026) to complete most required rulemakings, with full implementation taking effect 18 months after enactment (January 18, 2027). While the regulators have expressed their commitment to completing the GENIUS rulemakings on time, the timeline is an official one, but probably not the real one. 

The reason being: there are no real consequences for agencies that miss this “soft” deadline, and Washington has a long track record of running late. For example, the Dodd-Frank Act, signed in 2010, mandated over 400 rulemakings. As of today, dozens remained incomplete, and a handful of significant rules have never been finalized at all. The GENIUS Act is a fraction of that scale, but the dynamic is the same: Congressional deadlines for rulemakings are important, but frequently aspirational.

The process is just getting started. We’ll keep the tracker updated as rulemakings progress. If you’re building in this space and have questions, reach out.