The U.S. Department of the Treasury issued a notice of proposed rulemaking (NPRM) on April 1, 2026, formally soliciting public comment on the requirements that state-level stablecoin regulatory regimes must satisfy under the Guiding and Establishing National Innovation for U.S. Stablecoins Act – commonly known as the GENIUS Act – which President Donald Trump signed into law in July 2025.
The NPRM establishes a 60-day comment window, with submissions due approximately early June 2026 and accepted through the federal public docket at regulations.gov. The action arrives as the aggregate market capitalization of dollar-pegged stablecoins approaches $300 billion, a threshold that lends the rulemaking immediate market-structure significance.
Source: Treasury.gov
The GENIUS Act permits states to license and supervise stablecoin issuers with consolidated outstanding issuance below $10 billion, provided those state frameworks do not deviate materially from federal standards – and it is precisely the definition of that deviation threshold that the NPRM is now asking the public to help sharpen.
We suspect the Treasury’s decision to open a formal rulemaking process at this stage, rather than issuing interim guidance or deferring to agency discretion, signals a deliberate effort to establish federal supremacy over the architecture of dual-track oversight before state legislatures can entrench inconsistent standards. The NPRM is less about gathering novel information and more about constructing a legally defensible record that preemptively resolves any future conflict between state certifications and federal floor requirements – a structural move consistent with how Treasury has managed regulatory sequencing in other areas of payments law.
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Uniform Requirements, Discretionary Space, and the $10 Billion Trigger on US Treasury Stablecoin
The mechanism functions as follows. The GENIUS Act creates two regulatory tracks: issuers below $10 billion in consolidated outstanding stablecoin issuance may be supervised by an approved state authority, while issuers above that threshold automatically fall under federal jurisdiction – most likely the Office of the Comptroller of the Currency – regardless of their state of incorporation or existing state licensure.
treasury just dropped its notice of proposed rulemaking (NPRM) implementing section 4(c) of the GENIUS act, the rules that will determine whether states can regulate their own stablecoin issuers or whether everyone has to go federal. this defines the terms on which the dual… pic.twitter.com/UdtSTwtmop
— Alex Thorn (@intangiblecoins) April 1, 2026
The $10 billion figure operates as a hard statutory trigger, not a supervisory discretion call, meaning growth alone can shift a firm’s primary regulator without any enforcement action or application process.
Within the state track, Treasury’s NPRM identifies a set of non-negotiable, uniform requirements from which no state framework may deviate. These include mandatory 1:1 reserve backing in cash or high-quality cash equivalents, monthly public reporting obligations, full compliance with federal anti-money laundering and sanctions regimes administered by the Financial Crimes Enforcement Network and the Office of Foreign Assets Control, and an absolute prohibition on token rehypothecation – the practice of using a single reserve asset to simultaneously collateralize multiple redemption claims. On these four categories, state rules cannot be more permissive than the federal standard; they may only be more restrictive.
States retain discretionary authority over liquidity requirements, capital buffers above the federal floor, risk management frameworks, supervisory examination procedures, enforcement mechanisms, and administrative due process rules.
The NPRM specifies that any state election to exceed federal standards in these discretionary areas is permitted – and in some interpretations, encouraged – as long as the net regulatory outcome for stablecoin holders is at a minimum as protective as the federal baseline. As the proposal states directly: “State-level regulatory regimes must lead to regulatory outcomes that are at least as stringent and protective as the Federal regulatory framework.” A newly constituted US Treasury Stablecoin Certification Review Committee, drawing participation from the Federal Reserve, FDIC, NCUA, and OCC, will evaluate submitted state frameworks for substantial similarity before approving them for operation under the dual-track system.
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Daniel Frances is a technical writer and Web3 educator specializing in macroeconomics and DeFi mechanics. A crypto native since 2017, Daniel leverages his background in on-chain analytics to author evidence-based reports and deep-dive guides. He holds certifications from The Blockchain Council, and is dedicated to providing “information gain” that cuts through market hype to find real-world blockchain utility.
