Under a Sept. 30 Treasury rule, states can keep a clear path open toward stablecoin-regime approval even if their regulations are still unfinished. They can do this by submitting an initial certification on time and finalizing the remaining work prior to any substantive review.
The interim final rule establishes the necessary forms and review protocols for the Stablecoin Certification Review Committee, which is the federal agency tasked with evaluating state stablecoin frameworks. According to the Committee, incomplete or conditional certifications can fulfill the initial filing deadline, even if the state still has planned regulatory or legislative steps to complete.
Although the rule took effect on Sept. 30, certifications will not be officially accepted until the information collection receives Paperwork Reduction Act approval. Treasury will issue a notice to announce when submission intake officially opens.
This flexibility is significant for state-qualified payment stablecoin issuers holding no more than $10 billion in consolidated outstanding payment stablecoin issuance. These entities may choose state oversight provided that the state regulator certifies its framework matches Treasury’s substantial-similarity requirements, and the Committee unanimously grants approval indicating the regime meets or exceeds the standards outlined in section 4(a) of the GENIUS Act.
A separate Treasury proposal covers the substantial-similarity standards used to evaluate state systems against federal ones, though the September procedural rule does not finalize those principles.
How a filing reaches substantive review
Conditional filings may be updated at any point. They do not trigger a substantive review or launch the Committee’s 30-day window to approve or deny a request. That timeframe only begins once a properly completed certification is submitted according to established procedures.
To reach that stage, a state must supply an unconditional attestation executed by an authorized official, a thorough breakdown explaining how its framework satisfies Treasury’s similarity guidelines, relevant legal documentation, and any other data the Committee requests.
This approach allows states time to complete their regulatory or legislative processes after the initial deadline passes. However, it does not automatically grant approval to their regimes or issue licenses to specific stablecoin operators.
Previous coverage by CryptoSlate in July highlighted the challenges of evaluating state equivalence while rules from Treasury, the OCC, and federal agencies remained incomplete. The updated rule introduces necessary forms and procedures—including flexibility for early filings—while preserving strict substantive approval criteria.
Based on an anticipated effective date of Jan. 18, 2027, for the GENIUS Act, the rule establishes Jan. 18, 2028, as the target for initial certifications. The statutory deadline requires filings to be submitted within one year of the Act taking effect.
The legislation could also become effective sooner. Section 20 specifies a timeline of 18 months after enactment or 120 days following the issuance of any final implementing regulations by primary federal payment stablecoin regulators, whichever comes first.
Public comments on the interim procedures must be submitted by Nov. 30.