The US Treasury issued a Notice of Proposed Rulemaking (NPRM) on April 1, 2026, formally soliciting public comment on the requirements that state-level stablecoin regulators must meet under the US Stablecoin National Innovation Guidance and Establishment Act – known as the GENIUS Act – which President Donald Trump signed into law in July 2025.
The NPRM creates a 60-day comment window, with applications due around early June 2026 for submission and acceptance through the public federal list at communications.gov. This action comes as the total market value of dollar-pegged stablecoins approaches $300 billion, a threshold that makes setting rules in the market structure immediately important.
source: Department of Treasury.gov
The GENIUS Act allows states to license and supervise stablecoin issuers with less than $10 billion in outstanding consolidated issuances, provided that these state frameworks do not deviate materially from federal standards — setting the deviance threshold that the NPRM is now asking the public to help sharpen.
We believe that Treasury’s decision to open a formal rulemaking process at this point, rather than issuing interim guidance or deferring to agency discretion, indicates a deliberate effort to establish federal supremacy over the dual-track oversight structure before state legislatures can entrench inconsistent standards. The NPRM is less about collecting new information and more about building a legally defensible record that proactively resolves any future conflicts between state certifications and federal minimum requirements—a structural move consistent with how the Treasury Department manages its regulatory hierarchy in other areas of payments law.
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Standardized requirements, discretionary space, and value of $10 billion for the US Treasury stablecoin
The mechanism works as follows. The GENIUS Act creates two regulatory paths: Issuers with less than $10 billion in consolidated stablecoin issuance may be supervised by an authorized government authority, while issuers above this threshold automatically fall under federal jurisdiction—most likely the Office of the Comptroller of the Currency—regardless of their state of incorporation or current state license.
Treasury just dropped its Notice of Proposed Rulemaking (NPRM) to implement Section 4(c) of the GENIUS Act, rules that will determine whether states can regulate their own stablecoin issuers or whether everyone will have to turn to the federal government. This sets the conditions under which the dual… pic.twitter.com/UdtSTwtmop
– Alex Thorne (@intangiblecoins) April 1, 2026
The $10 billion figure acts as a strong legal trigger, rather than a call for supervisory discretion, meaning that growth alone can transform a company’s primary regulator without any enforcement action or application process.
Under the State Path, the National Policy Mechanism of the Ministry of the Treasury sets out a set of uniform, non-negotiable requirements from which no government framework may deviate. These include a mandatory 1:1 reserve backing in cash or high-quality cash equivalents, monthly public reporting obligations, full compliance with anti-money laundering and federal sanctions regulations administered by the Financial Crimes Enforcement Network and OFAC, and an absolute prohibition on token re-hypothecation – the practice of using a single reserve asset to secure multiple redemption claims simultaneously. In these four categories, state rules cannot be more lenient than the federal standard; It might just be more restrictive.
Countries Retain discretion over liquidity requirements, capital buffers above federal minimums, risk management frameworks, supervisory examination procedures, enforcement mechanisms, and administrative due process rules.
The NPRM states that any state elections that exceed federal standards in these discretionary areas are permissible — and, in some interpretations, encouraged — as long as the net regulatory outcome for stablecoin holders is at least as protective as the federal baseline. As the proposal directly states: “State-level regulatory regimes must produce regulatory outcomes that are at least as stringent and protective as the federal regulatory framework.” The US Treasury’s newly formed Stablecoin Certification Review Committee, with participation from the Federal Reserve, FDIC, NCUA, and OCC, will evaluate submitted country frameworks for significant similarity before approving them for operation under the dual-track system.
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Daniel Francis is a technical writer and Web3 educator specializing in macroeconomics and DeFi mechanics. A crypto native since 2017, Daniel brings his background in cross-chain analytics to author evidence-based reports and detailed guides. It is certified by the Blockchain Council and is dedicated to providing “information gain” that cuts through the market noise to find the real-world utility of blockchain.
