GENIUS Act Explained: What the Stablecoin Law Means for Merchants
The GENIUS Act stablecoin law regulates issuers, not merchants. See which dates matter for your checkout and when accepting stablecoins actually pays off.
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On this page 6 sections
- What the GENIUS Act Stablecoin Law Covers, and What It Leaves to Merchants
- July 18, 2028 Is the Date That Reaches Your Checkout
- How Stablecoin Settlement Differs From a Card Sale
- Worked Example: A $25,000 Invoice From an Overseas Buyer
- Which Merchants Should Test Stablecoin Acceptance
- Two Questions for Your Provider Before July 2028
The GENIUS Act regulates the companies that issue dollar stablecoins, not the merchants who accept them. It creates no duty to accept coins and gives payers no chargeback rights. For merchants weighing stablecoins, two dates matter: the issuer licensing rules are expected to take effect January 18, 2027, and on July 18, 2028, exchanges and similar providers generally lose the right to offer unlicensed coins to people in the U.S.
The law makes stablecoins safer to hold, not a better way for most U.S. businesses to get paid. The exception is a seller whose overseas buyers already hold dollar stablecoins, and even there the worked example below shows the case is narrower than the pitch.
This article is general information, not legal or tax advice. Several implementing rules were still proposals in late October 2026. Confirm current requirements with qualified professionals before acting.
What the GENIUS Act Stablecoin Law Covers, and What It Leaves to Merchants
The Senate Banking Committee advanced the Guiding and Establishing National Innovation for U.S. Stablecoins Act 18–6 on March 13, 2025, according to its legislative history. The Senate passed it 68–30 on June 17 and the House 308–122 on July 17. The president signed it on July 18, 2025, making it Public Law 119-27, per the Congress.gov record for S. 1582.
The law covers payment stablecoins: digital assets issued for payment or settlement and redeemable at a fixed amount such as $1, as the Congressional Research Service overview defines them. Bitcoin and other floating-price crypto assets fall outside it.
Most of the statute is about issuers. A U.S. issuer must be a subsidiary of an insured bank or credit union, a federally qualified nonbank issuer or a state-qualified issuer, supervised by the matching regulator. Every $1 of coins outstanding needs at least $1 of permitted reserves, which CRS lists as cash, insured deposits, short-dated Treasury bills, Treasury-backed repos, government money market funds and a few similar government assets. Issuers also can't pay holders interest or yield, a ban the Office of the Comptroller of the Currency (OCC) spells out in its proposed rules.
The business on the receiving end of a payment gets almost nothing new:
- No obligation to accept. Taking stablecoins stays a business choice.
- No dispute rights. The law creates nothing like a card chargeback. Visa and Mastercard rules for card sales are unchanged.
- No fee limits. Nothing caps what a provider charges to convert your coins to dollars.
- No deposit insurance. A stablecoin balance is a claim on a private issuer, not a bank deposit, so FDIC coverage doesn't apply.
- No tax guidance. How to record receipts and conversions is a question for your CPA.
Your existing obligations stay put. The OCC's proposal preserves state consumer protection laws, as Troutman Pepper Locke notes, so refund and pricing disclosure rules still apply. So does sanctions screening, covered in our guide to OFAC sanctions screening for online sellers. Marketplaces that hold money for sellers should ask counsel whether money transmission licensing applies.
July 18, 2028 Is the Date That Reaches Your Checkout
Under the enacted text, the law takes effect 18 months after enactment or 120 days after the primary federal stablecoin regulators issue final rules, whichever comes first. Treasury's August 2026 announcement names January 18, 2027 as the expected date. From then, issuing a payment stablecoin in the U.S. generally requires a federal or state license.
| Date | Rulemaking Step |
|---|---|
| September 2025 | Treasury advance notice of proposed rulemaking, after an August 2025 request for comment (KPMG) |
| February 25, 2026 | OCC issued its proposal on licensing, reserves, custody and capital (Mayer Brown); it was published in the Federal Register March 2, and comments closed May 1 |
| August 18, 2026 | Treasury's proposed rule on issuance, offer and sale published |
| October 19, 2026 | Comments on the Treasury proposal closed (Sheppard Mullin) |
KPMG's August alert said final rules had no clear release date and the Federal Reserve hadn't yet released its proposals. Jones Day expected final rules to come too late to pull the date forward, which leaves January 18, 2027.
That date changes nothing at your checkout, because it governs who may issue coins. The merchant date is July 18, 2028. From then, a digital asset service provider generally may offer or sell a payment stablecoin to people in the U.S. only if a licensed U.S. issuer or a qualifying foreign issuer issued it, according to Freshfields. Jones Day notes the law defines those providers broadly to include U.S. businesses that exchange or hold digital assets for others. A provider that converts your coins to dollars may well qualify. If a coin you accept isn't from a qualifying issuer by then, your provider may have to drop it.
How Stablecoin Settlement Differs From a Card Sale
"Accepting stablecoins" can mean a wallet you control, where converting to dollars is your job, or an acceptance provider that receives the coins and deposits dollars in your bank. In a third version, stablecoins move between banks behind the scenes and you see normal dollar settlement, as with Mastercard's stablecoin settlement platform for processors.
| Factor | Card Payments | Direct Stablecoin Payments |
|---|---|---|
| Approval | Issuing bank approves or declines | Goes through if the wallet has funds |
| Timing | Deposited in batches, usually within a few business days | Confirms on-chain in minutes or less, any day of the week |
| Reversals | Chargebacks under network rules | Generally final; a refund is a new outbound transfer |
| Costs | Interchange plus network and processor fees | Blockchain fees plus provider conversion fees |
| Reconciliation | Processor reports match your batches | You match transaction hashes to orders |
No chargebacks cuts both ways: you shed friendly fraud but lose a structured way to settle real problems, and some buyers won't pay without recourse.
Worked Example: A $25,000 Invoice From an Overseas Buyer
Every number in this example is illustrative, not a quote from MannyPay or any provider.
A U.S. wholesaler invoices an overseas distributor $25,000, and the distributor already holds dollar stablecoins. Assume the card route costs the seller 3.5% all in. A wire costs the seller a $25 incoming fee, with the buyer covering its own sending costs. An acceptance provider charges 1% to convert coins to dollars, and the blockchain fee is $1.
| Payment Route | Seller's Cost | Calculation |
|---|---|---|
| Card | $875 | $25,000 × 3.5% |
| Stablecoin via provider | $251 | ($25,000 × 1%) + $1 |
| International wire | $25 | Flat incoming fee |
The stablecoin beats the card by $624 but loses to the wire by $226. So the real case is speed: a payment that confirms on a Saturday from a buyer who would rather skip its bank's wire desk.
Now suppose the order is canceled. Buying $25,000 of coins back for the refund costs another $251 under the same assumptions, so the canceled sale costs about $502 and earns nothing.
If your card cost on large invoices sits well below 3.5%, the advantage shrinks. If your buyers are domestic, it may vanish, since they already have fast rails, compared in our guide to RTP, FedNow and ACH.
Which Merchants Should Test Stablecoin Acceptance
This section is Beyond the Swipe editorial analysis.
A test makes sense when customers are already asking to pay in stablecoins, a real share of revenue comes from abroad, invoices are large and refunds are rare. Without those, cards, ACH and pay-by-bank options cover your needs.
B2B sellers with overseas buyers have the strongest case, for the reasons in the example. Online stores with crypto-native customers can add stablecoins as an extra checkout option while cards stay the default. Marketplaces often gain more from faster seller payouts, such as stablecoin funding for Visa Direct payouts. In travel, routine cancellations turn every stablecoin refund into a manual transfer, so card-based travel payment processing stays the better default.
If you run a pilot, keep it small:
- Use a provider that converts to dollars on receipt, so price swings stay off your books.
- Accept a short list of coins, favor licensed issuers once licenses are granted, and check the provider's enforcement history; our piece on vetting your crypto payment partner lists the questions.
- Publish a refund policy covering the refund currency and wallet address checks. A refund sent to a wrong address usually can't be recovered.
- Record each payment's coin, blockchain, dollar value at receipt, transaction hash and matching invoice.
- Get sign-off from your CPA and counsel before the first sale, then cap volume for a set review period.
Pegged doesn't mean fixed. Under the OCC's proposal, an issuer would have to hold reserves equal to the full par value of its coins even if the market price dips, Mayer Brown notes. That protects redemption, not the price you get on a bad day, so convert promptly. Coins from issuers outside the new regime raise more questions, as our coverage of the Senate probe into Tether's U.S. payments shows.
Stablecoins are not a workaround for underwriting. If a product can't be approved for card processing, taking crypto doesn't change the rules that apply to it, and acceptance providers screen for this. Merchants in regulated categories should start with a high-risk merchant account.
Two Questions for Your Provider Before July 2028
Over the next few months, watch for final rules from the OCC and the other federal bank regulators, and for the first issuer licenses. If you accept stablecoins or plan to, email your provider now. Ask which coins it will support after July 18, 2028, and what a refund costs.
If cross-border sales are driving your interest, MannyPay's international payment processing includes multi-currency acceptance, cross-border acquiring paths and review of USD or local-currency settlement. To compare them with what you pay now, request a free quote; a MannyPay specialist responds within one business day.
Sources
- GENIUS Act (Wikipedia, legislative history dates)
- All Information for S.1582, GENIUS Act, 119th Congress (Congress.gov)
- Text of S.1582, Public Law 119-27 (Congress.gov)
- Stablecoin Legislation: An Overview of the GENIUS Act of 2025 (P.L. 119-27) (Congressional Research Service)
- GENIUS Act Implementation: OCC Issues Proposed Rules (Sullivan & Cromwell, March 2026)
- OCC Unveils Sweeping GENIUS Act Stablecoin Proposed Rule (Troutman Pepper Locke, April 2026)
- OCC Proposes Comprehensive Rulemaking to Implement the GENIUS Act (Mayer Brown, March 2026)
- Implementing the GENIUS Act for the OCC (Federal Register, March 2, 2026)
- Treasury Seeks Public Comment on GENIUS Act Proposed Rulemaking (U.S. Treasury)
- GENIUS Act Regulations on Payment Stablecoin Issuance, Offer, and Sale (Federal Register, August 18, 2026)
- GENIUS Act: Treasury Proposal for Issuance, Offer, and Sale of Payment Stablecoins (KPMG, August 2026)
- U.S. Treasury Proposes GENIUS Act Rules (Jones Day, August 2026)
- Treasury Proposes GENIUS Act Gatekeeping Rules with a Path for Foreign Issuers (Freshfields)
- Treasury Proposes GENIUS Act Rules for Stablecoin Issuance and Sales (Sheppard Mullin, August 2026)
This article is for general educational purposes and is not legal, tax or financial advice. Card network rules and state laws change; confirm current requirements for your business.
