July 18, 2026 marked the one-year anniversary of the GENIUS Act's enactment. We need to issue a correction to our earlier coverage, and then explain what the anniversary actually means for the RWA sector.

In our July 2 article on bank stablecoins, we reported that the GENIUS Act's implementing rules would "go live July 18." That was based on Section 13 of the Act, which directed regulators to issue implementing rules within one year of enactment. What we did not adequately flag is the distinction between the rulemaking deadline and the Act's effective date — and the fact that federal agencies missed the rulemaking deadline.

Here is the corrected picture.

The Correction: Rules Are Still at Proposal Stage

As of July 18, 2026, the implementing regulations from the OCC, FDIC, NCUA, and Treasury remain at the proposal stage — not final rules. Section 13 set a one-year deadline for regulators to issue final rules; that deadline passed without final rules being issued.

The GENIUS Act's effective date framework says the Act becomes operative on the earlier of: (a) 120 days after the primary federal regulators issue final rules, or (b) January 18, 2027. Because final rules have not yet been issued, the operative effective date is currently January 18, 2027. The OCC did issue a proposed rule on stablecoin implementation with a 60-day comment period — but a proposed rule and a final rule are different things, and the comment period has not yet closed.

We covered the July 18 date as a milestone. The milestone was real — it was the rulemaking deadline. The miss of that deadline, and the shift to a January 2027 effective date, was not something we made clear. That is the correction.

What the One-Year Anniversary Does Mean

The GENIUS Act is still law. Its framework — 1:1 reserves in cash or short-term Treasuries, OCC oversight for issuers above $10 billion, no issuer-paid yield to holders — is established statutory text regardless of when the implementing rules become final. Institutions can and are preparing for compliance. The regulatory architecture is known. What is not yet operative is the formal enforcement mechanism and the specific operational rules that licensed issuers must follow.

The practical effect: stablecoin issuers operating in the US are in a holding pattern. They know what the law requires. They are waiting for the final rules that specify exactly how to comply. The 60-day OCC comment period, once it closes, leads to a final rule — which triggers the 120-day countdown to the Act going live. At the current pace, Q1 2027 is the realistic effective date.

GENIUS Act — Corrected Status (July 23, 2026)
  • Enacted: July 18, 2025 ✅
  • Rulemaking deadline: July 18, 2026 — missed by regulators
  • Implementing rules status: Proposal stage (OCC, FDIC, NCUA, Treasury)
  • OCC proposed rule: Issued with 60-day comment period — not yet final
  • Effective date: January 18, 2027 (or 120 days after final rules, whichever is earlier)
  • Realistic effective date: Q1 2027 at current pace

What Banks Are Actually Doing

Despite the regulatory delay, major US banks have not paused their stablecoin preparation. JPMorgan moved its Kinexys deposit token onto Coinbase's Base — operating under existing regulatory authority rather than waiting for GENIUS Act rules. Societe Generale launched USD CoinVertible under European regulatory frameworks that do not depend on US rulemaking. Bank of America has confirmed intent but has not publicly announced a timeline tied to specific rule implementation.

The US-UK Transatlantic Taskforce for Markets of the Future, jointly released by Treasury and UK HM Treasury on July 14, 2026, includes recommendations on tokenized securities, stablecoins, and cross-border capital raising — signaling that the policy direction remains consistent even as the implementation timeline extends.

The Broader Lesson

Federal rulemaking timelines are consistently optimistic. The one-year statutory deadline for GENIUS Act implementing rules was always ambitious for agencies that run 60-day public comment periods and multiple rounds of interagency review. The delay does not change the Act's ultimate impact — it changes the timeline. For the RWA sector, January 2027 is the new target date to watch for the full settlement-layer implications of the GENIUS Act becoming operational.

→ Our original GENIUS Act coverage — bank stablecoins explained
→ Stablecoins and RWA: the settlement layer that connects them
→ CLARITY Act: what stalled before August recess