The four US agencies tasked with implementing the GENIUS Act — the Treasury Department, the Office of the Comptroller of the Currency (OCC), the Federal Deposit Insurance Corporation (FDIC), and the Federal Reserve — failed to publish final rules by the set deadline. According to Tokenpost, citing Cointelegraph, these agencies collectively released 10 draft implementing rules over the past year (4 from Treasury, 2 from the OCC, 1 from the FDIC, and 1 jointly from federal banking regulators) and ran public comment periods, but the final rules did not land within the deadline. To be clear: the law itself remains in effect — what’s missing is the layer of detail that turns statutory language into enforceable compliance obligations. This isn’t a repeal; it’s an intermediate state of “law without rules.”
Editorial take: what this actually means for USDT card users
The bottom line first: an overdue rulemaking deadline does not mean something is wrong with USDT or USDC. The GENIUS Act primarily constrains stablecoin “issuers” — reserve composition, redemption obligations, audit disclosure, who’s eligible to issue. It doesn’t directly regulate how you swipe your card. So in the short term, most cardholders won’t feel any change at all.
That said, there is a transmission path, depending on the scenario:
- Users paying subscriptions with US-region USDC (for example, people using Coinbase Card or a linked USDC balance to pay for ChatGPT Plus or Cursor Pro). Circle, as an issuer squarely in the crosshairs of US regulatory attention, could see rising compliance costs indirectly passed through via redemption fees or reserve-yield allocation. But this would play out on a quarterly, not daily, timescale.
- Users on Asia-Pacific rails, primarily using USDT. This group sits further from the direct reach of GENIUS Act regulation. The Asia Elite variant covered in our MPCard review — our editorial pick — runs on Asia-Pacific BINs and USDT settlement, and the absence of US stablecoin rules has essentially no effect on its day-to-day transaction flow.
- Users planning to apply for a new US-dollar-region card. This is the only group that needs to think one layer further — see the recommendations at the end of this article.
Expected timeline:
- Within 7 days: No change. Don’t rebalance holdings or switch cards because of this news.
- Within 30 days: Watch whether major issuers like Circle and Paxos issue formal statements about the rulemaking delay. Note — this article does not assume they have already commented; go by each issuer’s official announcements.
- Within 90 days: If the rules remain absent, issuers may proactively raise compliance buffers (for example, tightening US-region KYC or adjusting reserve-disclosure frequency). This is the level at which user experience could actually be affected.
Historical comparison: how this differs from 2023 and from MiCAR
Comparing two reference events helps clarify what kind of event this is.
The March 2023 USDC depeg was a “real-time market risk” event — Circle had $3.3 billion in reserves stuck at Silicon Valley Bank, and the price deviated from $1 for several hours. Users genuinely needed to act at the time (watching redemptions, assessing exposure). This is entirely different: the GENIUS rulemaking delay is a “regulatory-process issue,” not a reserve-safety issue — the stablecoin’s price peg and redemption capability are unaffected. Equating the two is the most common misreading of this news.
The EU MiCAR legislative timeline — MiCAR was adopted in 2023, with stablecoin provisions taking effect in June 2024, and it too went through a period of implementation standards (RTS/ITS) being rolled out in batches, with some delays along the way. What’s similar: both are cases of “framework first, details lagging,” and markets went through a stretch of rule uncertainty in both. What’s different: MiCAR’s transitional arrangements were relatively clear, and issuers knew the rough timetable; this GENIUS Act situation involves “missing a set deadline” with no new fixed timeline anchor — the uncertainty is concentrated more sharply on the question of “when will the rules actually arrive.”
Regulatory boundaries: is this currently permitted, a gray zone, or prohibited
Three layers need to be distinguished:
- Clearly permitted: Holding and using compliant stablecoins, topping up a virtual card with USDT/USDC for spending — none of this is affected by the overdue GENIUS rules.
- Where the gray zone lies: Issuers’ specific compliance obligations (reserve audit frequency, mandatory standards for redemption timeframes) haven’t been finalized — the state is “the legal requirement exists, the enforcement standard is pending.” This gray zone sits on issuers, not on cardholders.
- Additional considerations for users in mainland China / Hong Kong: Beyond US rules, the regulatory environment where you’re located is the first priority. Readers planning to hold a card should first read our Hong Kong compliance overview and US compliance overview to understand the compliance boundaries on their own side before weighing in on US issuer rulemaking.
Milestones worth watching next
- New timelines from each agency: Watch whether Treasury and the OCC give a new publication window for the rules. So far, the four agencies have collectively issued 10 drafts — the next signal is which draft gets finalized first.
- Quarterly disclosures from major issuers: The next reserve and compliance statements from Circle and Paxos are the most direct window into whether costs are being passed through.
- Whether comment periods reopen: If regulators open another round of comment on already-issued drafts, it means the rules are delayed by at least another quarter.
- Reactions from Asia-Pacific and the EU: Whether issuers operating under the MiCAR regime try to seize a compliance-certainty advantage could affect the product supply of non-US-region cards.
Editorial recommendations
- Holders of Asia-Pacific-rail USDT cards like MPCard (including the Asia Elite variant): no action needed. This news doesn’t touch your transaction flow.
- Users paying subscriptions with US-region USDC: no need to switch cards, but add “watch Circle’s official announcements” to your monthly checklist — wait for the issuer itself to comment on the rulemaking delay before deciding whether to adjust anything.
- Users about to apply for a new US-dollar-region stablecoin card: consider holding off for 30 days, until major agencies give a new rulemaking timeline, to avoid locking into a long-term commitment during the window of maximum rule uncertainty. If you want to do your homework in the meantime, compare the 2026 Top 5 USDT Cards and Lowest-Fee USDT Cards, narrow your candidates to two or three, and commit once the signal is clearer.
In one line: this is a regulatory-process story, not a wallet-security story. Don’t read “rules overdue” as “something’s wrong with stablecoins” — the appropriate response to each is completely different.