Treasury Allows Conditional State Stablecoin Filings

The Treasury issued an interim final rule on Sept. 30 that lets states submit conditional or incomplete certifications of proposed stablecoin regimes to preserve statutory filing timelines while laws or regulations remain unfinished. The rule establishes forms and procedures for the Stablecoin Certification Review Committee and clarifies when substantive review begins.

Under the rule, a conditional or incomplete certification preserves the initial filing date but does not trigger the Committee’s substantive review or the 30-day approval-or-denial period. To start substantive review, a state must submit an unconditional attestation signed by an authorized representative, a detailed explanation of how its regime meets Treasury’s similarity principles, supporting legal materials and any additional information the Committee requests.

Conditional filings can be amended at any time. The rule applies to state-qualified payment stablecoin issuers with no more than $10 billion in consolidated outstanding payment stablecoin issuance that choose state regulation. Approval of a state regime by the Committee does not itself license individual stablecoin issuers.

Although the procedural rule took effect on Sept. 30, Treasury will not accept certifications until the rule’s information-collection requirements complete the Paperwork Reduction Act process. The department will publish a notice to announce when it will begin accepting filings. The rule invites public comment through Nov. 30.

The interim rule uses Jan. 18, 2028 as the deadline for initial certifications, based on an expected Jan. 18, 2027 effective date for the GENIUS Act; the statute sets initial filings due one year after the Act takes effect. Section 20 of the Act provides an alternate effective date equal to the earlier of 18 months after enactment or 120 days after primary federal payment stablecoin regulators issue final implementing regulations.

The rule sets administrative mechanics for the Review Committee but does not finalize the Treasury’s separate proposal on how to determine whether a state regime is substantially similar to federal standards. That substantial-similarity proposal remains under development.