Treasury’s state stablecoin test entered the Federal Register

The Federal Register published a U.S. Treasury proposal on April 3, 2026 that would decide when a state’s payment-stablecoin regime is sufficiently aligned with the federal framework created by the GENIUS Act.

Publication mattered because the statute preserved a state-supervision route for a defined class of issuers but left “substantially similar” to be implemented. Treasury’s proposal supplied the test. A state-qualified issuer with consolidated outstanding payment-stablecoin issuance of no more than $10 billion could generally choose state regulation only if the state framework qualified and the Stablecoin Certification Review Committee approved it.

The proposal was not a final rule, an issuer license or an endorsement of any stablecoin. Treasury announced the notice on April 1, 2026; its April 3 publication in the Federal Register opened the formal record and set June 2, 2026 as the deadline for comments.

A federal floor with room for state design

Treasury proposed dividing the GENIUS Act’s core prudential provisions into “uniform requirements” and “state-calibrated requirements.” A state regime would have to implement the uniform category consistently with the federal framework in all substantive respects, without materially narrowing the scope of the federal standards.

The uniform category included requirements where the statute did not give state regulators substantive discretion. Treasury identified subjects including one-to-one reserve backing, monthly disclosures and certifications, limits on rehypothecation, redemption obligations, Bank Secrecy Act and sanctions compliance, and the capacity to comply with lawful orders.

The state-calibrated category allowed more local design, but not a weaker outcome. Treasury proposed that state rules concerning areas such as capital, liquidity, reserve diversification, interest-rate risk, operational risk and internal controls produce results at least as stringent and protective as the federal framework. States could impose additional requirements if they did not conflict with federal law or undermine substantial similarity.

That combination was the policy center of the proposal: state regulation would remain available, but federal rules would establish a floor rather than one optional model among looser alternatives.

Why the OCC became the main comparison

Treasury proposed defining the “federal regulatory framework” to include the GENIUS Act plus a limited set of published federal interpretations and regulations. For most provisions, the baseline would be Office of the Comptroller of the Currency material published in the Federal Register. Treasury rules would control for anti-money-laundering, sanctions and lawful-order provisions, while Federal Reserve material would supply the anti-tying component.

Treasury’s reasoning was institutional as well as textual. Nonbank issuers choosing a federal route would generally fall under OCC supervision, and most state-qualified nonbank issuers exceeding the $10 billion threshold would transition toward OCC oversight unless they received a waiver. Aligning the state test mainly to the OCC framework was intended to make that transition less disruptive.

The proposal excluded informal federal guidance that was not published in the Federal Register from the comparison framework. That detail limited the prospect that states would have to track every FAQ or staff statement to retain certification.

What the April 3 record did not settle

The April 3 proposal asked the public to comment on fundamental design questions, including whether similarity should be judged section by section or holistically and whether another standard should replace “stringent and protective.” Those questions showed that the architecture remained open to revision.

No state regime was certified by publication of the notice, and no issuer was shown to satisfy the eventual framework. The $10 billion figure was a statutory eligibility threshold based on consolidated outstanding issuance, not a market-size estimate, reserve measurement or forecast.

The event-day significance was therefore procedural but substantial. Treasury had moved the federal-state boundary for U.S. payment-stablecoin supervision from an undefined statutory phrase into a proposed, reviewable rule. The final allocation of discretion would depend on comments, a final rule and later certification decisions; none of those outcomes could be assumed on April 3, 2026.