Only Two Top Stablecoins Meet GENIUS Act Rules
A Bank Policy Institute study finds most of the largest dollar stablecoins do not yet align with new federal reserve asset requirements.
Updated on Nov. 6, 2026 in Saving
The Bank Policy Institute published a study on Friday, November 6, finding that only two of the 10 largest dollar stablecoins align with reserve asset requirements under the GENIUS Act. Those two represent 26% of tokens outstanding, while the top 10 together account for 97% of all stablecoins as of June 2026.
Why it matters
The GENIUS Act requires reserve assets to prevent stablecoins from losing their peg to the dollar, so most of the market's largest tokens currently fall outside that protection. Four of the 10 largest stablecoins are expected to become subject to the requirements when they take effect next year.
The Bank Policy Institute study examined reserves of the 10 largest dollar stablecoins, which hold 97% of the market as of June 2026, and found 2 of the 10 meet GENIUS Act requirements, representing 26% of tokens outstanding. Circle's USDC and Paxos PYUSD are the compliant tokens, while World Liberty's USD1 and Ripple USD are backed by money market funds holding agency debt and longer-dated Treasuries.
The players
Bank Policy Institute
A Washington-based think tank representing large U.S. banks that publishes research on financial regulation and banking policy.
Circle
The issuer of USDC, one of the largest dollar stablecoins, which meets the GENIUS Act reserve asset requirements.
Paxos
A regulated blockchain infrastructure company that issues PYUSD, a dollar stablecoin that meets the GENIUS Act reserve asset requirements.
The details
The GENIUS Act requires stablecoins to be backed by U.S. Treasury securities with maturities under 93 days, overnight reverse repurchase agreements secured by Treasuries, bank deposits and other highly liquid assets. Stablecoins outside the framework will continue to carry a heightened risk of de-pegging.
Timeline
- June 2026: Snapshot of the top 10 stablecoins' 97% market share.
- September 2026: PYMNTS Intelligence credit union report published, finding a 25-percentage-point gap between readiness and active engagement.
- November 6, 2026: Bank Policy Institute study published.
- 2027: GENIUS Act requirements take effect for onshore stablecoins.
Market Dynamics
The GENIUS Act's payment stablecoin reserve requirements set the standard the largest dollar tokens must meet, and the study shows most of the top 10 do not yet comply. Stablecoins outside that framework face a continuing risk of losing their dollar peg as the market grows.
Holders of stablecoins outside the GENIUS Act framework face a heightened risk of de-pegging from the dollar. Savers and investors using these tokens should check whether their stablecoin's reserves meet the new federal requirements before relying on it as a store of value.
The takeaway
Checking whether a stablecoin's reserves meet GENIUS Act requirements is a practical step before holding it. Compliant tokens currently represent a small share of the largest coins' market value.
What happens next
The GENIUS Act's reserve requirements take effect for onshore stablecoins next year, when four of the 10 largest stablecoins are expected to be subject to them.
Further reading
Learn more about saving as stablecoin reserve rules reshape where digital dollars are held.
Source note: This article includes information reported by PYMNTS.
