On September 30, the U.S. Department of the Treasury issued and took effect a temporary final rule allowing states to submit a “conditional” certification to hold their place while their state stablecoin regulatory rules are still being finalized.
The rule details are worth unpacking. The statutory deadline for the first certification is January 18, 2028; as long as any form of certification is submitted before then—whether it includes unfinished legislative conditions or is deemed procedurally incomplete—the deadline is considered met. But the key is the next sentence: this early submission does not trigger a substantive review, nor does it start the committee’s 30-day “approval or denial” clock. Only a complete submission (including an unconditional statement and explanations that meet the “substantially similar” standard) causes the 30 days to begin.
The rule applies to state-eligible payment stablecoin issuers with aggregate issued amounts not exceeding $10 billion. The committee is chaired by the Secretary of the Treasury, and members include the Chairman of the Federal Reserve and the Chairman of the FDIC.
My take: this isn’t easing—it’s staking a claim. Treasury has not finalized the hardest part—those independent proposals for the “substantially similar” standard. Instead, it has put procedural requirements in place first, effectively telling states: you go ahead and get in line; we’ll define the rules slowly. The real decision-making power hasn’t been given away at all.
As a result, the practical impact on the sector is delayed and structural. In the short term, there will be no license grants and no new supply. In the longer term, the true beneficiaries are the issuers that already have state-level trust licenses and established state regulatory relationships, because they’ve gained certainty earlier.
$USDC
#U.S. Treasury allows states to submit stablecoin certifications early
I’d like to hear your judgment: by moving the certification deadline earlier and postponing substantive review, is this regulatory-friendly—or is it just pushing uncertainty out by two more years?
The rule details are worth unpacking. The statutory deadline for the first certification is January 18, 2028; as long as any form of certification is submitted before then—whether it includes unfinished legislative conditions or is deemed procedurally incomplete—the deadline is considered met. But the key is the next sentence: this early submission does not trigger a substantive review, nor does it start the committee’s 30-day “approval or denial” clock. Only a complete submission (including an unconditional statement and explanations that meet the “substantially similar” standard) causes the 30 days to begin.
The rule applies to state-eligible payment stablecoin issuers with aggregate issued amounts not exceeding $10 billion. The committee is chaired by the Secretary of the Treasury, and members include the Chairman of the Federal Reserve and the Chairman of the FDIC.
My take: this isn’t easing—it’s staking a claim. Treasury has not finalized the hardest part—those independent proposals for the “substantially similar” standard. Instead, it has put procedural requirements in place first, effectively telling states: you go ahead and get in line; we’ll define the rules slowly. The real decision-making power hasn’t been given away at all.
As a result, the practical impact on the sector is delayed and structural. In the short term, there will be no license grants and no new supply. In the longer term, the true beneficiaries are the issuers that already have state-level trust licenses and established state regulatory relationships, because they’ve gained certainty earlier.
$USDC
#U.S. Treasury allows states to submit stablecoin certifications early
I’d like to hear your judgment: by moving the certification deadline earlier and postponing substantive review, is this regulatory-friendly—or is it just pushing uncertainty out by two more years?