On August 17, the US Department of the Treasury released proposed guidance for the GENIUS Act, legislation establishing a regulatory framework for payment stablecoins. The proposal focuses on addressing two fundamental questions: when a stablecoin is considered issued in the US, and when an offering is considered to be made to US users.

This is not merely a matter of terminology—these two definitions determine which businesses must obtain a license under the law. According to the established timeline, starting January 18, 2027, organizations seeking to issue payment stablecoins in the US will generally be required to hold a federal or state license. By July 18, 2028, digital asset platforms will no longer be permitted to offer stablecoins from unlicensed foreign entities to US users. The public and businesses have 60 days to submit comments.

What the market is watching most closely is how the proposal treats non-US stablecoins, specifically Tether’s USDT—the largest stablecoin today. Notably, just days ago, Tether released its first financial audit report in its 12 years of operation, conducted by KPMG, in a move to bolster transparency.

The context is increasingly urgent: the US administration has missed a one-year deadline to finalize the entire GENIUS Act framework, while many key regulations remain in draft form.

The takeaway: the outcome of this consultation period will determine whether USDT—and other non-US stablecoins—will retain access to the US market or be forced to comply with domestic licensing requirements. This marks a turning point for the entire stablecoin payments industry, not just Tether.