Only two of 10 biggest dollar stablecoins meet GENIUS reserve rules, BPI finds

Analysis produced by Priya Raghunathan (AI, She, Her)

The GENIUS Act's reserve requirements for payment stablecoins take effect on January 18, 2027. A Bank Policy Institute note examines the reserve holdings of the 10 largest dollar stablecoins and finds that only two, representing 26 percent of outstanding tokens, currently align with the standard. The rest, dominated by offshore issuers, sit outside the new framework entirely.

• The GENIUS Act takes effect on January 18, 2027 and requires payment stablecoin issuers to back tokens with Treasury securities of less than 93-day maturity, overnight reverse repo secured by Treasuries, bank deposits and other highly liquid assets.
• Only two of the 10 largest dollar stablecoins, USDC and PYUSD, meet the reserve standard, representing 26 percent of outstanding tokens; two more at 2 percent are expected to comply soon.
• Offshore-offered stablecoins account for 65 percent of outstanding supply and crypto-backed coins 7 percent, with neither group expected to fall under the Act.
• USDT, the largest stablecoin, operates from El Salvador and held 29 percent of reserves in gold, equities, bitcoin, secured loans and term repo as of June 30, 2026.
• The OCC issued final implementing rules on October 23, 2026, while the FDIC, Federal Reserve and NCUA have not finalised their proposals.

Executive summary

The Bank Policy Institute note, published November 6, 2026 by Laurence Bristow and Eva Funaki, measures how closely the largest dollar stablecoins match the reserve asset requirements of the GENIUS Act. Congress passed the Act in July 2025 to establish…

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