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

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

The Bank Policy Institute examined whether the largest dollar stablecoins hold the highly liquid reserves the GENIUS Act will require. The answer, as of mid-2026, is mostly no. With the Act effective in January 2027 and most supply sitting offshore and outside the framework entirely, the analysis maps how far the market is from the standard meant to prevent de-pegging.

• Only two of the 10 largest dollar stablecoins, representing 26 percent of tokens outstanding, would meet GENIUS Act reserve requirements as of June 30, 2026, per BPI.
• Circle's USDC and Paxos PYUSD met the requirement to back coins with assets including Treasury securities of under 93-day maturity, overnight reverse repo secured by Treasuries and bank deposits.
• Four of the 10 largest coins are offered onshore and are expected to be subject to the Act when it becomes effective in January 2027.
• The two onshore issuers that would not comply are backed by money market funds holding agency debt and longer-dated Treasury securities as of June 2026.
• Most dollar stablecoins outstanding are offered offshore or backed by crypto assets and sit outside the framework, holding riskier reserve portfolios.

Executive summary

The Bank Policy Institute published an analysis examining which stablecoins would satisfy the GENIUS Act's requirement to back coins with highly liquid assets, and found that only two of the 10 largest dollar stablecoins would meet the reserve requirements as…

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