The U.S. Department of the Treasury published on August 17, 2026, a Notice of Proposed Rulemaking (NPRM) to implement Section 3 of the GENIUS Act (Guiding and Establishing National Innovation for U.S. Stablecoins). This proposal, which opens a 60-day public comment period, establishes the framework for determining which issuers require a GENIUS license and under what conditions stablecoins may be offered or sold in the U.S. market.
The relevance of this proposal to the crypto ecosystem does not lie in its surprise factor—the law was enacted in July 2025—but in the operational definitions it introduces for key concepts: what constitutes “issuing a payment stablecoin in the United States” and what constitutes an “offer or sale” to persons “in the United States.” These definitions will determine which assets and which protocols are exposed to restrictions and which, conversely, obtain a competitive advantage.
The Operational Timelines of the Regulatory Transition
The Treasury proposal establishes two compliance deadlines on a staggered basis:
January 18, 2027: expected effective date of the GENIUS Act. From this date, no person may “issue a payment stablecoin in the United States” without the corresponding federal or state license. Additionally, digital asset service providers may not offer, sell, or make available foreign-issued stablecoins unless the foreign issuer demonstrates technological compliance capability and agrees to submit to court orders and reciprocal agreements between the U.S. and its jurisdiction of origin.
July 18, 2028: from this date, digital asset service providers may not offer or sell any payment stablecoin to persons in the United States, unless said stablecoin has been issued by a licensed issuer.
The distinction between both dates is operationally relevant: the first restricts issuance (primary offering), while the second restricts commercialization (secondary market) of any unlicensed stablecoin.
The Differential Exposure of Protocols
The impact of this regulation on blockchain protocols is not uniform. It depends on a structural factor: the composition of their stablecoin supply and, specifically, the percentage of that supply that corresponds to licensed issuers—essentially, Circle (USDC) and, to a lesser extent, Ripple (RLUSD).
The Treasury, in its proposal, extends compliance responsibility beyond the issuers themselves. Intermediaries—including exchanges and other service providers—could be deemed participants in unlawful issuance if they “convert, redeem, or repurchase” the stablecoin, coordinate with the issuer on key steps such as customer acquisition, token minting, or making a newly issued stablecoin available for secondary market trading.
Hyperliquid (HYPE)
Hyperliquid presents the highest degree of favorable exposure to the regulation. The USDC supply on Hyperliquid HyperEVM reaches $5.93 billion, ranking as the third-largest USDC reserve globally, behind only Ethereum and Solana.
Circle has transferred $4.4 billion in USDC through HyperEVM in a single transaction. The concentration of its stablecoin supply in USDC—an asset issued by Circle, which has already obtained final approval as a licensed issuer—places Hyperliquid in a position of minimal regulatory risk under the new framework.
Additionally, the AQAv2 mechanism that Hyperliquid will launch on August 26, 2026, allocates 90% of the yield generated by non-exclusive stablecoins (such as USDC) to HYPE buybacks, which directly links regulatory compliance with value flow to the native token.
Arbitrum (ARB)
Arbitrum, with a stablecoin supply of approximately $6.9 billion, maintains a proportion of USDC. Approximately 63.5% of its stablecoin supply corresponds to Circle. This structure reduces its exposure to delisting or restriction risks that would affect protocols with high USDT (Tether) concentration.
However, the Layer 2 on Ethereum condition introduces an additional layer of regulatory complexity: the determination of the jurisdiction of issuance and commercialization may extend to the smart contract on the base layer, which could subject Arbitrum to more detailed scrutiny regarding the origin of stablecoins circulating on its network.
Polygon (POL)
Polygon has experienced significant growth in its stablecoin supply, which increased from $1.6 billion at the beginning of 2025 to approximately $3.76 billion by June 2026. USDC participation in this supply is approximately 55%. Polygon processed 493 million stablecoin transactions in February 2026, exceeding the combined total of Solana, Base, Arbitrum, and Ethereum. This transaction volume, combined with a majority of USDC in its supply, positions Polygon as a protocol that could benefit from the migration of users and liquidity from networks with high exposure to unlicensed USDT.
Solana (SOL)
Solana presents a stablecoin supply of $14.5 billion as of May 2026, of which $7.72 billion corresponds to USDC. The proportion of USDC in its total supply is approximately 43.5%. Circle has issued $72.01 billion in USDC on Solana during 2026, evidencing an active issuance relationship with the licensed issuer. However, the presence of a significant portion of USDT—issued by Tether, which does not hold a GENIUS license—exposes Solana to liquidity fragmentation risks starting in 2028, when platforms cannot offer USDT to U.S. users.
Ethereum (ETH)
Ethereum is the protocol with the largest absolute stablecoin supply: approximately $146.57 billion. The distribution, however, is more balanced: Tether’s USDT represents approximately $79.89 billion and Circle’s USDC approximately $47.88 billion (the remainder corresponds to other issuers such as Sky’s USDS). The proportion of USDC is approximately 33% of the total supply. Ethereum faces the challenge of managing the transition from a stablecoin supply with high Tether exposure toward an ecosystem dominated by licensed issuers.
The magnitude of its total supply, however, grants it a network effect that could cushion the impact: licensed issuers have an economic incentive to expand their presence on the network with the highest liquidity.
XRP Ledger (XRP) and RLUSD
The XRP case is qualitatively different. Ripple, through its stablecoin RLUSD, has obtained a conditional OCC license as an issuer. The circulating supply of RLUSD reaches approximately $1.71 billion, with a presence on XRP Ledger of approximately 48% of total supply. Ripple has minted an additional $10 million of RLUSD in August 2026. Ripple’s status as a licensed issuer makes RLUSD a natively compliant asset under the GENIUS Act, which could incentivize its adoption on platforms seeking to minimize regulatory risk.
The Substitution Effect and Tether’s Contraction
The European precedent with MiCA regulation offers a plausible scenario for the U.S. In Europe, MiCA implementation triggered the delisting of USDT on multiple exchanges and a forced migration of users toward USDC and other compliant stablecoins. The GENIUS Act, with its 2027 and 2028 deadlines, could replicate this pattern in the U.S. market.
The primary affected party would be Tron (TRX) , which hosts $92.04 billion in stablecoins, of which 97.9% corresponds to USDT. The absence of a licensed issuer in its stablecoin supply exposes Tron to an almost total restriction of its U.S. market starting in 2028.
Limitations and Risks of the Proposal
The Treasury proposal is not final regulation. The 60-day comment period and subsequent review process could introduce substantial modifications. Additionally, the GENIUS implementation process coexists with the Congressional effort to pass the Digital Asset Market Clarity Act, which could rewrite portions of GENIUS.
The performance data for the mentioned assets—with the exception of HYPE, which registers a positive return of 26.3% over the last twelve months—show declines ranging between 58% and 86% over the same period. Regulation, in this context, operates as a structural realignment factor, not as a catalyst for generalized appreciation.
