US federal regulators failed to finalize implementation details for stablecoins within the one-year deadline set by the GENIUS Act, releasing 10 proposed rules instead. This means the Act’s overall framework has taken effect, but the enforcement-level rules — determining who can issue stablecoins, how reserves must be custodied, and how audits and disclosures must work — remain stuck at the public-comment stage. According to Cointelegraph, the agencies responsible for implementation scraped by the deadline by substituting “proposals” for “final rules,” pushing substantive decisions into the next legislative cycle. For stablecoin holders, this isn’t a regulatory tightening — it’s a regulatory delay.
Editorial take: what this means for USDT card users
The bottom line first: this news will not change the usability of the card in your wallet anytime soon. The GENIUS Act primarily constrains stablecoin issuers (Tether, Circle, and potential bank-affiliated issuers) — not the downstream card issuers that let you load USDT and swipe a Visa/Mastercard. Most retail-facing U cards — whether RedotPay, Bybit Card, or OKX Card — were never open to US residents in the first place, or already restrict US access. A delayed rulebook simply means the window they’ve been operating under — “US regulation hasn’t landed yet” — stays open a bit longer.
Breaking down the timeline:
- Within 7 days: No practical impact whatsoever. No issuer will adjust fees or limits over a “proposal.”
- Within 30 days: Tether and Circle will likely submit comment letters on the 10 proposals — worth watching whether Tether signals any position on a “US-registered issuing entity” threshold.
- Within 90 days: The real variable is when the final rules actually land. Until then, legislation alone won’t close the gray-area path of using non-US card BINs to pay for US-region subscriptions (ChatGPT Plus, Cursor Pro, etc.).
If you’re using a U card to pay for overseas SaaS, check our ChatGPT Plus subscription scenario and Claude Code scenario — the core risk in both cases has always been account/IP/card BIN consistency, not stablecoin legislation.
Historical comparison: how this differs from MiCAR and the 2023 USDC de-peg
Two comparisons are worth making.
First, the March 2023 USDC de-peg: that was a liquidity/reserve event that directly hit the token’s value — users felt it the same day. This time it’s pure regulatory-process delay — the token’s value hasn’t moved at all. It’s a “slow variable.”
Second, the legislative pace of the EU’s MiCAR. MiCAR went from passage in 2023 to phased implementation by the end of 2024, going through a similarly long drafting period for technical standards (RTS/ITS), during which the market largely stayed on the sidelines. The GENIUS Act is now walking the same path — legal framework first, execution details lagging behind. The similarity: both give issuers a buffer period. The difference: the EU’s transition period had a clear calendar, while this time the US hasn’t even locked in a “final rule date,” making the uncertainty greater.
The takeaway for U card users: don’t mistake “proposal published” for “new rule in effect.” Historically, the gap between proposal and enforcement often runs 6–18 months.
Compliance implications: the gray area hasn’t turned red, and it hasn’t turned green either
The current boundaries remain clear:
- Clearly permitted: non-US residents holding and spending on a compliant issuer’s U card was never within the GENIUS Act’s direct scope.
- Clearly prohibited: no change — using falsified identity to bypass KYC remains a violation, regardless of legislative timing.
- Still a gray area: US residents using offshore stablecoin cards. The rule delay means this gray area persists — neither legalized nor explicitly banned under new rules.
US-based readers can refer to our US compliance guide. One important note: the GENIUS Act targets issuer licensing and reserves — it does not directly exempt downstream users from tax filing obligations. Reporting capital gains on USDT transactions remains your own responsibility.
Key milestones worth watching next
- Public comment deadline for the 10 proposals — typically 60–90 days after publication, when the real positions of issuers and banking lobbies will surface.
- Public responses from Tether / Circle — particularly whether Tether advances any “US-compliant entity” path.
- The next joint agency announcement — whether it names a firm date for final rules is the key anchor for judging overall pace.
- Wording changes in US-facing issuer policies — if US-linked issuers like Coinbase Card quietly revise user agreements, that’s often a leading indicator of regulatory direction.
Editorial recommendations
- Holders of non-US U cards: no action needed. The rule delay has zero impact on your day-to-day spending.
- Users planning to apply for a new U card for US-region subscriptions: proceed as normal, but focus your card selection on BIN match and fee rates rather than “whether regulation has landed” — see our best cards for ChatGPT Plus.
- US residents: don’t take any drastic action based on this news. The gray area has neither widened nor narrowed. Waiting is more cost-effective than jumping the gun — decide once a final rule date is confirmed.
- Everyone else: file this news under “to watch,” not “action required.” What will actually require you to adjust your card strategy is the final rule’s effective date, not today’s proposal.
If you’re still deciding on your first U card, start with What is a U Card for the basics, then check our 2026 Top 5 for a comparison of the mainstream options.