The U.S. stablecoin market is increasingly likely to be reshaped around large issuers as a deadline nears to finalise detailed rules under the GENIUS Act. If reserve requirements, monthly audits, licensing and anti-money laundering systems take full effect, the competitiveness of issuing stablecoins is expected to hinge on how much regulatory cost an issuer can absorb.
According to blockchain outlet CryptoSlate on July 3, the GENIUS Act requires detailed rules to be finalised within 1 year of enactment, and July 18 has been identified as a key turning point. After that point, issuers must have comprehensive compliance systems covering reserve composition, external audits, redemption standards, licensing and transaction monitoring.
The industry views this as a signal that stablecoins are being brought into the regulated system, while also assessing that it could create a high barrier to entry for small and mid-sized issuers. Mike McCluskey (마이크 맥클러스키), chief executive officer of tx, and Zahir Ebtikar (자히르 엡티카르), chief strategy officer of Plasma, both viewed the regulation not simply as a licensing issue but as an issue of recurring cost structure.
Ebtikar pointed to segregated reserve accounts, monthly external audits, dedicated compliance staff and anti-money laundering systems as ongoing costs. He said the basic costs do not differ much whether circulation is $200 million or $2 billion, meaning the burden grows heavier for smaller issuers.
The stablecoin market is already dominated by a small number of large operators. Based on DefiLlama, total stablecoin market capitalisation is about $311.5 billion, with USDT and USDC accounting for about 80%. USDT is $184.4 billion in size and USDC is $73.3 billion.
The GENIUS Act requires stablecoin reserves to be held in high-liquidity assets such as demand deposits, short-term U.S. Treasuries, overnight repurchase agreements and government money market funds. It also requires monthly verification by a registered accounting firm, and mandates that the chief executive officer and chief financial officer directly sign off on reserve figures. Issuers are classified as financial institutions under the Bank Secrecy Act, and must also shoulder obligations for customer identification, sanctions screening and transaction monitoring.
The revenue structure also changes. The law bans paying interest or returns to users simply for holding tokens. As a result, issuers' business viability is increasingly likely to depend on reserve-management income and the ability to control distribution networks.
The outlet cited an example of differences in cost structure. If the yield on 3-month U.S. Treasuries is 3.74 percent, a $200 million stablecoin can generate about $7.5 million a year in reserve income. But if audits, legal, licensing and anti-money laundering systems cost $15 million a year, it is difficult to make a profit. By contrast, for a $10 billion issuer, the same costs are only about 4 percent of roughly $374 million in reserve income.
For issuers below $10 billion, a path is also open to use a state regulatory framework. It requires certification that the state regime is substantively similar to federal standards. Ebtikar said this appears to be a protection for small issuers, but could in practice act as a growth ceiling because issuers that exceed $10 billion must shift to a federal supervisory framework within 360 days.
There are also positive assessments in terms of inflows from institutional investors. McCluskey said institutions have been waiting not for a technological breakthrough, but for a strong compliance framework that can pass internal reviews. He said assets that meet regulatory standards, such as bank-issued stablecoins or Circle's USDC, could become products that corporate treasury departments and institutional investors can access more easily.
Competition over distribution networks is also expected to intensify. The OpenUSD group, which includes more than 140 companies such as Visa, Mastercard and Coinbase, is pursuing a structure that shares reserve income with participating firms. Operators with large networks are likely to absorb regulatory costs and secure an advantage in distribution.
From July 18, 2028, it will become difficult to generally offer U.S. users a payment stablecoin unless it is issued by an approved issuer or by a qualified foreign issuer. In that case, tokens outside the regulatory scope could lose access to exchanges and liquidity.
Ultimately, the GENIUS Act is boosting stablecoins' safety and trust within the regulated system while also turning issuance into an industry requiring large-scale capital and compliance infrastructure. The market is viewing July 18 as the starting point that will divide not only stablecoins' legality but also which issuers can withstand the cost structure.