GDF Response to US Treasury Consultation on GENIUS Act Regulations on Payment Stablecoin Issuance, Offer and Sale

Global Digital Finance (GDF) submitted a response to the US Department of the Treasury’s proposed regulations implementing the GENIUS Act’s requirements for the issuance, offer and sale of payment stablecoins.
GDF supports the establishment of a clear and enforceable regulatory framework that enables lawful market access, strengthens financial crime controls and protects stablecoin holders. The response emphasises the importance of proportionate, activity-based regulation that provides legal certainty while preserving the efficiency and interoperability of payment stablecoins.


The submission highlights several key priorities, including clarifying the territorial scope of US stablecoin requirements, distinguishing issuance from routine token transfers, and ensuring that regulatory responsibilities are allocated according to the functions performed by issuers, distributors, custodians and technology providers.
GDF also recommends establishing a practical framework for recognising qualifying foreign stablecoin issuers, supported by transparent regulatory comparability assessments and coordinated registration requirements. The response calls for proportionate due diligence obligations, reasonable reliance on issuer representations and clear safeguards against unlawful issuance without imposing unnecessary compliance burdens on intermediaries.
The submission further stresses the importance of preserving self-custody and direct individual transfers, providing appropriate transitional arrangements and ensuring that cross-border regulatory requirements do not unnecessarily fragment global stablecoin markets.


Overall, GDF calls for a coherent and proportionate implementation of the GENIUS Act that maintains robust regulatory safeguards while supporting innovation, international interoperability and the responsible development of payment stablecoin markets.

Date:
19 October 2026

Global Digital Finance, together with its community of industry expert members, is driving the acceleration and adoption of digital finance to support the next era of digital commerce.

GDF
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