The Blockchain Association submitted its feedback to the US Department of the Treasury on October 19, 2026, regarding the proposed rules for the GENIUS Act. The organization supports the push for regulatory clarity but is requesting revisions to specific definitions within the draft.
The association argues that the term digital asset service provider should exclude self-custody software and certain trading firms. It also expressed concerns regarding the standards for criminal liability and the application of location-based tests to decentralized systems that operate across borders.
Additional requests include removing the functional equivalent test and revising initial compliance cost estimates. The group also advocates for aligning the effective dates of these rules with other regulations mandated by the GENIUS Act, which was signed into law on July 18, 2025.
The GENIUS Act establishes a federal framework for payment stablecoin issuers and requires federal or state oversight. The law is scheduled to take effect by January 18, 2027, or 120 days after the final rules are enacted. The Treasury proposal received over 100 public submissions.
