U.S. Stablecoin and CBDC Legislation: What Issuers Need to Know

On July 17, 2025, the U.S. House of Representatives passed the GENIUS Act, establishing a federal regulatory framework for stablecoin issuers, and the Anti-CBDC Act, prohibiting the Federal Reserve from issuing a central bank digital currency. Together, these measures introduce meaningful regulatory structure for institutions issuing and operating programmable assets in the United States.

What the Legislation Establishes

Two bills passed by the House on July 17, 2025 materially alter the regulatory environment for institutions engaged in digital asset issuance.

The GENIUS Act — Guiding and Establishing National Innovation for U.S. Stablecoins — sets binding requirements for stablecoin issuers operating in the United States. The Anti-CBDC Act forecloses the possibility of a Federal Reserve-issued central bank digital currency, preserving the existing monetary architecture.

For issuers of programmable assets, both measures reduce a key source of institutional hesitation: regulatory ambiguity.

The GENIUS Act: Reserve and Oversight Requirements for Stablecoin Issuers

The GENIUS Act introduces a structured compliance regime for stablecoin issuers. Full details are available via KPMG's regulatory alert.

Core provisions:

• Reserve requirements: Issuers must maintain reserves equal to the value of stablecoins in circulation, fully backing each instrument and limiting insolvency risk.
• Disclosure obligations: Regular audits and public reporting are mandated, establishing a transparent record for counterparties and regulators alike.
• Supervisory framework: The Act delineates federal and state oversight responsibilities, providing issuers with a defined compliance pathway rather than a patchwork of conflicting rules.

For institutions structuring stablecoin instruments — whether for payments, settlement, or asset-backed programs — these provisions establish the floor. Compliance is not optional; it is the condition of operation.

The Anti-CBDC Act: Preserving the Private Issuance Model

The Anti-CBDC Act prohibits the Federal Reserve from issuing a central bank digital currency, directly addressing institutional concerns about government intervention in the digital payment system. For background, see America's Credit Unions.

The practical effect is to preserve private-sector issuance as the primary model for digital monetary instruments in the United States. Institutions that have deferred decisions on programmable asset programs pending CBDC policy clarity now have a more defined market structure to plan against.

Regulatory Clarity and Its Effect on Institutional Participation

The combined passage of these bills shifts the conditions under which institutions engage with programmable asset issuance.

• Defined compliance obligations reduce the legal uncertainty that has kept many asset managers and banks at the margins of this market. With reserve and disclosure requirements codified, institutions can assess entry on known terms.
• Regulatory structure invites institutional participation. Banks, fund administrators, and issuers that require regulatory certainty before committing capital or infrastructure can now proceed on firmer ground.
• Consumer and counterparty protections embedded in the GENIUS Act strengthen the credibility of stablecoin instruments as operational assets — not speculative positions.

Compliance Considerations for Issuers

The legislation introduces real obligations. Institutions planning to issue or administer stablecoin instruments should account for:

• Compliance infrastructure investment. Reserve management, audit processes, and disclosure mechanisms require dedicated operational build-out.
• Competitive dynamics. A clearer regulatory framework will attract new entrants. Issuers that establish compliant programs early are better positioned to define market practice.
• Regulatory evolution. This legislation is a baseline. Secondary rulemaking and state-level implementation will continue to develop, and issuers must maintain the capacity to adapt.

Positioning for Issuers

Institutions best placed to operate in this environment are those that treat compliance as architecture — building reserve management, transfer rules, and disclosure obligations directly into their issuance programs from the outset.

The path forward is through regulated issuance: instruments that carry their own rules, backed by auditable reserves, and supervised within a defined federal framework. The GENIUS Act and Anti-CBDC Act do not resolve every open question, but they establish the structural conditions under which serious issuers can operate.

For institutions ready to issue, program, and operate real assets under this framework, the regulatory ground is firmer today than it was before July 17, 2025.