GENIUS Act MiCA Timeline: Key Dates for Stablecoin Teams

The GENIUS Act and MiCA timeline is the dated order in which each law reaches stablecoin issuers and the companies that handle their tokens. MiCA has applied in full since December 30, 2024. The GENIUS Act takes effect on January 18, 2027, and its restriction on providers starts on July 18, 2028.

As of November 1, 2026, MiCA's last provider transition has closed. The American clock has two dates left, plus a rulemaking still moving. This post is the calendar only. The substance of each regime is in our posts on the GENIUS Act and on MiCA rules.

How do the GENIUS Act and MiCA dates line up?

GENIUS Act, MiCA and Latin American dates in one calendar, as of November 1, 2026.

Where does the GENIUS Act rulemaking stand on November 1, 2026?

Section 13 gave regulators until July 18, 2026 to issue rules. They missed it, and the rules are arriving in pieces.

GENIUS Act rulemaking by agency, as of November 1, 2026.

The OCC rule is the only final one, and it leaves out the Bank Secrecy Act, anti-money-laundering and sanctions rules, which the agency says will come separately with the Treasury. The rules so far bind issuers and their supervisors, not the company that moves the token. For the obligation that already applies to providers, see our post on FinCEN MSB registration.

How the January 18, 2027 effective date is calculated

Section 20 sets the effective date at the earlier of 18 months after enactment or 120 days after the primary federal regulators issue final implementing regulations. Eighteen months after July 18, 2025 is January 18, 2027.

The second path wins only if a final rule came early. Counting back 120 days from January 18, 2027 gives September 20, 2026, and no final rule existed then. The OCC's came on October 21, 2026, and 120 days after that is February 18, 2027, so the 18-month date governs.

The foreign issuer test and the tokens a Latin American payer uses

A company in Brazil, Mexico or Colombia that pays in a dollar stablecoin meets the GENIUS Act through the token's issuer. USDC and USDT sit on different sides of the test.

USDC is issued by Circle, a US company. Section 2 of the Act defines a foreign payment stablecoin issuer as one organized or domiciled outside the United States that is not a permitted issuer, so USDC's issuer is not one. It falls under Section 3(b)(1): from July 18, 2028 a provider may offer it to a person in the United States only if it comes from a permitted payment stablecoin issuer. Circle is compliant with the GENIUS Act, and Lumx holds its own mint account with Circle besides buying USDC through BTG.

USDT is issued by Tether, which sits outside the United States, so the foreign issuer provisions are the ones that bear on it. Section 3(b)(2) makes it unlawful for a digital asset service provider to offer a foreign issuer's stablecoin in the United States unless the issuer has the technical capability to comply, and will comply, with any lawful order and any reciprocal arrangement under Section 18. It applies from January 18, 2027. Section 18(a) lifts the Section 3 prohibitions for a foreign issuer supervised in a jurisdiction Treasury finds comparable and registered with the Comptroller of the Currency, among other conditions. We found no published comparability finding.

The USDT detail is in our post on foreign stablecoins; for the basics, see what USDC is and what a stablecoin is.

On Lumx, the token is a field on each request, and the coverage page lists USDC on Ethereum, Polygon and Base and USDT on Ethereum, Polygon and Tron as sources for BRL, USD, EUR, MXN and GBP payouts.

Which MiCA transitions have ended?

All of them. Article 143(3) of MiCA let a provider that operated under national law before December 30, 2024 continue until July 1, 2026, or until it was granted or refused authorisation, whichever came first. Each member state could shorten the period or skip it. ESMA's list of grandfathering periods decided by Member States, read on November 1, 2026, gives the lengths, counted from December 30, 2024.

MiCA service provider transition length by member state, from ESMA's list of grandfathering periods under Article 143(3), read on November 1, 2026.

The list warns that some periods were communicated as expectations, so read the authority of the country you need.

A provider serving EU clients today holds a CASP authorisation, or is a bank or e-money institution acting under Article 60. Ask yours which.

Are USDC and USDT allowed in the EU under MiCA?

The test is Article 48: an e-money token may be offered to the public in the EU only by an issuer authorised as a credit institution or an e-money institution, with a notified white paper. Title IV has applied since June 30, 2024, and the provider rules since December 30, 2024.

Where USDC and USDT stand in ESMA's interim MiCA register of e-money token issuers, read on November 1, 2026.

This is a register fact, not a ruling. The register is interim, so recheck it and ask your provider in writing.

Lumx supports USDC and USDT. A euro payout leaves as a SEPA payment to an IBAN, through a banking partner.

What the dates mean for Brazil, Mexico and Colombia payouts

For Brazil the dated events are domestic: the two deadlines in the calendar (October 30, 2026 and May 31, 2027) come from the Central Bank resolutions covered in Brazil's guide. A Pix (Brazil's instant payment system) leg ends at the entity that holds the authorisation or the transition filing, so put it on the checklist.

Mexico and Colombia have no calendar date, since their local rules predate both foreign laws. Mexico regulates through the Fintech Law of March 9, 2018 and Banxico Circular 4/2019 (see the Mexico guide), and we found no enacted Colombian stablecoin statute. A Colombian payout is bound by a cap: Bre-B (Colombia's instant payment system) is limited to 1,000 UVB per payment, about COP 12.1 million in 2026. The GENIUS Act reaches a Latin American company where a payout to or from a US counterparty runs through a provider that must pass the issuer test, and MiCA where a euro leg touches a crypto-asset service. A USDC to EUR route can engage both, and a USDC to BRL route mainly the Brazilian entity.

What to put in the calendar and in what order

I would keep the two laws on separate lines of the compliance calendar, one for the issuer and one for the provider, and date each line with the agency document that moved it. I would re-read the US lines every month until January 18, 2027, because the rulemaking has already missed its own statutory deadline once. I would also give the calendar to the compliance lead, since the next move on any of these dates is a question about a counterparty.

On both sides of the Atlantic the order is the issuer, then the provider, then the local entity on each leg.

When a date calendar is the wrong tool

A calendar says when a rule applies, not whether you are in scope. A euro payment over SEPA that never touches a crypto-asset is under the payment services rules, not MiCA.

What the two calendars look like on a Lumx payout

Lumx is stablecoin payments infrastructure for businesses that move money between Latin America and the rest of the world: one API to collect, hold, convert, and pay out in BRL, MXN, COP, USD, EUR, and GBP or in USDC and USDT, over local rails such as PIX, SPEI, PSE, Bre-B, ACH, FEDWIRE, SEPA, and Faster Payments, with SWIFT and on-behalf-of payments and collections (POBO and COBO) in USD, EUR, and GBP, plus named virtual accounts, custodial wallets, and KYB/KYC built in.

The issuer rows belong to Circle and Tether, not to Lumx. What Lumx controls is the route: each off-ramp request names the source currency and a destination, and the coverage page in the docs lists which blockchain and token pairs convert to each currency. A SEPA payout is paid in euro to an IBAN, and Lumx picks the SEPA scheme on its own. The euro off-ramp guide covers that route.

In Brazil, Lumx filed for authorisation as an SPSAV (Sociedade Prestadora de Serviços de Ativos Virtuais, Brazil's virtual asset service provider regime) and operates under the Article 88 transition regime of Resolution 520/2025. In the United States, Lumx US OP LLC is a money services business registered with FinCEN, as the supported countries page states, read on November 1, 2026. KYB (know your business) and KYC (know your customer) run before any account is active.

Methodology and sources

Public Law 119-27 was read in the enrolled text on govinfo.gov on November 1, 2026, and the section numbers and periods above come from it. The OCC news release 2026-92 and Bulletins 2026-50 and 2026-51 of October 21, 2026 were read on occ.gov the same day, and the Federal Reserve Board press release of September 24, 2026 on federalreserve.gov. The Treasury notice of April 3, 2026 (91 FR 16844) was read on govinfo.gov. The Treasury notice of August 18, 2026 (2026-16796) is linked to the Federal Register. The FDIC notice of April 10, 2026 is cited by date from law firm summaries and was not read.

EUR-Lex returned an empty page to our checker for Regulation (EU) 2023/1114. The text of Article 143(3) comes from ESMA's statement of December 17, 2024, and the member state lengths from ESMA's list of grandfathering periods, both read on November 1, 2026. The USDC and USDT rows come from the EMTWP file of ESMA's interim MiCA register, downloaded on November 1, 2026. Product behavior was read on docs.lumx.io on November 1, 2026. Rulemaking dates move, so reread the agency documents.

Verified on November 1, 2026. Operational context, not legal, tax, or investment advice. Public Law 119-27 (GENIUS Act) checked against govinfo.gov on November 1, 2026. OCC news release 2026-92 of October 21, 2026 read on occ.gov on November 1, 2026. Federal Reserve Board proposals of September 24, 2026 checked against federalreserve.gov on November 1, 2026. ESMA Statement on MiCA Transitional Measures of December 17, 2024 checked against esma.europa.eu on November 1, 2026.

Cover photo: Emir Kutluay on Unsplash.