As regulatory momentum builds in Washington, the STABLE Act has returned with a 2025 amendment that clarifies the U.S. government’s stance on stablecoins. The updated proposal reshapes how both banks and nonbanks may issue dollar-backed digital assets—while placing oversight squarely in the hands of the Federal Reserve. For fintechs and digital asset projects eyeing U.S. expansion, this marks a pivotal moment in stablecoin regulation.
Originally introduced as a framework for centralizing oversight of U.S. dollar-backed stablecoins, the newly amended STABLE Act (H.R. 2392 / H.R. 4766) now reflects clearer distinctions between issuer types, reserve requirements, and supervisory expectations.
This updated bill attempts to bring a more nuanced and flexible structure to the U.S. stablecoin ecosystem while preserving core principles around consumer protection and financial stability.
You can review both versions of the STABLE Act directly via these official links (opens in new window):
A Tiered Framework for Stablecoin Issuers
The most notable update in the 2025 version of the STABLE Act is the introduction of a two-tier regulatory model:
- Tier 1 Issuers: These are insured depository institutions (IDIs)—federally regulated banks and credit unions. Tier 1 issuers may offer stablecoins under traditional banking frameworks, provided they meet asset and disclosure requirements.
- Tier 2 Issuers: These are nonbank financial companies that must register with the Federal Reserve and are subject to supervisory and examination authority. Tier 2 issuers are required to comply with stablecoin-specific rules around redemption, disclosures, and reserve management, even if they’re not IDIs.
This bifurcation reflects a compromise: Tier 1 institutions operate under legacy banking rules, while Tier 2 issuers—often fintechs or crypto-native firms—can participate under a clearly defined supervisory model.
Operational Insight: If your entity currently operates under state money transmission laws, you may need to restructure or re-register under the Tier 2 regime to continue issuing stablecoins nationally. Assess licensing strategy early to avoid business interruption.
Redemption, Reserve, and Reporting Requirements
The bill codifies several important protections for stablecoin holders:
- Redemption at Par: Issuers must redeem stablecoins at par value upon request and within a reasonable timeframe. This obligation is enforceable by federal regulators.
- Permitted Reserves: Reserves must consist of U.S. dollars, insured deposits, or Treasury securities with maturities of 90 days or less. No commercial paper, unsecured debt, or volatile assets are allowed.
- Monthly Reporting: Tier 2 issuers must publish monthly disclosures regarding their reserve holdings and redemption activity. These reports will be subject to review by the Federal Reserve.
Operational Insight: Treasury management, accounting, and audit workflows will need to align with monthly reporting cycles. Projects that previously relied on yield-bearing reserves will need to redesign financial models.
Federal Oversight and Enforcement Authority
The amended STABLE Act gives broad enforcement powers to federal regulators, particularly the Federal Reserve Board, which would serve as the primary supervisor of Tier 2 issuers. The bill also includes:
- Civil penalties for unlicensed issuance
- Authority to revoke licenses for failing to maintain reserves
- Examination rights, including the ability to audit reserve accounts
- Registration requirements for foreign issuers marketing to U.S. users
Unlike the GENIUS Act, which envisions a shared state-federal framework, the STABLE Act centralizes oversight at the federal level, aiming to create uniformity and reduce regulatory arbitrage.
Operational Insight: Founders relying on a patchwork of state licenses should evaluate whether consolidation under a single federal license could improve compliance consistency—and investor perception.
Disclosure and Consumer Protection Provisions
The 2025 version includes robust consumer protection measures:
- Stablecoin white papers must disclose reserve composition, rights of redemption, legal risks, and affiliations with custodians or affiliates.
- Marketing materials must avoid deceptive claims and clearly state that stablecoins are not FDIC-insured, unless issued by an IDI.
- Consumers must be notified of their rights upon stablecoin acquisition, including redemption timelines and applicable fees.
These provisions align with evolving standards around financial disclosures and mirror some of the regulatory expectations already codified under MiCA in the EU.
How the STABLE Act Compares to Other Frameworks
Compared to MiCA or the GENIUS Act, the STABLE Act remains the most stringent in terms of centralization and enforcement authority. However, the revised version introduces flexibility through its two-tier system, allowing fintechs and crypto companies a possible path to compliance without becoming a full-service bank.
| Feature | Revised STABLE Act (2025) | MiCA (EU) | GENIUS Act (U.S. Senate) |
|---|---|---|---|
| Legal Status | Proposed (House approved) | Enacted | Proposed |
| Issuer Types | Banks + Fed-registered nonbanks | EU-incorporated firms | Banks + qualified state/nonbanks |
| Oversight Body | Federal Reserve | National regulators (EU) | State + federal options |
| Reserve Assets | USD, deposits, short-term Treasuries | Same | Same |
| Redemption Obligation | Yes, enforceable | Yes | Yes |
| Interest Prohibited | Yes | Yes | Yes |
| State-Level Option | No | Not applicable | Yes |
| Monthly Disclosures | Required | Required | Required |
Final Thoughts
The revised STABLE Act represents a significant evolution in U.S. regulatory thinking. By creating clear rules for both banks and nonbanks, the bill may provide the regulatory certainty that institutional players and responsible fintechs have long sought. However, for projects that currently rely on state-chartered licenses or unregulated models, this could mean a fundamental shift in compliance strategy.
While the revised STABLE Act has cleared the House Financial Services Committee, it is not yet law. Issuers should continue tracking parallel legislative efforts (like the GENIUS Act) and consider contingency plans based on varying implementation timelines. In the meantime, aligning with the bill’s reserve, redemption, and disclosure principles may future-proof your model.
At Veritas Global, we help stablecoin issuers and digital asset companies prepare for regulatory change. Whether you’re evaluating entry into the U.S. market or aligning your business model with pending legislation, our legal and strategic team can help you assess your options and structure your operations for resilience and growth.
Ready to navigate the STABLE Act and beyond? Contact us today to position your company for compliant scale.
Read more: Compare the STABLE Act to MiCA and GENIUS or explore our original STABLE Act blog post to dive deeper into the regulatory evolution.
