According to Woofun AI, the US Treasury established a key policy breakthrough on September 30, allowing states to preserve a pathway to obtain stablecoin regulatory system authorization by submitting preliminary certifications even when relevant regulations are not yet fully developed.

This interim final rule, led by the Stablecoin Certification Review Committee, aims to provide federal agencies with clear forms and review procedures for evaluating state stablecoin regulatory proposals, ensuring that conditional or incomplete certifications can still meet preliminary submission deadlines even if states plan to take further legislative or regulatory measures.

Regarding the application process mechanism and conditional restrictions, the rule clearly states that no certification applications will be accepted until the information collection work is approved under the Paperwork Reduction Act. The US Treasury will separately notify the specific acceptance timeline. For qualifying state-level payment stablecoin issuers with total issuance not exceeding $10 billion, this flexibility is crucial.

If state-level regulators can demonstrate that their systems meet the "substantial similarity" standards set by the US Treasury, and the Committee unanimously determines that they meet or exceed the standards and requirements stipulated in Section 4(a) of the GENIUS Act, these issuers may choose to accept state-level regulation.

It is worth noting that data compiled by Woofun AI shows that CryptoSlate pointed out in July that assessing the equivalent effectiveness of state regulatory systems is extremely difficult given the unsettled rules of the federal government, the US Treasury, and the Office of the Comptroller of the Currency (OCC.US). To this end, relevant states must provide an unconditional statement signed by an authorized representative, a detailed explanation of how the regulatory system meets similarity standards, and legal documents and materials deemed necessary by the Committee.

Such conditional certification applications can be amended at any time and will neither initiate formal review nor start the 30-day authorization or rejection period stipulated by the Committee. The clock only begins once submitted according to the prescribed process. Another independent proposal by the US Treasury regarding "substantial similarity" standards aims to clarify the criteria for comparing state-level and federal-level regulatory systems, but the procedural rules issued in September did not finalize these criteria.

Key timing nodes are closely linked to the Act's effective logic. Based on the GENIUS Act's expected effective date of January 18, 2027, the rule sets the initial certification deadline as January 18, 2028. The law stipulates that the actual application submission deadline should be one year after the Act takes effect, but the Act may take effect earlier.

Section 20 of the Act provides for the earlier of two dates: either 18 months after the Act's enactment, or 120 days after the federal-level payment stablecoin regulator issues relevant implementation rules. The deadline for feedback on these interim rules is November 30.

This arrangement leaves states time to complete legislative or regulatory work after meeting preliminary deadline requirements, but it will not automatically approve state regulatory systems nor issue licenses to specific stablecoin issuers. Although the interim final rule provides forms and review procedures and grants certain preliminary submission flexibility, it still retains strict authorization requirements. The independent proposal aims to clarify comparison criteria, while the procedural rules have not yet finalized these criteria.

This is another key refinement in the implementation and execution of stablecoin regulation in the United States following the establishment of the GENIUS Act framework, marking the transition from principled legislation to operational review.