US state stablecoin frameworks operate alongside the federal GENIUS Act. Wyoming launched the Frontier Stable Token (FRNT) on Aug 19, 2025, the first state-issued stablecoin, with 102% reserve backing and live deployment across 7 chains. New York's NYDFS supervises USD-pegged stablecoins through its limited-purpose trust framework, used by Paxos and Gemini. Other states are advancing issuance and custody frameworks under the GENIUS Act state-certification path opened by the Apr 2026 Treasury NPRM.
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Stablecoin Regulation by US State: Wyoming, NY, Texas, and More

Stablecoin regulation by state in the United States is a patchwork of trust charters, money transmitter licenses, and special-purpose bank charters that operate alongside the federal framework created by the GENIUS Act of 2025. Issuers picking a U.S. pathway today choose between a state-level license, a federal qualified payment stablecoin issuer (QPSI) charter, or both. This guide walks through six state regimes that issuers actually use , Wyoming, New York, Texas, California, Florida, and Illinois , and how each one interacts with the federal floor that took effect on July 18, 2025. It is not legal advice; cite the regulator's site and a licensed attorney before filing.
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The GENIUS Act, signed by President Trump on July 18, 2025, established the first federal framework for payment stablecoins. The statute creates a federal license for "permitted payment stablecoin issuers" supervised by the OCC, FDIC, or Federal Reserve, and runs a parallel state pathway for issuers with consolidated outstanding stablecoins under $10 billion. State regimes that meet a "substantially similar" test, certified by a Treasury-led review panel, can keep regulating issuers below that threshold.
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Two practical consequences. First, state charters did not become obsolete on July 18 , the law's section-by-section summary codifies a 36-month transition window, so existing state-licensed issuers operate under their current frameworks while regulators publish implementing rules. Second, issuers that already hold a New York limited-purpose trust charter or a Wyoming Special Purpose Depository Institution charter can continue under those regimes if their state is certified, then graduate to the federal pathway when they cross $10 billion in circulating supply.
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State-level pathways still matter for three reasons. State chartering tends to be faster than the federal alternative, with Wyoming SPDI applications historically closing in 12 to 18 months versus an estimated 18 to 24 months for an OCC trust charter. Some states confer commercial benefits: a New York trust charter permits custody of customer crypto assets, and a Wyoming SPDI is the only U.S. depository institution explicitly permitted to hold digital assets without FDIC insurance. And state regimes set the floor for activities that fall outside payment stablecoins entirely, such as algorithmic stablecoins, yield-bearing tokens, and tokenized deposits , categories the GENIUS Act either restricts or excludes.
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Wyoming's House Bill 74, signed in February 2019 and codified at Wyo. Stat. § 13-12-101 et seq., created the Special Purpose Depository Institution (SPDI) , a state-chartered bank designed for businesses that handle digital assets. SPDIs are supervised by the Wyoming Division of Banking and must hold 100% reserves against demand deposits, are prohibited from making loans against deposits, and cannot accept FDIC insurance.
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Commercium Financial (chartered August 2021). Kraken's charter was the first; Custodia's January 2023 denial from the Federal Reserve to obtain a master account became the leading test case on whether SPDIs can plug directly into the Fedwire system. The Tenth Circuit affirmed the denial in October 2025, leaving SPDIs without direct Fed access.
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For stablecoin issuers specifically, the SPDI structure is attractive because it allows the issuer to take fiat deposits backing the stablecoin and hold them with the issuer's own bank charter rather than a third-party custodian. The SPDI's required application guidance sets a $5 million minimum capital floor, requires a three-year business plan with stress scenarios, and obligates a stablecoin-issuer SPDI to maintain a custody agreement that segregates customer assets from the bank's general estate. Application fees run $5,000 to $10,000, with examination assessments thereafter based on assets under management.
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New York runs the most heavily-used state regime for stablecoin issuance. The New York Department of Financial Services (DFS) operates two relevant licenses: the BitLicense, codified at 23 NYCRR Part 200 and effective June 24, 2015, and the limited-purpose trust company charter under New York Banking Law § 102-a. Most stablecoin issuers choose the trust charter because it permits fiduciary custody of customer assets and avoids some of the BitLicense's transaction-licensing constraints.
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Notable trust-chartered issuers include Paxos Trust Company (chartered May 2015), Gemini Trust Company (chartered October 2015), and Circle Internet Financial's New York affiliate. DFS issued specific stablecoin guidance on June 8, 2022, requiring USD-backed stablecoins issued under DFS authority to maintain reserves of cash, U.S. Treasury bills with three-month-or-less maturity, or reverse repos collateralized by Treasury securities. Reserves must be segregated from the issuer's proprietary assets and verified monthly by an independent CPA following AICPA attestation standards.
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DFS also publishes a greenlist of pre-approved coins that licensed entities can list without separate regulatory approval. As of late 2025 the greenlist included USDC, GUSD, PYUSD, RLUSD, and a handful of non-stablecoin tokens. Issuers that want to add a new stablecoin to a DFS-supervised exchange's offering can submit a self-certification under the streamlined process introduced in November 2023, which compresses what was a multi-month review into a typical 30-to-60-day window. Application fees for a trust charter run on a sliding scale; the base examination fee is approximately $5,000 with ongoing assessments tied to assets under management.
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Texas has not enacted a bespoke stablecoin or virtual-currency statute. Instead, the Texas Department of Banking treats sovereign-backed stablecoins as "money" under the Texas Money Services Act (Tex. Fin. Code Ch. 151) per Supervisory Memorandum 1037, originally issued April 2019 and most recently updated January 2023. The memo distinguishes between "sovereign-backed" stablecoins (those redeemable 1:1 for U.S. dollars or another fiat currency, which trigger MSB licensing) and other digital assets (which generally do not).
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For a stablecoin issuer that plans to take customer fiat in Texas and issue tokens redeemable for that fiat, a Texas Money Transmitter license is required. The application is filed through the Department of Banking's MSB portal and through NMLS for multi-state efficiency. Net worth requirements scale with transaction volume , minimum $300,000 net worth, plus $0.05 per dollar of average daily outstanding obligations, capped at $2 million. Surety bond requirements run $300,000 to $2 million. Fees include a $10,000 application fee plus annual assessments.
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Texas examiners have signaled that custodial wallets holding stablecoins for customers , whether by an exchange, a payment processor, or a remittance company , also fall under the MSB regime. The 2024 Texas Working Group on Blockchain Matters report estimated that approximately 60 entities held active MSB licenses with crypto-related activity disclosed, up from roughly 25 in 2021. Texas does not currently require separate stablecoin reserve disclosures beyond standard MSB safety-and-soundness reporting, but the supervisory memo allows examiners to require attestations as a condition of license maintenance.
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California enacted the Digital Financial Assets Law (DFAL) when Governor Gavin Newsom signed Assembly Bill 39 on October 13, 2023. The law became operative July 1, 2026, after an initial 18-month delay from its original July 2025 effective date , a postponement signed into law by AB 1934 in September 2024 to give the Department of Financial Protection and Innovation (DFPI) more time to write implementing regulations.
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DFAL requires any person engaged in "digital financial asset business activity" with California residents to hold a DFPI license. Stablecoin issuance falls squarely within the statute's definition. The law goes further than most state regimes by addressing stablecoin reserves directly: section 3601 of the California Financial Code (as added by DFAL) requires a stablecoin issuer to maintain reserves of "United States dollars or eligible securities" in an amount no less than the aggregate par value of outstanding stablecoins, with eligible securities limited to short-duration Treasury bills, certain reverse repos, and money-market funds. The DFPI may also designate stablecoins for use by licensees through an approval process modeled in part on the New York greenlist.
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The licensure path includes an application fee, ongoing assessments based on California-attributable transaction volume, and customer disclosures specified in Cal. Fin. Code § 3502. The DFPI DFAL portal began accepting pre-applications in early 2026, with full licensure expected to commence on the operative date. California's volume-weighted importance , the state accounts for an estimated 12% to 14% of U.S. retail crypto transaction volume per Chainalysis 2024 Geography of Crypto data , makes DFAL compliance a practical requirement for any consumer-facing stablecoin issuer, even one chartered elsewhere.
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Florida regulates stablecoin issuance and custody through its Money Services Business framework codified at Florida Statutes Chapter 560 and supervised by the Office of Financial Regulation (OFR). Florida classifies sovereign-backed stablecoins as "monetary value" under § 560.103, requiring Part II MSB licensure for issuers that take customer fiat in exchange for the token. Net worth and surety bond requirements are tiered by transmission volume, starting at $100,000 net worth and a $50,000 bond at the entry tier. Florida has not published a separate stablecoin reserve regulation; it relies on standard MSB safety-and-soundness examinations supplemented by guidance letters issued through the OFR's industry portal.
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Florida's volume of MSB activity is meaningful: as of late 2024 the state listed roughly 950 active money transmitters, with an estimated 70 to 90 disclosing virtual-currency activity. The state has been broadly accommodating to fintech operators but has not enacted a digital-asset-specific statute, leaving stablecoin issuers under the same MSB regime as cross-border remittance companies and prepaid card programs.
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Illinois moved later but more comprehensively. The Digital Assets and Consumer Protection Act (SB 1797) was signed by Governor Pritzker on August 18, 2025. The act assigns supervisory authority to the Illinois Department of Financial and Professional Regulation (IDFPR) and requires licensure for "digital asset business activity," defined to include exchange, custody, and stablecoin issuance with Illinois residents. Initial license application fees are $5,000 with ongoing assessments tied to Illinois-attributable transaction volume. ​
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Illinois's reserve provisions parallel California's at a high level: stablecoin issuers must maintain reserves of cash and short-duration Treasuries equal to or exceeding outstanding circulation, with monthly attestation and quarterly examiner reporting. Illinois explicitly excludes algorithmic and yield-bearing stablecoins from the licensable category, mirroring the GENIUS Act's federal exclusions. The IDFPR's digital assets portal opened for pre-licensure consultations in October 2025.
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Each state pathway optimizes for different issuer profiles. Wyoming SPDI suits issuers that want a bank charter and are willing to forgo Fed master-account access, with the lowest capital floor at $5 million. New York's trust charter is the most established and widely-recognized regime, with the deepest greenlist and the heaviest examination burden, suited to issuers planning to operate consumer-facing custody services. Texas, Florida, and Illinois rely on money-transmitter licensure that scales by volume and is generally cheaper to enter than a bank charter. California's DFAL, operative July 1, 2026, sits between MSB licensure and a bank charter , a digital-asset-specific license with detailed reserve and disclosure rules.

Issuers planning national distribution typically pursue New York or Wyoming as the primary charter, then either layer state MSB licenses for transaction-flow states or pursue federal QPSI status post-GENIUS. The federal pathway becomes economically attractive somewhere between $1 billion and $10 billion in circulating supply, given examination overhead and the master-account question. Below that level, state regimes generally offer lower per-unit compliance cost.
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Eco operates as a stablecoin orchestration network, not as an issuer, and routes USDC, USDT, USDT0, oUSDT, and several other stablecoins across 15 supported chains including Ethereum, Base, Arbitrum, Solana, and Plasma. Issuers using Eco Routes for cross-chain settlement remain subject to whichever state or federal regime governs their issuance; Eco's role is execution-layer, similar to how Visa or SWIFT route value without issuing it. The Routes CLI and API give issuers a single interface for moving reserves between chains while maintaining the audit trail their state examiner expects.
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No. The GENIUS Act creates a federal floor for payment stablecoin issuance but preserves a state pathway for issuers under $10 billion in consolidated outstanding stablecoins, provided the state regime is certified as substantially similar by a Treasury-led review panel. Wyoming, New York, and California are widely expected to qualify based on their existing frameworks.
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Texas and Florida MSB licensure typically have the lowest entry capital, starting at roughly $100,000 to $300,000 in net worth plus a surety bond, versus $5 million for a Wyoming SPDI charter. The trade-off is that MSB licenses do not confer bank status and limit the issuer to transmitting rather than holding deposits backing the token directly.
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Not directly, as of 2026. The Tenth Circuit affirmed the Fed's denial of Custodia Bank's master account application on October 31, 2025. The GENIUS Act does not change this outcome; it remains an open question whether federal QPSI status changes Reserve Bank access in the future. ​
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For issuance and primary distribution, generally yes , most states define "money transmission" or "digital asset business activity" to include exchanges with that state's residents. Secondary trading on third-party venues is typically the venue's licensing burden, not the issuer's. New York's BitLicense, however, can reach further upstream when consumer-facing activity occurs in New York.
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A New York trust charter is a fiduciary entity that custodies customer assets but is not a depository institution; a Wyoming SPDI is a depository bank that takes fiat deposits and holds 100% reserves. Trust charters are faster to obtain and lower-capital but limit certain banking activities; SPDIs offer fuller bank powers but cannot access FDIC insurance or, today, Fed master accounts.
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