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Reports/Stablecoins/The stablecoin standard vs. the GENIUS Act
Stablecoins

The World Has Largely Agreed on What a Trustworthy Stablecoin Looks Like. Five Already Meet the Bar. The Biggest One Keeps Choosing Not To.

Europe, Hong Kong and now the US have each written down roughly the same definition of a credible stablecoin: fully backed, independently audited, openly disclosed. Five dollar stablecoins from five different issuers already live up to it, landing on nearly identical marks across the board. The exception is USDT, the largest and most-used stablecoin in the world. It could clear the same bar; full disclosure would be straightforward for it. Instead, as regulators everywhere moved toward transparency, its issuer moved the other way — relocating to one of the few places without those rules. The paradox is the story: the market leader, with the most trust to gain, is the least verified of the group — by choice.

Key findings
  • →The world's major jurisdictions have converged on roughly the same definition of a trustworthy stablecoin — full reserve backing, independent audit, open disclosure — across the EU's MiCA, Hong Kong's Stablecoins Ordinance and the US GENIUS Act (2024–2026). Credibility is increasingly defined by transparency.
  • →Five dollar stablecoins from five different issuers — Circle (USDC), PayPal (PYUSD), Ripple (RLUSD), Paxos (USDP) and Gemini (GUSD) — already meet the stricter version of that bar: a top-tier trust charter, a PCAOB-registered auditor, and a recent reserve attestation. On OnChain Benchmark's scoring they land on nearly identical marks (reserve quality 23 of 25; transparency 18–19 of 20), as of July 2026.
  • →The exception is USDT, the largest and most-used stablecoin (~US$190B). By liquidity it is the deepest of the group (it out-scores USDC on redemption depth, 24 vs 19); its lower marks are about disclosure — reserve quality 6 of 25, because reserves are attested in aggregate rather than independently audited. This is a choice, and a paradox: as regulators everywhere moved toward transparency, Tether relocated from the British Virgin Islands to El Salvador, one of the few places without those requirements — leaving the market leader, with the most to gain from trust, the least verified of the set.
OnChain Benchmark ResearchPublished · Jul 27, 2026, 10:10 PM UTCData current · Jul 27, 2026

Over the past two years, the world's major financial jurisdictions have quietly agreed on what a trustworthy stablecoin is supposed to look like. The EU's MiCA regime is now fully in force; Hong Kong passed a Stablecoins Ordinance; the US passed the GENIUS Act. The details differ, but the core is strikingly consistent: reserves fully backed by safe assets, independently audited, and openly disclosed. After years in which “stablecoin” could mean almost anything, credibility is settling on a single idea — transparency.

On-chain, you can see who has met that bar and who hasn't. Five dollar stablecoins from five different issuers — Circle's USDC, PayPal's PYUSD, Ripple's RLUSD, Paxos' USDP and Gemini's GUSD — have arrived at the same shape: each is issued under a top-tier trust charter, each is audited by a PCAOB-registered accounting firm, and each publishes a recent reserve attestation. Five separate companies, the same three choices — and on a common set of measures they come out nearly on top of each other: reserve quality 23 out of 25 for all five, transparency 18 to 19 out of 20. Not similar. Nearly identical. Most got there before the rules that would require it were final — because for an issuer that wants to be trusted by banks and institutions, this is the price of admission now.

Five audited issuers, one reserve-quality mark23USDC · PYUSD · RLUSD · USDP · GUSD — the same mark, five different companies
Jurisdictions now demanding audit and disclosure3the EU (MiCA), Hong Kong and the US (GENIUS) — a converging global bar
USDT's mark — the largest, the least verified6reserve quality of 25 — reserves attested in aggregate, not independently audited

Fig. 1

By money: one unaudited coin, then USDC, then almost nothing.

Each coin's share of the major dollar stablecoins we measure (~US$268B), by circulating supply. USDT alone is ~71% (~US$191B). Of the five coins that carry a top-tier trust charter and an independent audit, only USDC (~25%) is large; PYUSD, RLUSD, USDP and GUSD are each a fraction of a percent. So the audited standard is now the norm by count of issuers — but by dollars, it rests largely on USDC while the market's most-used coin sits outside it.

ONCHAIN
BENCHMARK
0.0%20.0%40.0%60.0%80.0%USDTUSDCPYUSDRLUSDUSDPGUSDSHARE
Source: OnChain Benchmark — measured on-chain supply × NAV, Jul 27, 2026 · onchainbenchmark.comJul 27, 2026
See coverage →

A standard the market wrote itself

What these regimes ask for is not exotic, and it is largely the same everywhere: reserves fully backed by cash and short-term government debt, kept segregated; regular disclosure of what's in the reserve; and independent verification of it. The five coins above do the stricter version — not self-certified assertions but audits from firms registered with the accounting industry's own oversight board. Most didn't wait for any single country's rules to be final. For an issuer that wants to be trusted by banks and institutions across markets, this is the price of admission now, and it is converging into one recognizable shape.

So why is the biggest one the exception?

Which makes the outlier the interesting part — and the outlier is enormous. USDT is the largest dollar stablecoin by a wide margin, roughly US$191 billion, and the most heavily used token in crypto. It is 2.7 times the size of the five audited coins combined, which together hold about US$71 billion. It is also the least independently verified of the group: a reserve-quality mark of 6 out of 25 against the 23 the others carry. Not because anyone doubts it can pay out — by liquidity it is the deepest dollar token there is — but because its reserves are disclosed in aggregate through a voluntary attestation rather than an independent, line-item audit. That has been the standing criticism of USDT for years, and it remains true today.

Fig. 2

Five coins meet the reserve bar. The biggest one is far below it.

Reserve-quality score (of 25) for each fiat-backed dollar stablecoin we rate. Five different issuers — USDC, PYUSD, RLUSD, USDP, GUSD — sit together at 23, each carrying a top-tier trust charter and an independent audit. USDT sits at 6: its reserves are attested in aggregate, not independently audited. (Algorithmic and synthetic-dollar coins are scored on a different basis and excluded here.)

ONCHAIN
BENCHMARK
010203040USDCPYUSDRLUSDUSDPGUSDUSDTRESERVE QUALITY
Source: OnChain Benchmark — reserve-quality dimension, v1.2 stablecoin methodology · onchainbenchmark.comJul 27, 2026
How we score reserves →

Closing that gap would be, for Tether, both easy and rewarding. Tether is one of the most profitable companies in finance, its reserves are widely believed to sit well above what it owes, and a full independent audit is the most direct route from “biggest” to “most trusted” — the one distinction USDT's smaller rivals hold that it does not. Instead, as one jurisdiction after another moved toward mandatory disclosure, Tether moved the opposite way, relocating from the British Virgin Islands to El Salvador in early 2025 — a jurisdiction courting crypto firms with tax exemptions and light-touch oversight rather than audit mandates. The world's most-used dollar met a tightening consensus on transparency by seating itself outside of it.

Tether is not standing still: it has engaged a Big Four firm for a full audit and spun up a separate, US-compliant coin, USAT, for the American market. But USAT is a sideline; USDT is the franchise, and USDT stays the least independently verified major stablecoin even as verification becomes the industry's defining test. The pattern that holds across the rest of the market — that scale and scrutiny rise together — breaks at the top. Whether it keeps breaking is the question the next two years answer: either the largest stablecoin converges to the standard its challengers already meet, or it becomes the working proof that at sufficient scale, a dollar can dominate global crypto without ever being audited like one.

Five issuers, one structureCross-issuer scoringIdentical marks

USDC (Circle), PYUSD (PayPal/Paxos), RLUSD (Ripple), USDP (Paxos) and GUSD (Gemini) each carry a top-tier US trust charter, a PCAOB-registered auditor and a recent reserve attestation, and score reserve quality 23/25 with transparency 18–19/20. Scored on identical axes, they land on nearly the same marks — a shared standard across five separate issuers.

Verified Jul 27, 2026 · onchainbenchmark.com/methodology
The rules aren't in force yetRegulatory statusPrimary timeline

The GENIUS Act was signed July 18, 2025. As of mid-2026 the OCC, FDIC, Treasury and Federal Reserve implementing rules remain proposals; the statute takes effect January 18, 2027, or 120 days after final rules. So the shared market standard predates the binding federal requirement.

The Block — What Is the GENIUS Act
Why USDT is outside — jurisdictionRegulatory structurePublic record

USDT is issued by Tether, which is based in El Salvador, not the US. The GENIUS Act permits compliant payment stablecoins only from US-domiciled issuers, so USDT cannot take the US path the other five did. Rather than reorganize USDT, Tether launched a separate US-market coin, USAT (Sept 2025, via a US banking partner). A three-year grace period applies, ~two years of which remain, after which US platforms cannot offer non-compliant issuers' coins.

CoinDesk — Tether's USDT two-year countdown
USDT — verification, not soundnessDimension decompositionPer-axis read

USDT (~US$190B) scores redemption depth 24/25 — higher than USDC's 19 — reflecting the deepest on-chain liquidity of any dollar token. Its reserve-quality score is 6/25 because reserves are disclosed in aggregate via a voluntary third-party attestation rather than an independent line-item audit. The gap is in how reserves are verified, not in the coin's demonstrated ability to redeem. Tether has engaged a Big Four firm for a full audit.

Verified Jul 27, 2026 · onchainbenchmark.com/instruments/usdt
MethodologyWe score fiat-backed dollar stablecoins on the same axes — reserve quality (of 25), transparency (of 20), and redemption depth (of 25) among them — from published attestations, audit and charter status, and on-chain reserve and redemption data. The five coins described as sharing a standard each hold a top-tier US trust charter, a PCAOB-registered auditor and a recent attestation; the marks are a snapshot of their current filings, not a claim about when each adopted that structure. Algorithmic and synthetic-dollar coins (e.g. GHO, Frax, USDe) are scored on a different basis and are excluded from the fiat-backed comparison. The comparison covers the stablecoins we rate, not every stablecoin in existence. No issuer is rated as trustworthy or not — the scores describe verifiable structure. Full methodology: onchainbenchmark.com/methodology.
Questions & answers
What compliance standard have regulated stablecoins converged on?
Five US-facing dollar stablecoins — USDC (Circle), PYUSD (PayPal), RLUSD (Ripple), USDP (Paxos) and GUSD (Gemini) — currently share the same structure: a top-tier US trust charter, a PCAOB-registered auditor, and a recent reserve attestation. On OnChain Benchmark's scoring they land on nearly identical marks (reserve quality 23 of 25; transparency 18–19 of 20), as of July 2026. It is effectively a shared market standard.
Does the GENIUS Act already require this?
Not yet in force. The GENIUS Act was signed on July 18, 2025, but the implementing rules from the OCC, FDIC, Treasury and Federal Reserve remained proposals as of mid-2026, and the statute takes effect January 18, 2027 (or 120 days after final rules). The five coins meet the stricter version of what the law is expected to require before the binding rules exist.
Is Tether a US-regulated stablecoin issuer?
No. Tether, the issuer of USDT, is based in El Salvador, not the United States. The GENIUS Act only permits US-domiciled issuers to run a compliant payment stablecoin, so USDT cannot take the same US regulatory path as USDC, PYUSD, RLUSD, USDP and GUSD. Rather than reorganize USDT, Tether launched a separate US-market stablecoin, USAT, in September 2025 through a US banking partner — keeping USDT as its global coin. So the world's largest stablecoin sits, by design, outside the US framework its main rivals have organized around.
Why does USDT score lower if it's the largest stablecoin?
Not because of soundness — on redemption depth, the read on whether a coin can be redeemed at scale, USDT actually out-scores USDC (24 vs 19), reflecting the deepest on-chain liquidity of any dollar token. Its lower reserve-quality score (6 of 25) comes from disclosing reserves in aggregate via a voluntary attestation rather than an independent, line-item audit. The notable part is that this is a choice: an audit would be straightforward for Tether and would be the surest way to convert its size into trust, yet as global regulators moved toward mandatory disclosure it relocated to El Salvador, a lighter-touch jurisdiction. Tether has since engaged a Big Four firm for a full audit, which would narrow the gap.
Is USDT unsafe or untrustworthy?
That's not what the scores say. By the redemption-depth read — whether the coin can actually be redeemed at scale — USDT is the best-positioned of the group. The scores describe how independently a coin's reserves are verified, not a judgment of trustworthiness, and USDT's lighter verification is a disclosed choice that is in the process of changing.
Key facts
SubjectThe stablecoin standard vs. the GENIUS Act
Issuers sharing the standard5 (reserve 23/25)
USDC / PYUSD / RLUSD23 · 23 · 23
USDP / GUSD23 · 23
USDT (largest)6 — verification gap ↗
GENIUS rules statusPending → effective Jan 2027
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