The Act takes effect on the earlier of two dates
What the document says“This Act, and the amendments made by this Act, shall take effect on the earlier of (1) the date that is 18 months after the date of enactment of this Act; or (2) the date that is 120 days after the date on which the primary Federal payment stablecoin regulators issue any final regulations implementing this Act.”
The whole section. The Act was approved July 18, 2025, so the first date falls in January 2027. The second depends on when the Federal regulators issue final implementing regulations, which section 13 requires within one year of enactment. Section 4(c)(4), section 5(f) and section 13(c) each run their own clocks from the effective date rather than from enactment.
What the document actually says“This Act, and the amendments made by this Act, shall take effect on the earlier of (1) the date that is 18 months after the date of enactment of this Act; or (2) the date that is 120 days after the date on which the primary Federal payment stablecoin regulators issue any final regulations implementing this Act.”
This law starts on one of two days. One is 18 months after it passed. The other is 120 days after the watchdogs put out final rules. The earlier day wins.
The law passed on July 18, 2025. So the first day falls in January 2027. Part 13 gives the watchdogs one year to write the rules.
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