Fed Rules for Stablecoins: What to Check on Backing and the Redemption Right

The Federal Reserve published two proposed rules on September 24, 2026 that set out in detail for the first time what a payment stablecoin must be backed by and how quickly an issuer should redeem it. For you as an investor in Germany one sentence puts everything else in order: these rules apply to issuers that sit under the supervision of the US central bank. Your right to redeem a stablecoin you hold in Germany, by contrast, comes from the EU's MiCA regulation. The Fed proposal is therefore above all a reason for you to settle a different question: who stands behind your token, and against whom could you actually direct your claim?

Which stablecoins are authorised under MiCA and how USDT, USDC, EURC and others compare is shown in our stablecoin list.

The distinction sounds technical and decides, in an emergency, whether you get your money back at face value or only the price an exchange happens to quote. This article sorts out both: what has been proposed in Washington, and which rights and duties follow from that for your holdings in Germany.

What the Fed proposed for payment stablecoins on September 24, 2026

The central bank has published two so-called notices of proposed rulemaking, that is, formal drafts followed by a comment period. Both implement the GENIUS Act, the US stablecoin law, and concern exclusively issuers of payment stablecoins supervised by the Federal Reserve.

A payment stablecoin in this framework is a token meant to represent a fixed amount of money and intended for payments. The first draft governs the substance behind it. According to the Fed's statement, supervised issuers must back their stablecoins fully with eligible reserve assets; named are short-dated US government securities, known as Treasury bills, and certain other high-quality liquid assets. On top of that come standardized capital requirements meant to cover credit and operational risks of the stablecoin business, rules for risk management and requirements for the custody of the backing assets.

The second draft is procedural law. It creates a dedicated application process for banks under Fed supervision that want to issue payment stablecoins. Anyone planning to do so must submit a business plan and financial records, among other things. The draft also sets out how objection, hearing and the final decision on an application proceed.

Neither draft is applicable law yet. The Fed will accept comments for 60 days after publication in the Federal Register. Only afterwards will it decide whether the rules arrive, and in what form. You can find the announcement directly at the Federal Reserve.

Full backing with short-dated T-bills: what is meant to count as a reserve

The core of the first draft is a positive list. Not every security works as a reserve for a token that customers want to swap back into dollars at any time. Short-dated Treasury bills are the benchmark, because they carry almost no price risk and can be sold quickly in large amounts.

Why Treasury bills rather than simply bank deposits

A bank deposit is legally a claim against the bank. If the institution runs into trouble, a stablecoin issuer's reserve turns into an insolvency claim. That connection is precisely why supervisors on both sides of the Atlantic argue about the composition of stablecoin reserves. In the EU the matter pulls in the other direction: there the legal framework requires issuers of e-money tokens to hold a considerable part of the reserve as bank deposits, something the European Central Bank has itself recently named as a risk.

For you this mainly yields one check question, and one you can actually answer: does the issuer of your stablecoin regularly publish what its reserve consists of, and who confirms it? Large issuers provide monthly breakdowns and attestations from audit firms. If both are missing, that is no proof of a problem and still a gap in what you know.

The order of magnitude at stake can be measured. CoinGecko market data on September 25, 2026 showed the following market capitalizations for the four largest dollar-linked stablecoins: Tether (USDT) around $183.7 billion, USDC around $75.4 billion, USDS around $9.7 billion and Ethena USDe around $4.9 billion. Together that is about $273.7 billion resting on promises of backing. For comparison: the price of Bitcoin stood at around $84,043 at the same moment.

Capital buffer and application process: what the second draft means for issuers

Capital requirements are something other than reserves. The reserve covers the tokens issued. Capital is the company's own funds cushion, meant to absorb losses from day-to-day operations, for instance from a system failure or the default of a service provider. The Fed wants to standardize these requirements instead of setting them case by case.

The US trade press reads more concrete figures out of the drafts than the announcement itself contains. According to an analysis by PYMNTS of September 24, 2026, supervised issuers are to hold at least one dollar of eligible reserves per dollar issued and to serve customer redemption requests within two business days. The Fed's press release contains no deadline in days and no backing ratio in figures. Anyone quoting the two business days is quoting a reading of the draft text and not the central bank's summary.

Fed Governor Michael Barr issued a statement of his own on the same day and struck a skeptical note in it. According to The Block's report of September 24, 2026, he worries that the standard of "significant or systemic" laid down in the law could have unforeseeable consequences for how reliably the central bank can establish whether an institution maintains compliant programs over time. That is the assessment of one governor, not a position of the board.

Does the Fed rule apply to your stablecoin in Germany?

For an investor resident in Germany the answer as a rule is: no, at least not directly. What governs is the EU regulation on markets in crypto-assets, MiCA for short. The regulation distinguishes two kinds of value-stable token, and that distinction determines your rights.

E-money token and asset-referenced token: the definitions in one sentence each

An e-money token is a crypto-asset that references the value of a single official currency, the euro or the US dollar for example. An asset-referenced token, by contrast, references a basket, such as several currencies, commodities or other assets. The dollar-linked stablecoins you meet in everyday use fall under the stricter category as e-money tokens.

The practical part follows from that. Anyone offering e-money tokens publicly in the EU needs authorization as an electronic money institution or credit institution, and the supervisor lists the authorized issuers in a register. A count of that register by cryptoticker.io on August 16, 2026 produced 23 authorized issuers. A token without an authorized issuer may no longer be offered to European retail customers, which is why some well-known names have disappeared from trading venues for customers in the European Economic Area.

In practice that means: first check whether the token in your account is issued by an issuer authorized in the EU, or whether your trading venue merely carries it as a non-EU product. On a regulated platform you can usually read this in the product description. If you have yet to choose a trading venue, the authorized providers are set side by side in the comparison of the best regulated crypto exchanges.

Redemption right under MiCA: at any time, at face value, free of charge

This is the point at which European law is ahead of the Fed draft. Under MiCA, holders of e-money tokens have a claim at any time that the issuer repay the monetary value of the tokens held at face value, in cash or by transfer. The issuer may not charge a fee for that redemption. Conversely, it may not pay interest on e-money tokens, which is why no issuer can offer you a yield on the bare token.

The words "at any time" are the actual news here. On the trade press reading, the Fed draft works with a deadline of two business days. The European claim names no such figure. It attaches to the holder's request. In practice an issuer will need identity verification and a payment route, and that takes time. Legally your starting position in the EU is still the stronger one.

Why your claim ends at the exchange and not at the issuer

Here lies the gap many investors overlook. The redemption claim is directed against the issuer of the token. If your stablecoins sit in the account of a trading platform, in most cases you do not hold the token yourself. You hold a claim against the platform, which books the token for you. Your route to redemption therefore hangs on the platform, and its solvency comes to stand alongside that of the issuer.

The difference only becomes visible under stress, and by then it is too late to reposition. A frozen account, a halt on withdrawals or insolvency proceedings separate you from a token whose backing is perfectly sound. Anyone holding the token in their own wallet has the issuer as counterparty and a direct route to redemption, provided the issuer serves retail customers at all. Many do so only above high minimum amounts and after their own identity checks.

There is a second layer that applies independently of insolvency. Issuers can freeze individual addresses when authorities order it or a suspicion of money laundering exists. A frozen balance is neither lost nor available, and the way back leads through the issuer instead of through the exchange.

Five points to check on your stablecoin holdings now

The Fed draft changes nothing for you legally today. It is, however, a good occasion to go through your own position once, because the check goes faster without time pressure than in an emergency.

1. Which token actually sits in the account. USDT, USDC, USDS and a synthetic dollar such as USDe are four different constructions with four different risk profiles. The ticker on the screen tells you nothing about the issuer.
2. Who the issuer is and in which legal system it sits. Authorization in the EU decides whether you have a redemption claim under MiCA or a claim under foreign law.
3. Where the token sits. On the exchange you hold a claim against the exchange. In your own wallet you hold the token and have the issuer as counterparty.
4. Whether the issuer discloses its reserve. Monthly breakdowns and attestations by an audit firm are the standard you can measure against.
5. Which routes are open to you if your trading venue drops the token. Delistings in the European Economic Area have repeatedly set deadlines for sale and withdrawal in recent months. Miss the deadline and you leave the conversion to the provider.

Stablecoin swaps and tax: why the switch is taxable in Germany

One point that regularly gets lost when repositioning: swapping one stablecoin for another is a disposal transaction in Germany. For tax purposes a stablecoin is another economic asset, not a euro balance, and therefore the move from one token into another is a tax-relevant event, even though the value does not change.

In practice the gain is usually small, because the price barely moves. Under the rules for private disposal transactions, gains stay tax free if more than a year lies between acquisition and sale; below that holding period your personal income tax rate applies, and an exemption threshold of 1,000 euros applies to the sum of all private disposal gains in a year. The real effort lies not in the tax burden but in the documentation: every swap needs a time, a quantity, a price and a counter value, and across repositioning over several platforms that quickly becomes hard to follow.

If you are going through your holdings anyway, you should put the records in order in the same pass. That is the moment when a tool that consolidates inflows and outflows across several accounts pays for itself.

What the draft is not yet: comment period and open points

In the United States several steps lie between a proposed rule and applicable law. The Fed collects comments for 60 days after publication in the Federal Register, evaluates them and then publishes a final version, which may differ from the current one. Which capital ratio ends up in place is therefore open.

Also open is how the two legal areas relate to each other. An issuer supervised by the Fed in the United States that offers in the EU through a subsidiary with MiCA authorization is subject to two sets of rules with different reserve requirements. Whether that leads to separate reserve pools per jurisdiction is in neither of the two drafts. For you as a holder that is the question of which pool stands behind your token, and today it can only be answered through the issuer's product documents.

What can already be observed, on the other hand: in stablecoins, supervision is moving on from the question of whether they are permitted to the question of how well they are backed. Both Fed drafts revolve around backing, capital and custody. That is the same direction MiCA has been setting in the EU since last year.

Checking your stablecoin redemption right: what to take away

1. Establish who stands behind your token. Check whether the issuer holds an EU authorization, because that determines whether you can assert the claim to redemption at face value at all. Trading venues with European authorization state this in the product details; an overview is offered by the comparison of the best regulated crypto exchanges.
2. Put the records in order before you reposition. Every swap between two stablecoins is a tax-relevant event with a time, a quantity and a counter value. A portfolio tool takes over the allocation across several accounts; the common programs are in the overview of crypto tax software and portfolio trackers.
3. Decide deliberately where the holdings sit. In an exchange account you share the platform's risk; in your own custody you carry the responsibility for the keys. If you want to take the second route, the devices are set side by side in the hardware wallet comparison.

(As of September 25, 2026. This article is not investment advice. Prices and fee structures change; check the terms with the provider before you buy.)