Florida Stablecoin Issuer Licensing Takes Effect With a $10 Billion Cap

Florida's licensing regime for payment stablecoin issuers took effect on Thursday. A company issuing a dollar-pegged payment token in the state now needs either a money services business licence under chapter 560 or a trust company certificate of approval from the Office of Financial Regulation. The statute is CS/CS/HB 175, enacted as chapter 2026-176, putting issuers inside the law the state already uses for money transmitters. Reserves must cover outstanding tokens at least one-to-one. Consolidated issuance above $10 billion pushes an issuer out of state supervision altogether.

Two doors into the same licence

The Florida Senate's summary puts the choice plainly: an issuer must be "licensed as an MSB or obtaining a certificate of approval as a trust company" before acting as a qualified payment stablecoin issuer. Orrick's July note reads the prohibition from the other side, barring "a person from engaging in the activity of a qualified payment stablecoin issuer in the state unless the person is licensed or exempted." The two accounts agree. Exemptions do most of the work in practice. A federally qualified issuer is out of scope, and so is one already qualified under another state's regime. Peer-to-peer transfers, same-provider movements and self-custody activity sit outside it.

What counts as a reserve

Backing has to be identifiable and at least one-to-one. CryptoSlate's reading of the statute lists US currency, insured deposits, short-term Treasuries, certain repurchase arrangements and government money market funds. Phemex and KuCoin, the latter carrying a ChainCatcher report, give a shorter list and add a limit the statute-level account does not mention: Treasury securities with no more than 93 days remaining. Those two appear to share a wire, so the figure stands on thin ground. The Senate summary gives no maturity at all, pointing instead to "minimum prudential requirements in accordance with the GENIUS Act" — the federal law whose terms the Fed addressed when it proposed tiered capital and two-day redemptions. On the continuing duties the accounts line up: monthly reserve-composition reports, monthly examination by certified public accountants, certifications from the chief executive and chief financial officer, and public disclosure of the redemption policy.

Three accounts say 360 days, the legislature's summary does not

Every source agrees on the trigger. Consolidated outstanding issuance of $10 billion ends the state-only arrangement. What follows is reported two ways. TokenPost, Phemex and KuCoin each say the issuer then has 360 days to move to the federal framework unless a federal exemption is granted, or must pause new issuance until it falls back under the line. The Senate summary says only that such an issuer transitions to federal oversight unless a waiver is obtained, with no period attached. CryptoSlate's statute-level account states outright that it finds no transition period in days. They do not reconcile. We could not establish whether 360 days sits in the enacted text, because the House staff analysis returned "The requested document was not found for this bill" at the address tried.

A second statute lets the state take stablecoins for fees

A companion law, SB 1568, enacted as chapter 2026-175, created the Florida Stablecoin Pilot Program. Orrick's is the only legal reading of it retrieved here. The Department of Financial Services may accept payment stablecoins for governmental fees as a voluntary option, and has to turn what it receives into dollars within a reasonable time. Annual reporting starts on 1 February 2027.

"Convert any payment stablecoin it receives into U.S. currency within a reasonable time after receipt," the pilot statute instructs the department.

One claim needs separating out. A March account called Florida the first US state to build a framework specifically for payment stablecoins, and nothing else read here repeats it. It stands unverified. The shape is familiar elsewhere: Hong Kong cleared regulated stablecoins to trade on licensed venues this year, and a licence plus a reserve test plus a monthly attestation is the common pattern now.

No Florida filing has been made public. The obligations that bite monthly are the accountant's examination and the reserve report, not the licence. Whether 360 days is the real clock gets settled the first time an issuer crosses $10 billion.