Stablecoins Need an Operator’s Rulebook, Not Just a Regulator’s Rulebook

Every major payments infrastructure breakthrough in the United States has had two things in common: a regulatory framework that defined what it could and couldn’t do, and an operational rulebook that defined how it actually had to work. ACH has the NACHA Operating Rules. Card networks have their dispute and chargeback frameworks. FedWire has Regulation J. FedNow and RTP both launched with detailed participation agreements and operating rules before a single live transaction was processed.

Stablecoin payment networks? So far, mostly white papers and LinkedIn posts.

The GENIUS Act — signed into law in July 2025 — is a genuine landmark. It establishes federal regulatory supervision for payment stablecoin issuers, mandates 100% reserve backing with liquid assets, and requires AML programs consistent with those maintained by traditional financial institutions. It brought the United States from regulatory ambiguity to a defined legal framework in a single legislative stroke.

But here is what it does not do: it does not tell a stablecoin payment network how to handle a disputed transaction. It does not define return codes, unauthorized transaction windows, or funds availability commitments. It does not establish liability allocation between the originating party, the receiving party, and the network operator when something goes wrong.

That is not a failure of the legislation. That is precisely what industry-developed operating rules exist to solve.

What NACHA Built — and Why It Mattered

I have spent over twenty-five years in the payments industry, and one of the most underappreciated facts about ACH is that its durability is not primarily a product of regulation. It is a product of governance.

The NACHA Operating Rules created a binding, enforceable, and regularly updated framework that defined how every participant in the ACH network had to behave — as an originator, as a receiver, as an ODFI, as an RDFI. Those rules specified return timeframes to the day. Error resolution procedures, step by step. Unauthorized transaction rights, clearly allocated. Record retention requirements, with no ambiguity about who bears responsibility. Liability allocation between parties, tested through actual disputes and refined through each annual rule revision cycle.

These were not suggested best practices. They were operating conditions — the price of admission to a network that processed trillions of dollars annually.

The result was a network that financial institutions, businesses, and consumers could trust — not because the government mandated every operational detail, but because the industry had built a governance architecture that made trust structurally possible. NACHA did not tell Congress what ACH had to do. NACHA told its members what ACH participants had to do. That distinction is the entire ballgame.

That governance continues to evolve. NACHA’s 2026 rule amendments introduce mandatory fraud monitoring for all ACH network participants (effective March 20, 2026, with Phase 2 on June 22, 2026) and new standardized entry descriptions for Payroll and Purchase transactions — the kind of ongoing, iterative rulemaking that stablecoin networks have yet to achieve.

The GENIUS Act tells stablecoin issuers what they must be. The operator’s rulebook tells the network how it must behave. The industry cannot afford to confuse the two.

— Anthony Serio, Co-Founder & COO, 7T World LLC

The Gap That Exists Right Now

At 7T World, we have spent considerable time building exactly this kind of governance framework for stablecoin payment networks — not because regulators asked for it, but because any serious payment infrastructure operator understands that the rulebook is the product.

When we examined what the stablecoin payment industry currently has, the gaps were significant. There is no industry-standard definition of a stablecoin payment return. There is no standard dispute resolution window — not 24 hours, not 48, not five business days. There is no shared understanding of liability allocation when a stablecoin payment is misdirected, delayed by a network event, or processed against a frozen wallet. There is no equivalent to a NACHA-audited compliance program for stablecoin network participation.

These are not hypothetical problems. They are the exact problems that ACH, wire, and card networks solved over decades — problems that are going to be forced into the open quickly as institutional adoption accelerates and consumer-facing stablecoin use cases multiply.

Since this article was first published, that urgency has only intensified. On February 25, 2026, the OCC issued Bulletin 2026-3, proposing comprehensive regulations to implement the GENIUS Act. The proposed rule would create a new 12 CFR Part 15, covering licensing, reserves, capital, custody, reporting, supervisory fees, and enforcement for payment stablecoin issuers under OCC jurisdiction. The FDIC separately proposed implementing rules on December 16, 2025. Comments close May 1, 2026, with final rules due by July 18, 2026 and full enforcement beginning January 18, 2027. The regulatory machinery is moving. The operating rule infrastructure must keep pace.

What an Operator’s Rulebook Must Include

Based on building 7T World’s governance framework from the ground up — using the NACHA architecture as the reference model — here is what a mature stablecoin payment network operating rulebook needs to cover at minimum.

Transaction finality standards. At what point is a stablecoin payment final and irrevocable, and what obligations attach before and after that point? This is not a blockchain question. It is a network governance question. The blockchain may settle in seconds. The network needs to define what “settled” means for the purposes of participant liability and consumer rights.

Return and reversal procedures. The conditions under which a payment can be returned. Who initiates the return. What the timeframes are. Who bears the cost of a return at each stage. NACHA resolved this through a structured return code framework built over decades. Stablecoin networks need an equivalent architecture, developed now — before the volume makes retrofitting impossible.

Dispute resolution. A defined process for resolving disputed transactions that does not require litigation as the first option. Dispute resolution frameworks in payments are not glamorous. They are not the subject of conference keynotes. But they are what every institutional participant in a payment network evaluates before committing volume to that network. The absence of a dispute resolution framework is a market access problem, not just a compliance problem.

Liability allocation. A clear framework for determining which party bears loss in the event of fraud, error, or network failure. The payments industry has learned the hard way — through BaaS compliance failures, through early ACH fraud events, through card network disputes — that ambiguous liability is the most dangerous condition a payment network can operate in. Regulatory examination follows ambiguous liability like a shadow.

Participant compliance obligations. Layered AML, sanctions screening, and KYC requirements that apply to each participant role, not just the issuer. The GENIUS Act defines issuer-level compliance. Network-level compliance obligations — what is required of every originator, every wallet provider, every off-ramp partner — are still undefined industry-wide.

It is worth noting that Circle has begun to address portions of this gap. The Circle Payments Network (CPN), announced in April 2025, operates under published CPN Rules that define participant eligibility, AML/CFT obligations, SLAs for uptime and transaction speed, and dispute resolution expectations. Circle also launched a Refund Protocol — a non-custodial smart contract enabling on-chain escrow, lockups, and mediated refunds for ERC-20 payments. While these represent meaningful first steps, CPN remains a single-issuer proprietary network rather than an industry-wide governance body analogous to NACHA. No neutral, multi-stakeholder operating rule framework yet exists for stablecoin payment networks as a class.

Even NACHA has recognized the convergence, publishing guidance noting that integrating stablecoins into payment flows does not change existing ACH operating rules but introduces new funding patterns, counterparties, and fraud vectors that require careful attention to existing return timelines and authorization warranties.

The Infrastructure Opportunity

Here is the strategic reality: the organizations that define the operational governance architecture for stablecoin payment networks will have significant influence over how this market develops. This is not a regulatory capture play. It is how every major payments infrastructure market in history has worked.

NACHA members shaped ACH operating rules. Card network members shaped dispute frameworks through decades of rule-change processes. The U.S. Faster Payments Council is shaping the policy and operational architecture for instant payments right now — with work groups on financial inclusion, digital assets, fraud, and operational considerations producing deliverables that will define how this market operates for the next decade.

The stablecoin payment network space needs the same kind of serious, practitioner-led governance development. Not as a lobbying exercise. As a market-building exercise. The organizations willing to do that work — to write the rulebook, to define the return codes, to build the dispute resolution framework — are the ones who will be trusted to operate the rails that matter.

7T World’s Position

We are building that governance architecture. Our network operating rules, return procedures, dispute resolution framework, and compliance obligations are part of the product — not an afterthought. The GENIUS Act is the floor. The operator’s rulebook is the building. At 7T World, we are building the building.

None of this requires re-inventing what the payments industry already knows. It requires applying what the payments industry already knows to a new set of rails. That is the work. That is the opportunity.

Anthony Serio is Co-Founder & COO of 7T World LLC, a FinCEN-registered MSB. He serves as Chair of the Financial Inclusion Work Group at the U.S. Faster Payments Council and as editorial reviewer across all FPC work group publications. He has 25+ years of experience in payments infrastructure, FX, and regulatory engagement.