Regulation · Regime · New York · Regulator rule or rulebook · New York State Department of Financial Services
New York virtual currency regime (BitLicense, 23 NYCRR Part 200, and limited purpose trust charters)Updated 18 Oct 2026
New York's licensing regime for virtual currency business, including transmission, custody, exchange and issuing a virtual currency. Firms need a BitLicense or a limited purpose trust charter under the Banking Law; the charter route also allows fiduciary activity and money transmission. Most US-regulated dollar stablecoins (Paxos, Gemini, Ripple and, from 2026, Circle) have been issued through NYDFS-chartered trust companies under its 2022 stablecoin guidance. A proposed Part 202 would align the regime with the GENIUS Act.
In force · effective 24 Jun 2015
Key points
- A licence is required for virtual currency transmission, custody for others, buying and selling as a business, exchange services, and controlling, administering or issuing a virtual currency.[1]
- A limited purpose trust company can carry on virtual currency business without a BitLicense with the Superintendent's approval, and may act as a fiduciary.[1]
- NYDFS-supervised dollar stablecoins must be fully backed at the end of each business day, redeemable at par in a timely manner, backed by segregated short-dated Treasuries, Treasury reverse repo or bank deposits, and attested monthly by an independent CPA.[2]
What it covers
Timeline
- 24 Jun 2015 · In forceBitLicense regulation takes effect.[1]
- 8 Jun 2022 · AmendedGuidance on the issuance of US dollar-backed stablecoins.[2]
- Jul 2026 · ConsultationProposed Part 202 on authorised payment stablecoin issuers published.[3]
- 21 Sep 2026 · Consultation closedComments on proposed Part 202 close (published in the State Register on 22 July).[4]
Instruments
- NYDFS proposed 23 NYCRR Part 202: Authorized Payment Stablecoin IssuersProposed rule · Consultation closed
- NYDFS Industry Letter: Guidance on the Issuance of U.S. Dollar-Backed Stablecoins (8 June 2022)Guidance · In force · 8 Jun 2022
Permissions granted under it
- NYDFS limited purpose trust charter: Circle Internet Trust Company (Circle New York Trust)Circle
- NYDFS limited purpose trust charter: Gemini Trust CompanyGemini
- NYDFS limited purpose trust charter: Standard Custody & Trust Company (Ripple)Ripple
- NYDFS limited purpose trust charter: WisdomTree Digital Trust CompanyWisdomTree
Deployments operating under it
None recorded with a source yet.
Likely relevant to
| Deployment | Status | Assets | Use cases | Last reviewed |
|---|---|---|---|---|
| Gemini Dollar (GUSD)Updated 7 Nov 2026 Gemini | Live (limited) | Reviewed 13d ago | ||
| Pax Dollar (USDP)Updated 7 Nov 2026 Paxos tokenisation platform | Live (limited) | Reviewed 25d ago | ||
| PayPal USD (PYUSD)Updated 7 Nov 2026 Paxos tokenisation platform | Live (scaled) | Reviewed 13d ago | ||
| Ripple USD (RLUSD)Updated 7 Nov 2026 Ripple | Live (scaled) | Reviewed 13d ago |
Sources
- [1]Virtual Currency Business Licensing — New York State Department of Financial Services. Accessed 12 Oct 2026.A
- [2]Superintendent Harris Announces New DFS Regulatory Guidance on the Issuance of U.S. Dollar-Backed Stablecoins — New York State Department of Financial Services, 8 Jun 2022. Accessed 12 Oct 2026.A
- [3]Proposed new 23 NYCRR 202, Authorized Payment Stablecoin Issuers — New York State Department of Financial Services, Jul 2026. Accessed 12 Oct 2026.A
- [4]NYDFS files formal proposal to align stablecoin oversight with GENIUS Act — Orrick (InfoBytes), 24 Jul 2026. Accessed 18 Oct 2026.B