The Financial Stability Board (FSB) conducted this thematic peer review to assess how jurisdictions have implemented its 2023 Global Regulatory Framework for Crypto-asset Activities, which includes recommendations for crypto-assets (CA) and global stablecoins (GSC). The review evaluates regulatory frameworks, data-reporting systems, and cross-border cooperation across FSB member and selected non-member jurisdictions.
Key Findings
The FSB finds that while many jurisdictions have advanced toward regulating crypto-assets, implementation remains fragmented and incomplete, particularly for stablecoins. Out of all reviewed jurisdictions, only 11 have finalised frameworks for crypto-assets and 5 for global stablecoins. Even where frameworks exist, few are fully aligned with FSB recommendations, resulting in regulatory gaps, inconsistent supervision, and risks of regulatory arbitrage.
For crypto-asset activities, several jurisdictions now regulate crypto-asset service providers (CASPs), but oversight of high-risk activities—such as borrowing, lending, margin trading, and proprietary trading—is often missing. This leaves major financial-stability risks unaddressed. Moreover, supervisory and enforcement capabilities lag behind legal frameworks. Many authorities still lack comprehensive data-reporting structures, limiting their ability to monitor exposures, contagion channels, and systemic vulnerabilities.
Regarding global stablecoins, implementation is even slower. Few jurisdictions have bespoke laws for stablecoins as distinct payment instruments. Critical deficiencies remain in liquidity risk management, capital and reserve requirements, redemption rights, and recovery or insolvency planning. Discrepancies in redemption timing, custody rules, and collateralisation frameworks complicate oversight of cross-border stablecoin issuers and raise coordination challenges.
Cross-border cooperation is the weakest area. Despite the global nature of crypto markets, coordination between jurisdictions is limited and inconsistent. Existing mechanisms mostly support enforcement rather than supervisory cooperation or financial-stability monitoring. Divergent definitions of crypto-assets, legal secrecy barriers, and fragmented responsibilities across domestic regulators further hamper effective information sharing.
Recommendations
The FSB outlines eight key actions:
- Accelerate full implementation of the FSB crypto framework and prioritise closing gaps.
- Promote alignment through cooperation between the FSB, standard-setting bodies, and non-member jurisdictions.
- Conduct comprehensive gap analyses of CASP frameworks to address financial-stability risks.
- Do the same for GSC frameworks, focusing on liquidity, capital, redemption, and resolution.
- Improve data infrastructure for monitoring risks between crypto and traditional finance.
- Enhance consistency through capacity building and sharing best practices on stablecoin regulation.
- Assess and strengthen cross-border cooperation mechanisms and create bilateral/multilateral arrangements.
- The FSB and SSBs should develop best-practice solutions for global coordination on crypto-asset oversight.
Overall, the report stresses that uneven progress and regulatory divergence could endanger financial stability as crypto markets expand toward USD 4 trillion in market value. It urges jurisdictions to act swiftly to ensure consistent, comprehensive, and globally coordinated supervision.
Table — Overall Implementation Status (as of Aug 2025)
| Stage of Progress | Definition | CA Recommendations – Jurisdictions | Count | GSC Recommendations – Jurisdictions | Count |
| 1 – No framework | No regulatory framework in place | China¹, India, Kazakhstan, Lebanon, Mexico, Saudi Arabia¹ | 6 | Argentina, Chile, China¹, India, Indonesia, Kazakhstan, Lebanon, Mexico, Saudi Arabia¹, South Africa, Türkiye | 11 |
| 2 – Partial regulation | Limited or AML/CFT-only regulation | Argentina, Canada, South Africa | 3 | Canada, Philippines, Thailand | 3 |
| 3 – Plans under discussion | Public consultation ongoing | Brazil, Korea³, Switzerland³, Uruguay | 4 | Australia³, Brazil, Korea, Nigeria, Switzerland³, Uruguay | 6 |
| 4 – Framework proposed | Draft rules or bills not yet enacted | Armenia, Australia³, Philippines, UK | 4 | Armenia, Singapore³, UK, US | 4 |
| 5 – Framework finalised | Comprehensive legal and supervisory system in force | Bahamas, Bermuda, Chile, EU, Hong Kong, Indonesia, Japan, Nigeria, Singapore, Thailand, Türkiye | 11 | Bahamas, Bermuda, EU, Hong Kong, Japan | 5 |
¹ Crypto-asset activities prohibited. ³ Partial regulations also in place.
In essence: The FSB finds global regulatory progress on crypto-assets and stablecoins advancing but inconsistent. To prevent fragmentation and systemic risk, it calls for rapid, aligned, and data-driven implementation of its 2023 framework through stronger cross-border cooperation.
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