FSB and IOSCO review crypto regulation around the world

The Financial Stability Board and IOSCO have issued reports on the regulation of cryptoassets. The reports provide a snapshot on cryptoasset regulatory regimes in dozens of jurisdictions. Their findings hint at potential areas for future crypto policy work.

Reviewing progress so far

In 2023 the FSB and IOSCO recommended ways to regulate cryptoassets and stablecoins. The aim was to promote greater regulatory consistency between different jurisdictions.

• The FSB framework addresses financial stability risks. Its high-level recommendations cover (1) cryptoasset markets and activities, and (2) global stablecoin arrangements.

• IOSCO’s recommendations address investor protection and market integrity concerns within crypto and digital asset markets. They cover activities performed by cryptoasset service providers including offering, settlement, marketing and distribution to retail investors.

In 2025, the FSB and IOSCO ran thematic reviews of how their member jurisdictions have implemented their recommendations and have now published reports with their findings.

Key takeaways

Both the FSB report and the IOSCO report note that members have made some progress on creating cryptoasset regimes. However, implementation remains fragmented and inconsistent.

Key issues revolve around:

• CASP-related risks: The FSB highlights gaps in addressing financial stability risks, especially regarding the regulation of crypto-asset service providers (CASPs). According to the FSB, comprehensive reporting frameworks for CASPs will help how authorities can effectively tackle these risks.

• Stablecoin regulation: The FSB notes that progress on implementing regimes for global stablecoin arrangements has been slow, with only a few having developed comprehensive frameworks. Although efforts are increasing, most do not completely meet its recommendations for global stablecoins. Key gaps include risk management practices, capital buffers, and recovery and resolution planning.

• Multi-issuer stablecoins: The FSB reports growing concern among participating jurisdictions about multi-issuer stablecoins, i.e. stablecoins issued in multiple jurisdictions under the same branding, which raise particular challenges that may not be adequately catered for under applicable regulation. These could pose redemption risks and other issues.

• Higher-risk activities: Both reports highlight risks emerging from certain business models, such as cryptoasset borrowing and lending. IOSCO says that jurisdictions are considering introducing measures to address conflicts of interest risks emerging from these activities. The FSB finds that only two jurisdictions comprehensively regulate crypto borrowing and lending.

• Cross-border cooperation: Both IOSCO and the FSB call for more coordination to facilitate the multilateral sharing of information and better identify and monitor financial stability risks. IOSCO observes that this cooperation needs to go beyond enforcement proceedings.

Based on its findings, the FSB also provides eight recommendations for jurisdictions to consider when developing their crypto frameworks. These include:

• prioritising full implementation of the FSB crypto framework,

• introducing supervisory reporting requirements for CASPs,

• setting rules on liquidity risk management, capital buffers, stress testing, user redemption, custody of and eligibility for the reserve of assets, and recovery and resolution planning,

• analysing vulnerabilities stemming from global stablecoins with multi-jurisdictional issuances, and

• encouraging cross-border cooperation and information-sharing.

Next steps

IOSCO and the FSB expect member jurisdictions to step up their regulatory activity in relation to cryptoassets. The reports are likely to influence policymaking where crypto regimes are under development (see for example: UK cryptoasset regulation: Where are we now?), as well as future changes to existing regulatory frameworks. For example, the FSB’s commentary on multi-issuer stablecoins echoes similar concerns raised by the European Systemic Risk Board’s report on the financial stability risks posed by stablecoins that are jointly issued by EU and non-EU entities.