Crypto regulation uneven, creating financial stability risks
The Financial Stability Board assessed the implementation of its global regulatory framework for cryptoassets and stablecoins, revealing significant gaps and inconsistencies. Its October 2025 Thematic Review highlighted uneven progress across jurisdictions.
Global patchwork of crypto rules
The Financial Stability Board's global regulatory framework for cryptoasset activities, published in July 2023, is based on the principle of "same activity, same risk, same regulation".
Its October 2025 Thematic Review revealed significant gaps in implementation across jurisdictions.
As of August 2025, only 11 jurisdictions had finalised comprehensive regulatory frameworks for cryptoasset activities (CA recommendations), and a mere five for global stablecoin arrangements (GSC recommendations).
A critical gap is the lack of comprehensive coverage for CASP activities generating leverage and liquidity risks, such as cryptoasset borrowing, lending, and margin trading; only two jurisdictions cover these.
Supervision and enforcement also lag behind regulatory development.
This fragmented approach creates opportunities for regulatory arbitrage and complicates cross-border oversight of global crypto markets.
Fragmented oversight of digital assets
Regulation of global stablecoin arrangements (GSCs) similarly reflects a fragmented and inconsistent landscape.
Few jurisdictions have established comprehensive regulatory frameworks for GSCs, as existing mandates are often insufficient to address their unique risks.
Critical gaps include insufficient requirements for robust risk management, capital buffers, and recovery and resolution planning.
Significant challenges persist in obtaining necessary data to monitor financial stability risks, with authorities relying heavily on incomplete commercial data.
Reporting requirements for CASPs and stablecoin issuers lag behind licensing efforts.
Cross-border cooperation also remains fragmented and insufficient, hampered by divergent definitions and legal barriers like secrecy laws, constraining effective oversight of cross-border cryptoasset activities.
Urgent call for global alignment
The FSB's review underscores a critical failure in global regulatory coordination, leaving vast swathes of the crypto market vulnerable to arbitrage and systemic risks.
Despite clear recommendations, national interests and differing legal frameworks continue to impede a unified approach, perpetuating a fragmented landscape.
Without swift and comprehensive implementation, the promise of a resilient digital asset ecosystem remains elusive, while financial stability risks continue to fester.