The Financial Stability Board and IOSCO have published reports on the regulation of cryptoassets. The reports provide insight into regulatory regimes for cryptoassets in dozens of jurisdictions. Their findings suggest potential areas for future work on crypto policy.
Review of progress made so far
In 2023, the FSB and IOSCO have recommended ways to regulate cryptoassets and stablecoins. The aim was to promote greater regulatory consistency between different jurisdictions.
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The FSB framework addresses risks related to financial stability. Its high-level recommendations cover (1) crypto-asset markets and activities, and (2) global stablecoin agreements.
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IOSCO’s recommendations address investor protection and market integrity concerns in the cryptocurrency and digital asset markets. They cover activities carried out by crypto-asset service providers, including offering, settlement, marketing and distribution to retail investors.
In 2025, the FSB and IOSCO conducted thematic reviews on how their member jurisdictions implemented their recommendations and have now published reports containing their findings.
Key takeaways
Both the FSB report and the IOSCO report note that members have made progress in creating crypto-asset regimes. However, implementation remains fragmented and inconsistent.
The key issues revolve around:
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Risks related to CASP: The FSB highlights gaps in the management of financial stability risks, particularly with regard to the regulation of crypto-asset service providers (CASP). According to the FSB, comprehensive reporting frameworks for PSAPs will help authorities effectively combat these risks.
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Stablecoin Regulations: The FSB notes that progress in implementing regimes for global stablecoin agreements has been slow, with only a few having developed comprehensive frameworks. Although efforts are increasing, most do not fully address its recommendations for global stablecoins. Key gaps include risk management practices, capital buffers, and recovery and resolution planning.
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Multi-issuer stablecoins: The FSB reports growing concern among participating jurisdictions regarding multi-issuer stablecoins, i.e. stablecoins issued in multiple jurisdictions under the same brand, which raise particular challenges that may not be adequately addressed by applicable regulations. This could pose takeover risks and other problems.
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Higher risk activities: Both reports highlight the risks arising from certain business models, such as borrowing and lending crypto-assets. IOSCO indicates that jurisdictions are considering introducing measures to address the risks of conflicts of interest arising from these activities. The FSB finds that only two jurisdictions comprehensively regulate crypto borrowing and lending.
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Cross-border cooperation: IOSCO and the FSB call for more coordination to facilitate multilateral information sharing and better identify and monitor risks to financial stability. IOSCO observes that this cooperation must go beyond enforcement procedures.
Based on its findings, the FSB also offers eight recommendations for jurisdictions to consider when developing their crypto frameworks. These include:
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prioritize the full implementation of the FSB cryptography framework,
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introduce prudential reporting requirements for CASPs,
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set rules on liquidity risk management, capital buffers, stress testing, user buy-in, custody and asset reserve eligibility, as well as recovery and resolution planning,
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analyze vulnerabilities arising from global stablecoins with multi-jurisdictional issuance, and
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encourage cross-border cooperation and information sharing.
Next steps
IOSCO and the FSB expect member jurisdictions to increase their regulatory activity relating to crypto-assets. The reports are likely to influence policymaking where crypto regimes are being developed (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 jointly issued by EU and third-country entities.
