- Peer review reveals significant gaps and inconsistencies in implementing the FSB Global Framework for Crypto-Asset Activities, that could pose risks to financial stability and to the development of a resilient digital asset ecosystem.
- Jurisdictions have made progress in implementing recommendations on crypto-asset markets and activities, but regulation of global stablecoin arrangements is lagging.
- FSB urges jurisdictions to prioritise full and consistent implementation, so as to minimise the risk of regulatory arbitrage and to improve the oversight of an inherently global crypto-asset market.
The Financial Stability Board (FSB) today published a Thematic Peer Review on the FSB Global Regulatory Framework for Crypto-asset Activities. The report describes the findings of a peer review to evaluate progress in implementing the FSB’s 2023 global framework, including recommendations on crypto-asset service providers and stablecoin arrangements, data reporting and collection, and cross-border cooperation and coordination.
Crypto-asset markets and regulation are changing rapidly. The review shows that, as of August 2025, jurisdictions have made progress in regulating crypto-asset activities and to a lesser extent global stablecoin arrangements (GSCs). However, it also reveals significant gaps and inconsistencies that could pose risks to financial stability and to the development of a resilient digital asset ecosystem.
While jurisdictions have made notable advancements toward implementing the recommendations on crypto-asset markets and activities, few have finalised their regulatory frameworks for GSCs. Even where regulatory frameworks are finalised, full alignment with the FSB recommendations remains limited, especially with regard to stablecoin arrangements and crypto-asset service providers. Moreover, jurisdictions may continue to update, modify, or refine their frameworks.
The review calls on the FSB and its member jurisdictions to prioritise work in this area and to do more to reach full and consistent implementation. Specifically, it puts forward some recommendations to address outstanding issues in terms of implementation progress, comprehensiveness and consistency, and cross-border cooperation and coordination. “Implementation progress remains incomplete, uneven and inconsistent. This creates opportunities for regulatory arbitrage and complicates oversight of the inherently global and evolving crypto-asset market”, said Arthur Yuen, Deputy Chief Executive of the Hong Kong Monetary Authority and chair of the team that prepared the report.
Today, the International Organization of Securities Commissions (IOSCO) also released the results of a thematic review on the implementation of IOSCO’s Crypto and Digital Asset framework. A joint information note provides an overview of the scope and the findings of the FSB and IOSCO’s complementary reports.
Background
The FSB published its global regulatory framework for crypto-asset activities in July 2023. This framework consists of high-level recommendations for the regulation, supervision and oversight of crypto-asset markets and activities and revised high-level recommendations for the regulation, supervision and oversight of global stablecoin arrangements.
The Thematic Review on the FSB Global Regulatory Framework for Crypto-asset Activities evaluates implementation progress by FSB jurisdictions and some volunteering non-FSB jurisdictions but does not assess the effectiveness of the regulatory approaches undertaken by jurisdictions. The review was prepared by a team of experts from FSB member institutions and chaired by Arthur Yuen, Deputy Chief Executive of the Hong Kong Monetary Authority.
The FSB coordinates at the international level the work of national financial authorities and international standard-setting bodies and develops and promotes the implementation of effective regulatory, supervisory, and other financial sector policies in the interest of financial stability. It brings together national authorities responsible for financial stability in 24 countries and jurisdictions, international financial institutions, sector-specific international groupings of regulators and supervisors, and committees of central bank experts. The FSB also conducts outreach with approximately 70 other jurisdictions through its six Regional Consultative Groups.
The FSB is chaired by Andrew Bailey, Governor of the Bank of England. The FSB Secretariat is located in Basel, Switzerland and hosted by the Bank for International Settlements.
