On 16 October 2025, the Financial Stability Board (FSB) published Thematic Peer Review on the FSB Global Regulatory Framework for Crypto-Asset Activities.

Background

The G20, during India’s Presidency in 2023, charged the FSB with coordinating the delivery of an effective and comprehensive regulatory framework for crypto-assets. In consultation with standard-setting bodies and international organisations, the FSB finalised in 2023 a global regulatory framework for crypto-asset activities based on the principle of ‘same activity, same risk, same regulation.’

This framework consists of high-level recommendations for the regulation, supervision and oversight of crypto-asset markets and activities (CA recommendations) and revised high-level recommendations for the regulation, supervision and oversight of global stablecoin arrangements (GSC recommendations).

The FSB in 2023 committed to conducting, by end-2025, a review of the implementation of the CA and GSC recommendations. The FSB was subsequently asked by South Africa’s 2025 G20 Presidency to deliver the review to the G20.

Key findings

This latest report reviews how FSB jurisdictions and some volunteering non-FSB jurisdictions have implemented both sets of recommendations.

The report’s key findings include:

  • While jurisdictions have made notable advancements toward implementing the CA recommendations, few have finalised their regulatory frameworks for the GSC recommendations.
  • For crypto-asset activities, gaps remain in addressing financial stability risks, particularly in the regulation of crypto-asset service providers. Comprehensive coverage of potentially higher risk activities, such as borrowing, lending, and margin trading, is often lacking.
  • The regulation of GSCs similarly reflects a fragmented and inconsistent landscape. Implementation progress has been slow, as relatively few jurisdictions have established comprehensive regulatory frameworks for GSCs.
  • While financial stability risks from crypto-assets appear limited at present, monitoring financial stability risks in crypto asset markets, including specific use cases and interconnections, is critical for authorities to fulfil their financial stability mandates.
  • Cross-border cooperation and coordination is fragmented, inconsistent, and insufficient to address the global nature of crypto-asset markets, due in part to the fact that implementation efforts are still ongoing.

Recommendations

Based on its findings the FSB sets out eight recommendations in the report. These recommendations are addressed to jurisdictions as they develop their regulatory regimes. The recommendations cover:

  • Implementation progress.
  • Comprehensiveness of regulatory frameworks.
  • Consistency.
  • Cross-border cooperation and coordination.

As regards cross-border cooperation and coordination, one recommendation provides that at the appropriate time, jurisdictions should conduct an assessment of the scale and nature of cross-border crypto-asset activities into and out of their jurisdictions.

Information note

Together with the International Organization of Securities Commissions (IOSCO), the FSB has issued an information note. The note accompanies the FSB’s report and a report issued by IOSCO following its thematic review of crypto and digital asset markets.