The Financial Stability Board (FSB) has released a thematic peer review highlighting significant gaps and inconsistencies in the implementation of its global regulatory framework for crypto-asset activities. The review, published on October 16, 2025, evaluates how jurisdictions have adopted the FSB’s 2023 recommendations concerning crypto-asset service providers, stablecoin arrangements, data reporting and collection, as well as cross-border cooperation.
According to the FSB, while there has been progress in regulating crypto-asset markets and related activities up to August 2025, the regulation of global stablecoin arrangements (GSCs) is lagging behind. The report notes that few jurisdictions have finalized their regulatory frameworks for GSCs and even where such frameworks exist, they are not fully aligned with FSB recommendations. This misalignment is particularly evident in areas relating to stablecoin arrangements and oversight of crypto-asset service providers.
“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.
The peer review urges member jurisdictions to prioritize full and consistent implementation of the framework to minimize risks associated with regulatory arbitrage. It also calls for enhanced cross-border cooperation to improve oversight of what it describes as an inherently global market.
In parallel with this release from the FSB, the International Organization of Securities Commissions (IOSCO) issued its own thematic review on implementing IOSCO’s Crypto and Digital Asset framework. A joint information note provides an overview comparing both organizations’ findings.
The FSB’s global regulatory framework was first published in July 2023. It consists of high-level recommendations designed to guide national authorities in regulating, supervising, and overseeing both general crypto-asset markets and specific stablecoin arrangements.
The current thematic review covers implementation progress by both FSB member jurisdictions and some non-member volunteers but does not assess how effective these regulatory approaches are in practice. The expert team responsible for this work was chaired by Arthur Yuen.
The FSB acts as a coordinator at an international level among national financial authorities and standard-setting bodies. Its mandate includes developing policies aimed at maintaining financial stability worldwide. The board brings together authorities from 24 countries along with international financial institutions, sector-specific groups of regulators, committees of central bank experts, and consults with about 70 additional jurisdictions through six Regional Consultative Groups.
Andrew Bailey serves as Chair of the FSB; its Secretariat is based in Basel, Switzerland at the Bank for International Settlements.