FSB Crypto: Global Regulatory Framework and Standards

FSB crypto refers to the global regulatory framework developed by the Financial Stability Board for crypto-asset activities, markets and global stablecoins. Finalised in July 2023, the FSB global regulatory framework for crypto-asset activities gives national authorities a common baseline for regulation, supervision and oversight while focusing primarily on risks to financial stability rather than functioning as a single binding international crypto law.

Key Takeaways

• The FSB recommendations for crypto-asset activities and markets contain nine high-level recommendations, while the framework for global stablecoin arrangements contains ten revised recommendations.

• The FSB's global regulatory framework follows the principle “same activity, same risk, same regulation,” meaning comparable financial activities should face comparable regulatory outcomes regardless of technology.

• Crypto-asset issuers and service providers should face requirements covering governance, risk management, asset safeguarding, data reporting, disclosures and conflicts of interest.

• Global stablecoins face additional expectations covering reserve quality, redemption rights, legal claims, stabilisation mechanisms and cross-border cooperation.

• The FSB's 2025 implementation review found progress across jurisdictions but significant gaps and inconsistencies, particularly in the regulation of global stablecoins.

How the FSB Crypto Framework Supports Financial Stability

The Financial Stability Board (FSB) monitors the global financial system and makes recommendations designed to reduce systemic risk. Its global regulatory framework for crypto-asset activities applies a technology-neutral approach to crypto assets, crypto-asset issuers, crypto asset service providers, and other asset activities and markets.

General crypto asset activities require comprehensive regulation, supervision and oversight proportionate to the financial stability risks they pose. Authorities are expected to supervise governance, operational arrangements, safeguarding of client assets, disclosures, data collection and comprehensive risk management frameworks.

The recommendations also target structural vulnerabilities such as leverage, liquidity problems, concentration, interconnectedness and significant volatility. The FSB's assessment of financial stability risks from crypto assets explains how failures involving major intermediaries can transmit stress through digital asset markets and, as connections with the traditional financial system, financial institutions and market infrastructures grow, potentially affect broader global financial stability.

FSB Global Regulatory Framework for Crypto Asset Activities and Markets

The July 2023 framework contains nine high-level recommendations covering regulatory powers, comprehensive supervision, cross-border cooperation, governance, risk management, data reporting, disclosures, interconnectedness and multifunction crypto businesses.

Authorities should ensure that crypto asset issuers and service providers maintain clear governance and effective risk controls. Firms combining several functions may require additional oversight because conflicts of interest, concentration and operational dependencies can increase financial stability risks.

The FSB's high-level recommendations for crypto-asset activities and markets are designed to promote consistent and effective regulation while reducing regulatory arbitrage between national regulatory regimes. They also encourage information sharing and international cooperation between national authorities, securities commissions, banking supervision bodies and other standard-setting bodies.

Global Stablecoins, Reserves and Cross-Border Financial Stability Risks

The FSB originally issued ten recommendations for global stablecoin arrangements in 2020 and published revised recommendations in 2023.

Under the FSB recommendations for global stablecoin arrangements, global stablecoin issuers should provide token holders with a robust legal claim and timely redemption rights. For reserve-backed arrangements, reserve assets should be conservative, high-quality and highly liquid, helping reduce the risk that rapid redemptions trigger forced asset sales or wider market stress.

Stablecoin oversight also covers governance, operational resilience, data access, recovery and resolution, disclosures and cross-border regulatory coordination. These controls become particularly important when global stablecoins operate across multiple jurisdictions or grow large enough to affect bank deposits, payments or monetary sovereignty.

Cross-Border Cooperation, Banking Supervision and International Organisations

The FSB does not regulate crypto companies directly. National authorities translate its recommendations into domestic regulatory frameworks.

Its work is coordinated with the International Monetary Fund, World Bank, Basel Committee on Banking Supervision, Bank for International Settlements committees, International Organization of Securities Commissions and Financial Action Task Force. The IMF-FSB synthesis paper on crypto-asset policies combines macroeconomic and regulatory approaches covering financial stability, macroeconomic stability and financial integrity.

This international coordination is intended to promote consistent supervisory approaches, improve cross-border cooperation and prevent crypto firms from exploiting differences between jurisdictions.

The broader policy direction is also reflected in the G20 commitment to clearer crypto and stablecoin regulatory frameworks, although FSB standards themselves are not directly binding national law.

What Changed After the FSB Consultative Report?

The FSB's 2022 consultative report preceded the final July 2023 framework. The FSB overview of consultation responses shows that the final recommendations strengthened requirements concerning client-asset safeguarding, conflicts of interest and cross-border cooperation following consultation and major crypto-market failures during 2022 and early 2023.

Implementation remains uneven. The FSB's October 2025 thematic review found that jurisdictions had made progress on regulation of crypto-asset activities, but fewer had fully developed frameworks for global stablecoins.

In its 2026 work programme, the FSB said it would continue monitoring crypto assets and examine vulnerabilities associated with multi-jurisdictional stablecoins.

Are Central Bank Digital Currencies Covered by FSB Crypto Rules?

No. The FSB global regulatory framework explicitly places central bank digital currencies outside the scope of its 2023 crypto-asset recommendations because CBDCs are digitalised central-bank liabilities rather than privately issued crypto assets.

Consumer protection, market integrity, AML/CFT, taxation and monetary policy are also not comprehensively covered by the FSB framework because other international organisations and national authorities have primary responsibility for many of those areas.

Conclusion

The FSB crypto framework provides an international baseline for regulating crypto-asset activities, service providers and global stablecoins with a focus on systemic and financial stability risks. Its central principle is “same activity, same risk, same regulation,” supported by governance, risk management, disclosure and cross-border oversight requirements. Implementation is progressing, but the FSB continues to identify regulatory fragmentation and gaps, especially for global stablecoins.

FAQ

What is the FSB crypto framework?

The FSB crypto framework is the Financial Stability Board's international regulatory baseline for crypto-asset activities, markets and global stablecoin arrangements. It was finalised on July 17, 2023.

How many recommendations are in the FSB framework for crypto assets?

There are nine high-level recommendations covering general crypto-asset activities and markets and ten recommendations covering global stablecoin arrangements.

Does the FSB directly regulate cryptocurrency exchanges?

No. The FSB develops international standards and supervisory recommendations. National authorities decide how those standards are implemented and enforced within their own jurisdictions.

Why does the FSB regulate global stablecoins more strictly?

Global stablecoins can create run risk, liquidity pressures and cross-border supervisory problems if they reach significant scale. Their use may also affect payments, bank deposits and monetary sovereignty.

What is the status of FSB crypto regulation in 2026?

Implementation remains incomplete. The FSB's 2025 peer review found significant gaps and inconsistencies, while its 2026 programme continues work on crypto monitoring and potential vulnerabilities from multi-jurisdictional stablecoins.