Patchwork stablecoin rules đŸ§¶

Stablecoin rules lack cohesion across jurisdictions, says the FSB.

November 24, 2025

Hey all, Liam here. 

The Financial Stability Board is making comprehensive global regulations around stablecoins a top priority for next year. 

That’s because the FSB, whose members include the world’s largest economies, suggested last week that rules governing crypto-based fiat currencies were incomplete worldwide. 

As such, the $302 billion market remains a risky venture until those gaps are closed.

“Divergences in regulatory and prudential frameworks across jurisdictions could add an additional layer of complexity and potential risk,” Andrew Bailey, the Governor of the Bank of England and Chair of the FSB, wrote. “It will be equally important to consider how stablecoins can operate effectively and safely across borders.”

After sweeping crypto regulations in Europe, called MiCA, came into effect in December 2024, the US has also followed suit with its own legislation to regulate stablecoins under the Genius Act.

While that US bill has yet to be fully implemented, the two economies have sparked a revival among other jurisdictions to review their position on crypto. 

Canada, previously quite cold on the future of digital assets, has also made stablecoins a key part of its budget review. Likewise, the UK is playing catch-up on crypto rules, too. 

And now that the FSB has signalled that harmonisation of these rules will be part of the organisation’s work programme for the year ahead, we should expect even more countries to follow suit. 

For key areas

When it comes to how states should consider regulating stablecoins, the FSB highlighted four key areas in October that lack cohesion amid the ubiquitous rise of this type of digital asset. 

First, crypto frameworks need to establish clear rules for asset recovery during insolvency proceedings. Should a stablecoin depeg or its issuer go bankrupt, who should get paid first, exactly?

Second, some active frameworks, said the FSB, lack “robust” requirements for liquidity risk management in the case of a run event with mass redemptions. Third, there is a lack of consistency across regimes about what types of assets should back stablecoins.  And fourth, the difference between custody and redemption requirements lacks cohesion. 

Put all together, the FSB sees this as a major problem for an emerging global payments tool. 

And it's for these reasons that the niche has become a key priority for the advisory group. 

“For payments, this is essential to ensure public trust, and it is important that authorities carefully consider how frameworks are designed to ensure they are effective, consistent, and supportive of safe innovation,” Bailey writes.  

ICYMI

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