Briefing
The Financial Stability Board (FSB) and the International Organization of Securities Commissions (IOSCO) published a joint Thematic Peer Review, asserting that national jurisdictions exhibit significant gaps and inconsistencies in implementing the 2023 Global Regulatory Framework for crypto-asset activities. This finding immediately elevates the systemic risk profile for global firms by confirming the persistence of regulatory arbitrage opportunities and complicating effective cross-border supervision of inherently global digital asset markets. The report specifically highlights that few jurisdictions have finalized comprehensive regulatory frameworks for Global Stablecoin (GSC) arrangements, underscoring a critical vulnerability in the financial stability mandate that must be addressed by the end-2025 review commitment.
Context
Prior to this review, the global regulatory environment operated under the expectation that the 2023 FSB and IOSCO recommendations → rooted in the principle of “same activity, same risk, same regulation” → were being systematically transposed into national law. The prevailing compliance challenge centered on interpreting these high-level principles for practical application, particularly concerning the classification of crypto-assets and the prudential requirements for Crypto-Asset Service Providers (CASPs). The assumption of consistent, albeit gradual, global convergence created a false sense of security for multi-jurisdictional entities, which now face a confirmed reality of fragmented legal landscapes.
Analysis
This report directly impacts the architectural design of a firm’s global compliance framework by confirming that a unified, technology-neutral approach is not yet viable across all G20 jurisdictions. The primary consequence is the immediate need to escalate risk mitigation controls in jurisdictions with incomplete stablecoin or CASP oversight, as regulatory arbitrage opportunities are now explicitly flagged by global standard-setters. Regulated entities must now allocate additional resources to monitor the divergence in national rules, particularly concerning capital requirements, custody segregation, and market conduct standards. This fragmented implementation necessitates a more localized, granular compliance strategy to avoid inadvertent violations in jurisdictions where frameworks remain unfinalized or inconsistent with the FSB’s high-level recommendations.
Parameters
- Implementation Status → Few jurisdictions have finalized regulatory frameworks for Global Stablecoins.
- Core Regulatory Principle → Same activity, same risk, same regulation.
- Key Finding → Significant gaps and inconsistencies in national implementation.
- Data Cutoff Date → Information reviewed by the FSB was current as of August 2025.
Outlook
The FSB and IOSCO will prioritize a concerted effort to push national authorities to close the identified gaps, particularly the finalization of Global Stablecoin frameworks, which are crucial for systemic stability. This review sets a clear precedent → international standard-setting bodies will not tolerate slow or inconsistent national implementation, and the next phase will involve heightened scrutiny and pressure on jurisdictions lagging in their legislative process. The industry should anticipate new, targeted guidance from the FSB and IOSCO focused on enhancing cross-border cooperation and mandating stricter data reporting standards to combat the confirmed risks of regulatory arbitrage.
Verdict
The global digital asset regulatory framework is now officially characterized by a dangerous and strategically significant fragmentation, demanding immediate, localized compliance fortification by all multi-jurisdictional firms.
