FSB warns of “global crypto regulation gaps” as U.S. leads with GENIUS Act

Key Takeaways

What did the FSB warn about?

The FSB cautioned that fragmented regulation of crypto and stablecoins could pose risks to global financial stability as adoption accelerates.

Why does global coordination matter?

Despite frameworks like MiCA and MAS rules, only a handful of countries have complete oversight in place.

The Financial Stability Board (FSB) has warned that inconsistent global crypto regulation across major economies could pose risks to global financial stability.

This is despite countries like the U.S., EU, and Singapore moving ahead with new frameworks.

In its 16 October 2025 thematic review, the FSB said only a few jurisdictions have fully implemented its 2023 recommendations. The recommendation is for crypto-asset and stablecoin oversight. 

The findings highlight an uneven global response as digital assets move closer to mainstream finance.

U.S. takes lead with GENIUS Act

The report praised the United States for “material progress” following the passage of the GENIUS Act. The Act was signed into law by President Donald Trump in July.

The landmark legislation created the country’s first federal framework for stablecoins. It required 1:1 backing with the U.S. Treasurys and cash, strict redemption-at-par rules, and monthly reserve attestations.

The law aligns closely with the FSB’s global standards, particularly in licensing, supervision, and transparency. However, it remains U.S.-centric and lacks provisions for cross-border coordination.

Global patchwork regulation

Among other leading jurisdictions, the European Union’s MiCA framework, the U.K.’s stablecoin regime, and Singapore’s MAS rules were cited. 

Japan’s Payment Services Act was highlighted as an early model for comprehensive oversight. At the same time, Switzerland and Hong Kong were credited for strong licensing systems but incomplete DeFi coverage.

Also, the report underscores how global crypto regulation remains uneven despite progress in key jurisdictions. 

Additionally, only five jurisdictions have enacted full frameworks, with another 20 expected to align by the end of 2026.

Uneven global crypto regulation could rattle global markets

The FSB, which coordinates financial policy across the G20, IMF, and central banks, said fragmented oversight could undermine efforts to safeguard global stability as digital assets expand.

The warning comes amid a record $302 billion in global stablecoin supply and ongoing DeFi growth.

The report urges governments to accelerate licensing, harmonize reserve and redemption rules, and strengthen cross-border cooperation. Also, it calls 2026 a “critical deadline” for achieving global consistency. 

Furthermore, the FSB urged policymakers to close global crypto regulation gaps by 2026 to prevent systemic risks.