The Financial Stability Board on 12 October sent G20 finance ministers and central bank governors a note on global stablecoin arrangements ahead of their 15 October meeting. Its central finding is uncomfortable for jurisdictions that have just finished writing stablecoin laws: the way those national regimes interact “remains uncertain or undefined in many jurisdictions”, including how they treat coins issued abroad. FSB Chair Andrew Bailey’s covering letter says cross-border cooperation on stablecoins “is still in its infancy”.
The market is large, dollar-based and not growing
The note puts the total market value of stablecoins at around $300 billion as of mid-2026, “essentially unchanged from a year earlier”, with 99% by value pegged to the US dollar. Stablecoins are still used mainly to move in and out of crypto-asset markets, though the FSB says they may serve as a store of value and support financial inclusion in some emerging market and developing economies.
A flat market changes how the note should be read, because the FSB is not reacting to rapid growth. Its concern is with the structure of the arrangements that already exist and with what happens when one of them fails across several legal systems at once.
Issuers may not know who holds their coins
The FSB contrasts a bank with a stablecoin issuer. A bank has an account relationship with known depositors and can manage withdrawals against its whole balance sheet. A global stablecoin issuer “may not know who holds its liabilities, where those holders are domiciled, or, in some cases, where redemption demand will materialise”. Tokens trade around the clock on secondary markets, while reserves and holders’ legal protections sit in specific jurisdictions and redemption runs on the hours of the markets where reserves are held.
In stress, the note says, round-the-clock trading can speed up a sell-off and push the coin off its peg if redemptions cannot keep pace. A run could spill into the traditional financial system through fire sales of reserve assets, deposit withdrawals to fund redemptions, payment dependencies in the real economy and foreign exchange markets where stablecoins are used for cross-border transactions.
Global stablecoins and national regulatory frameworks remain untested in severe stress and insolvency.
FSB, Global Stablecoin Arrangements: Cross-border vulnerabilities and financial stability monitoring, 12 October 2026
Multi-issuer coins are the hardest case
The note gives particular attention to “multi-issuer” arrangements, in which affiliated issuers in different jurisdictions share liability for a single coin but hold separate reserves. If holders can redeem with any issuer, regardless of where their tokens were issued, redemption demand could concentrate on one entity in the group. Rebalancing reserves across borders may face frictions in stress, and if holders’ locations cannot be established, it may be unclear which issuer owes what and under which insolvency law.
Multi-issuer structures are one way a single dollar coin can be offered through entities licensed in several markets, so the FSB’s concerns bear directly on licensing decisions in financial centres that have adopted stablecoin regimes. The FSB also says some issuers have chosen to locate in lightly regulated or unregulated jurisdictions, and that holding lower-quality reserves in places that have not implemented its 2023 recommendations can amplify liquidity and operational risks.
Supervisors depend on private data vendors
The second half of the note deals with data. Authorities rely mostly on private compilers of stablecoin data, whose proprietary methods vary in accuracy and transparency, creating “comparability and credibility risks”. Attributing activity to particular uses or countries is often impossible because public blockchains are pseudonymous. The FSB suggests three steps: develop financial stability metrics and identify data gaps; make better use of existing data through cross-border expertise and information sharing; and explore industry best practice for collecting data on- and off-chain.
For monitoring, the FSB recommends tracking the depth, liquidity and structure of secondary markets and the geographic distribution of holdings, redemptions and reserves, especially for multi-issuer coins.
Recovery and wind-down planning is next
The note sets out three areas for further work tied to its 2023 recommendations: better monitoring of cross-border vulnerabilities, support for implementation through cross-border cooperation and information sharing, and gathering information on how authorities plan for the distress or failure of a global stablecoin arrangement, with a focus on cross-border issues. The third item is new ground. It points toward something like resolution planning for stablecoin issuers that operate in several jurisdictions. Bailey’s letter calls greater consistency of outcomes with the 2023 recommendations “a necessary step” toward the safe use of stablecoins across borders.
What to watch
- 15 October 2026: G20 finance ministers and central bank governors meet in Bangkok.
- FSB work on recovery and failure planning for global stablecoin arrangements.
- Whether national regimes start to define how they treat foreign-issued stablecoins.
Primary sources
- FSB, Global Stablecoin Arrangements: Cross-border vulnerabilities and financial stability monitoring, 12 October 2026
- FSB, FSB Chair sets out FSB work on AI and stablecoins, 12 October 2026
- FSB, FSB Chair’s letter to G20 Finance Ministers and Central Bank Governors (PDF), 8 October 2026
Related: HKMA and Bank Negara Malaysia open a joint workstream on cross-border stablecoin use
Photo (cropped): Hamster28, Public domain via Wikimedia Commons
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