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1Fix the driver behind crashes, sound loss and screen glitches2Repair Windows errors before they cause bigger problems3Scan for outdated or missing drivers - takes under a minuteStablecoins do not follow one worldwide rulebook. The Financial Stability Board (FSB) sets out a common supervisory baseline, but national implementation remains uneven. The European Union’s Markets in Crypto-Assets Regulation (MiCA) is one concrete regional framework; it should not be treated as a template for every country. A token’s legal status and a business’s obligations depend on the instrument, the activities involved and the jurisdiction.
What counts as a stablecoin?
There is no universally agreed legal or regulatory definition. The FSB uses “stablecoin” for a cryptoasset that aims to maintain a stable value relative to a specified asset or a pool or basket of assets. The label describes an aim, not a guarantee that the token will hold its value.
The FSB also distinguishes the token from a “stablecoin arrangement”: the combination of functions and related activities that supports the token’s value objective. It uses “global stablecoin” for an arrangement with actual or potential reach across multiple jurisdictions and potential systemic importance. Regulators may therefore consider not just a token, but also its issuer, reserve arrangements, service providers and distribution. (FSB, 2023 recommendations.)
What is the international regulatory baseline?
The FSB’s revised 2023 recommendations are a high-level standard for national authorities, not a directly applicable global statute. They apply the principle “same activity, same risk, same regulation” and address financial-stability risks. They do not comprehensively cover every risk, and central bank digital currencies are outside their scope.
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For crypto-asset activities and markets, and separately for global stablecoin arrangements, the recommendations call for authorities to establish comprehensive, functional oversight proportionate to risk. For stablecoin arrangements, the practical elements include:
- Authority and accountability: Regulators should have the powers, tools and resources to oversee and enforce rules across an arrangement. The arrangement should disclose its governance framework and identify who is responsible for decisions and compliance.
- Coordination: Authorities should cooperate and share information within their own jurisdictions and across borders.
- Risk controls and data: Requirements should address operational resilience, cybersecurity and anti-money laundering and countering the financing of terrorism (AML/CFT). Arrangements should collect and safeguard data, report it appropriately and give supervisors access to it.
- Continuity planning: Arrangements should have recovery and resolution plans for dealing with serious stress or failure.
- Clear disclosures: Public information should address governance, conflicts of interest, redemption, stabilisation, operations, risks and financial condition.
- Claims, redemption and safeguards: Users should have a robust legal claim and timely redemption. For a token referencing a single fiat currency, the FSB calls for redemption at par into that fiat currency, alongside effective stabilisation and prudential requirements.
- Permission to operate: An arrangement should comply with applicable requirements before beginning operations in a jurisdiction, and adapt as those requirements change.
These recommendations do not replace domestic legislation or other sectoral standards. A country may implement them differently, impose additional rules or use different legal classifications.
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How far have jurisdictions implemented the standards?
The FSB’s October 2025 implementation review used information available as of August 2025. It found that work on crypto-asset regulation had advanced further than work on global stablecoin arrangements, where significant gaps and inconsistencies remained. The review covered implementation, reporting and disclosure frameworks, financial-stability monitoring and cross-border cooperation; it did not assess whether jurisdictions’ approaches were effective.
A BIS/Financial Stability Institute summary published in 2026 reported the following implementation stages for stablecoin recommendations, based on the August 2025 status snapshot:
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| Stage | Jurisdictions |
|---|---|
| No framework in place | 11 |
| Partial regulations | 3 |
| Plans under public discussion | 6 |
| Proposed framework, not yet finished | 4 |
| Finalised framework | 5 |
The same summary said 11 jurisdictions had finalised comprehensive frameworks for crypto-asset activities, compared with five that had finalised stablecoin frameworks. These counts describe implementation stages, not compliance with each recommendation, the strength of a framework or its effectiveness. The FSB warned that uneven implementation can create opportunities for regulatory arbitrage and make oversight of a global market more difficult.
What does the EU’s MiCA framework do?
The EU’s Markets in Crypto-Assets Regulation, Regulation (EU) 2023/1114, distinguishes between asset-referenced tokens and e-money tokens. It sets requirements concerning issuers, authorisation, disclosure and prudential safeguards, with heightened treatment for tokens classified as significant. The relevant category matters: the framework is not a single interchangeable set of rules for every token marketed as stable.
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MiCA’s rules for asset-referenced tokens and e-money tokens have applied since 30 June 2024. The wider regulation has applied since 30 December 2024. The operative law also includes transitional and delegated provisions, so those dates alone do not establish whether a particular issuer or token is authorised or compliant. Check the consolidated EU text and current regulator guidance for a specific case.
MiCA is an EU example, not a description of global law. Other jurisdictions may classify tokens differently or regulate issuers and service providers under other laws. A sound comparison needs to examine the legal category and scope, permitted issuers and authorisation, reserve eligibility and custody, capital and liquidity, redemption rights and timing, disclosures and governance, supervision and enforcement, AML/CFT duties, cross-border access and any transition arrangements.
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How do AML/CFT rules apply across borders?
FATF’s 2024 targeted update explains that stablecoin issuers and intermediaries may qualify as virtual-asset service providers (VASPs), or may have AML/CFT obligations on another basis, depending on their functions and the applicable law. It also notes that, depending on a token’s exact nature, it may be treated under FATF standards as either a virtual asset or a traditional financial asset. The marketing label alone does not settle classification.
FATF highlights illicit-finance risks, offshore services, international cooperation and implementation of the Travel Rule. It also reports that some stablecoin arrangements can freeze or burn tokens through programmable features, including in response to law-enforcement requests or targeted financial sanctions obligations. These capabilities and duties are arrangement- and jurisdiction-dependent; they should not be assumed to exist for every token.
Separately, FATF reported in 2024 that 42 of 147 survey respondents—29%—had not conducted a virtual-asset risk assessment. That finding concerns virtual assets generally, not stablecoins alone.
What should a consumer check before relying on a stablecoin?
A global overview cannot establish whether a particular token or provider is authorised where you live. For a decision involving a specific product, identify the jurisdiction and the relevant issuer, intermediary and activities, then check current official rules and disclosures. Useful questions include:
- How does the relevant regulator classify the token and the activities around it?
- Who is responsible for issuing, managing and redeeming it, and what authorisations apply to those entities?
- What assets support the arrangement, how are they safeguarded, and what information is disclosed about reserves and financial condition?
- What legal claim does a holder have, who must honour it, and what are the stated redemption terms and timing?
- What governance, conflict-of-interest, operational-resilience and recovery arrangements are disclosed?
- Which AML/CFT, sanctions and cross-border requirements apply to the issuer and service providers?
- Are there current transition provisions, delegated rules or regulator guidance that affect the product’s status?
These checks help frame the questions; they do not substitute for confirming the current law in the relevant jurisdiction. Rules, transition periods and supervisory guidance can change quickly. The global implementation figures above are an August 2025 snapshot, not a live count for October 2026.
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