International Standards Synthesis

Last Updated: June 2026

1. The International Standards Landscape

Six international bodies collectively define the global regulatory expectations for stablecoins. Each operates under a distinct mandate, addresses a specific set of risks, and targets a different set of regulated entities. No single body provides a complete framework; the international stablecoin regulatory architecture is the composite of all six.

1.1 The Six Bodies and Their Mandates

Financial Stability Board (FSB) -- The coordinating body and primary standard-setter for financial stability risks from global stablecoin (GSC) arrangements. Published 10 High-level Recommendations (July 2023, revised from October 2020) endorsed by the G20. Operates on the principle of "same activity, same risk, same regulation." Recommendations are non-binding but carry strong political weight. The FSB's October 2025 Thematic Peer Review found significant implementation gaps and inconsistencies across 28 assessed jurisdictions.

Financial Action Task Force (FATF) -- The exclusive international standard-setter for AML/CFT requirements applicable to virtual assets (VAs) and virtual asset service providers (VASPs). FATF Recommendation 15 and the Interpretive Note (INR.15) require countries to license/register VASPs and apply the full suite of preventive measures. Recommendation 16 (the "Travel Rule") requires originator/beneficiary information to accompany VA transfers above USD/EUR 1,000. The FATF has the strongest enforcement mechanism of any body through mutual evaluations and grey/black listing. As of the 2025 targeted update, 73% of jurisdictions (85 of 117) have passed Travel Rule legislation, but 59% have not yet enforced it.

International Organization of Securities Commissions (IOSCO) -- The global standard-setter for securities market regulation. Published 18 Policy Recommendations for Crypto and Digital Asset Markets (FR11/2023, November 2023) addressing market conduct, conflicts of interest, custody, market surveillance, and retail investor protection for crypto-asset service providers (CASPs). Provides stablecoin-specific disclosure guidance under Recommendation 6. The October 2025 implementation review found significant progress among members.

Committee on Payments and Market Infrastructures (CPMI-IOSCO) -- The global standard-setter for payment, clearing, and settlement systems. Published guidance on applying the Principles for Financial Market Infrastructures (PFMI) to systemically important stablecoin arrangements (July 2022, d206). Provides the most detailed international guidance on settlement finality (Principle 8) and money settlement quality (Principle 9) for stablecoins.

International Monetary Fund (IMF) -- Provides macroeconomic and macro-financial policy analysis rather than specific regulatory standards. Published "Elements of Effective Policies for Crypto Assets" (February 2023, 9 elements) addressing monetary sovereignty, capital flow management, fiscal risks, and legal certainty. The IMF's unique contribution is its focus on developing economy risks -- currency substitution, monetary policy transmission impairment, and circumvention of capital flow measures. Joint IMF-FSB Synthesis Paper published September 2023.

Basel Committee on Banking Supervision (BCBS) -- The global standard-setter for prudential regulation of banks. Published the crypto-asset exposure standard d545 (December 2022), creating a two-group classification system. Group 1b covers compliant stablecoins meeting four classification conditions; Group 2b imposes a 1,250% risk weight (effective 100% capital charge) on non-compliant exposures. Implementation date extended to 1 January 2026. Banks' total Group 2 exposure capped at 2% of Tier 1 capital.

1.2 Architectural Relationship

The six bodies form a layered architecture:

• Coordination layer: FSB (high-level principles, G20 mandate) + IMF (macroeconomic framework, 190-country surveillance)
• Sector-specific standard layer: FATF (AML/CFT), IOSCO (market conduct/investor protection), CPMI-IOSCO (payment system infrastructure), Basel Committee (bank prudential)
• Synthesis layer: IMF-FSB Synthesis Paper (September 2023) integrates all standards into a unified G20 roadmap

The FSB explicitly defers to sectoral bodies: its Recommendation 5 references FATF standards for AML/CFT; its Recommendation 2 references IOSCO for market integrity and CPMI-IOSCO for payment systems; and its Recommendation 9 references BCBS standards for prudential requirements. The IMF's Element 5 similarly directs regulators to all five standard-setting bodies for detailed rules.

A seventh body, the OECD, sits outside the six-body prudential/AML architecture but creates a parallel tax-transparency obligation through the Crypto-Asset Reporting Framework (CARF). CARF is not a stablecoin-specific standard, but it captures stablecoin trades and transfers within scope and now drives a distinct implementation timeline across the same jurisdictions. Section 2.1 maps national FATF/Travel Rule/CARF status; the OECD's CARF milestones appear in the timeline in Section 6.

2. Coverage Matrix: Regulatory Dimension by International Body

The following matrix maps which international body provides substantive standards for each major regulatory dimension of stablecoin regulation. "Primary" indicates the body is the lead standard-setter; "Secondary" indicates it provides complementary guidance; "Reference" indicates it cross-references another body's standard; blank indicates no substantive coverage.

Note on the "Tax Transparency / Reporting" row: none of the six core bodies sets a substantive standard here -- this dimension is governed by the OECD's CARF, mapped per jurisdiction in Section 2.1.

Key Observations from the Matrix

1. Reserve requirements receive the most overlapping coverage: FSB (high-level), CPMI-IOSCO (payment system quality), Basel (bank prudential), and IOSCO (disclosure). This reflects the centrality of reserve integrity to stablecoin stability.

2. AML/CFT is exclusively FATF territory at the international level. All other bodies defer to FATF, creating a single point of authority with the strongest enforcement mechanism.

3. Monetary sovereignty, capital flow management, and fiscal/tax are exclusively IMF territory. No other body addresses these dimensions, which are most critical for developing economies.

4. Recovery and resolution is covered only by the FSB (Recommendation 7). This is a notable gap -- there is no binding international framework for stablecoin resolution, and the FSB's October 2025 peer review found that most frameworks lack comprehensive recovery and resolution planning requirements.

5. Market integrity and custody are exclusively IOSCO territory at the international level, though national frameworks often address these through existing securities or payment services law.

2.1 National FATF, Travel Rule, and CARF Status

The matrix below mirrors the per-jurisdiction AML/CFT-and-tax-transparency dimension (FATF alignment, Travel Rule status, and OECD CARF adoption) across the 18 jurisdictions in this research series. It is the cross-country view of where each jurisdiction sits on the FATF Recommendation 16 (Travel Rule) and OECD CARF implementation curves. Entries marked "NOT VERIFIED" reflect that the underlying jurisdiction file does not yet establish the fact -- they are honest gaps, not negatives.

Observations.

• Travel Rule convergence is near-universal, thresholds are not. Every jurisdiction with a verified position has implemented or is implementing FATF Recommendation 16, but the de minimis threshold varies widely -- from zero (Japan, Singapore, South Korea, EU) through the FATF-standard USD/EUR 1,000 (UAE) and the stricter CHF 1,000 (Switzerland) to a USD 3,000 floor (United States). The zero-threshold jurisdictions are clustered in Asia-Pacific and the EU; the US sits at the most permissive end among advanced economies.

• CARF adoption is splitting into early movers and not-yet-committed jurisdictions. Among the matrix jurisdictions, Canada, the EU (via DAC8), the United Kingdom, and Nigeria begin CARF reporting from 1 January 2026; Brazil is already live via its DeCripto system (launched July 2025); Switzerland follows from 1 January 2027; and Turkey is aligning for 2025-2026. The United States has not adopted CARF, relying on its domestic Form 1099-DA broker-reporting regime instead. For Hong Kong, Singapore, the UAE, and several others, the jurisdiction files do not yet establish a CARF date -- recorded here as NOT VERIFIED / Not specified rather than asserted.

• A US carve-out from CARF. The single most consequential CARF gap among major jurisdictions is the United States, which substitutes domestic Form 1099-DA broker reporting for the multilateral CARF exchange. This produces a tax-transparency asymmetry: stablecoin flows touching CARF-adopting jurisdictions are exchanged automatically, while US-side reporting remains domestic.

3. Coherence Analysis: Overlaps, Reinforcements, and Tensions

3.1 Areas of Strong Coherence

"Same activity, same risk, same regulation" principle. This foundational principle is shared by the FSB (explicit in Recommendations 2 and 10), IOSCO (Recommendation 1), CPMI-IOSCO (functional approach to transfer function), and the IMF (endorsed in Executive Board Assessment). The Basel Committee applies a variant through its classification conditions -- the capital treatment depends on the functional characteristics of the stablecoin, not its label. This near-universal convergence on the functional approach provides a strong foundation for national implementation.

Algorithmic stablecoin exclusion. The FSB (Recommendation 9, footnote 2: "so-called algorithmic stablecoins do not meet recommendation 9") and the Basel Committee (SCO60.13: "Cryptoassets that use protocols to increase or decrease the supply of the cryptoasset do not meet classification condition 1") are in full alignment. Both bodies effectively exclude algorithmic stablecoins from compliant treatment. This consensus emerged post-TerraUSD collapse (May 2022) and represents the clearest point of international agreement.

Reserve asset quality standards. The FSB (Recommendation 9: "conservative, high quality and highly liquid assets"), CPMI-IOSCO (Principle 9: "little or no credit or liquidity risk"), and Basel (SCO60.12: "Level 1 HQLA" for fiat-pegged stablecoins) are convergent. The Basel standard is the most prescriptive (specifying Level 1 HQLA as defined in LCR30.41), while the FSB and CPMI-IOSCO use principles-based language. There is no conflict -- the standards form a hierarchy from principles (FSB) to payment system requirements (CPMI-IOSCO) to bank-specific rules (Basel).

Redemption at par. The FSB (Recommendation 9: "redemption should be at par into fiat" for single-fiat-currency GSCs) and the Basel Committee (SCO60.15: "full redeemability... at peg value at all times") are aligned. The Basel standard adds a specific timeline: redemption must be completable within 5 calendar days. The CPMI-IOSCO standard adds a complementary requirement: conversion "as soon as possible, at a minimum by the end of the day and ideally intraday."

Governance and identifiable legal entities. The FSB (Recommendation 4), CPMI-IOSCO (Principle 2), Basel Committee (Classification Condition 4), and IOSCO (Recommendation 2) all require identifiable legal entities with clear governance structures. All acknowledge the challenge of decentralised governance but none accommodate fully permissionless arrangements.

FATF Travel Rule as the AML/CFT convergence point. At the national level, the Travel Rule (FATF Recommendation 16) is the most consistently implemented international standard across the jurisdictions surveyed (see Section 2.1). The EU's Transfer of Funds Regulation, Singapore's PSN02, Japan's APTCP regime, Switzerland's CHF 1,000 rule, South Korea's zero-threshold regime, and the US >$3,000 BSA Travel Rule all trace to the same FATF source, even where thresholds differ. This reflects FATF's uniquely strong enforcement mechanism: jurisdictions implement to avoid mutual-evaluation downgrades and grey-listing.

3.2 Constructive Tensions

FSB's "same activity, same risk, same regulation" vs. Basel's bank-specific approach. The FSB principle implies that all entities performing the same function should face equivalent regulation regardless of their institutional nature. The Basel Committee, by mandate, sets standards only for banks. A stablecoin issuer that is not a bank faces FSB, FATF, IOSCO, and national regulatory expectations, but not Basel capital requirements. Conversely, a bank holding the same stablecoin faces the full weight of d545. This creates asymmetric treatment: a fintech stablecoin issuer operating outside the banking perimeter may face lighter prudential requirements than a bank engaging with the same product. The FSB's Recommendation 9 attempts to bridge this by referencing "prudential requirements equivalent to BCBS standards," but compliance assessment is left to national authorities.

FATF's VASP classification vs. IOSCO's securities-based approach. FATF classifies stablecoin service providers as VASPs (or financial institutions) based on the functions they perform -- exchange, transfer, safekeeping, participation in issuance. IOSCO addresses crypto-asset service providers (CASPs) through the lens of securities market regulation -- market integrity, conflicts of interest, listing standards, custody. A stablecoin exchange platform is simultaneously a VASP under FATF and a CASP under IOSCO, subject to both AML/CFT obligations and market conduct requirements. These frameworks are complementary rather than contradictory, but they create dual classification challenges at the national level. Jurisdictions must decide whether to regulate stablecoin platforms under AML/CFT legislation, securities legislation, payments legislation, or bespoke crypto legislation -- and ensure all FATF and IOSCO expectations are met regardless of the chosen vehicle.

Travel Rule threshold divergence. While the Travel Rule is the most uniformly adopted standard, the threshold at which it bites diverges materially -- from zero (Japan, Singapore, South Korea, EU) to USD 3,000 (United States). FATF's R.16 sets a USD/EUR 1,000 reference, but national implementations sit on both sides of it. This creates cross-border friction: a stablecoin transfer of USD 1,500 carries originator/beneficiary data when it touches a zero-threshold jurisdiction but may not when it originates in the US under the BSA floor. The standard is convergent in principle and divergent in calibration.

OECD CARF vs. domestic tax-reporting regimes. Most surveyed jurisdictions are adopting CARF directly (Canada, EU via DAC8, UK, Nigeria from 1 Jan 2026; Switzerland from 2027; Brazil already live). The United States instead relies on a domestic broker-reporting regime (Form 1099-DA) and has not adopted CARF. This is not a regulatory conflict but a structural divergence in tax transparency: CARF is built for automatic multilateral exchange, whereas the US regime is domestic-first. Stablecoin issuers and exchanges operating across both must run parallel reporting pipelines.

CPMI-IOSCO's systemic importance threshold vs. FSB's broad scope. The CPMI-IOSCO PFMI apply only to systemically important stablecoin arrangements -- and no stablecoin has yet been formally designated as systemically important in any major jurisdiction. The FSB recommendations apply to all GSCs and stablecoins "with the potential to become GSCs," a broader but vaguer scope. This creates a gap: a stablecoin may be large enough to attract FSB scrutiny but not formally designated as systemically important for CPMI-IOSCO purposes, meaning the detailed settlement finality and money settlement standards may not formally apply.

IMF's caution on stablecoins vs. other bodies' regulatory accommodation. The IMF's framework, particularly Elements 1 and 9, takes a more cautious stance. Element 1 opposes legal tender status for crypto-assets. Element 9 advocates public digital infrastructure (CBDCs, multilateral payment platforms) as alternatives to private stablecoin arrangements. Other bodies -- particularly the FSB, IOSCO, and Basel Committee -- take a more regulatory accommodation approach, seeking to bring stablecoins within existing frameworks rather than positioning alternatives. This philosophical tension does not create regulatory conflict but reflects differing views on whether well-regulated stablecoins are part of the solution or primarily a risk to be managed.

3.3 Outright Gaps Between Bodies

Cross-border resolution. No international body provides a binding framework for cross-border resolution of stablecoin arrangements. The FSB's Recommendation 7 requires recovery and resolution plans but provides no mechanism for coordinating resolution across jurisdictions. The October 2025 peer review confirmed that most jurisdictions lack comprehensive resolution frameworks for stablecoins.

Multicurrency stablecoins. The CPMI-IOSCO guidance (d206) explicitly excludes stablecoins pegged to baskets of currencies, reserving this for future work. The FSB's recommendations are also less detailed on multicurrency GSCs. This is a material gap given the historical proposal of basket-pegged stablecoins (e.g., the original Libra/Diem design).

DeFi governance. All six bodies acknowledge that decentralised governance poses challenges. None provides a comprehensive framework. The FATF guidance (October 2021) addresses DeFi only to the extent an identifiable entity performs VASP functions. IOSCO published a consultation on DeFi in September 2023 but has not finalised guidance. The FSB's recommendations require identifiable governance bodies, effectively excluding fully decentralised arrangements from compliance. As of June 2026, no major jurisdiction has enacted comprehensive DeFi regulation.

4. National Implementation Scorecard

The following scorecard assesses how well key national frameworks align with each international body's standards. Ratings: Full (comprehensive alignment), Substantial (most requirements addressed), Partial (significant gaps), Minimal (early stage or limited coverage).

4.1 EU/MiCA

EU CARF status: DAC8 (the EU implementation of OECD CARF) is applicable from 1 January 2026, with the first reporting year 2026 and reports due by 30 September 2027.

4.2 United States (GENIUS Act)

US CARF status: the United States has not adopted OECD CARF, relying instead on its domestic Form 1099-DA broker reporting regime (Infrastructure Investment and Jobs Act 2021). Market milestone: Tether launched USAT (a GENIUS-compliant US stablecoin) via Anchorage Digital Bank on January 27, 2026, coexisting with global USDT.

4.3 Singapore (SCS Framework)

Singapore CARF status: NOT VERIFIED -- the jurisdiction file does not yet establish a CARF adoption date.

4.4 Comparative Summary

The EU and Singapore emerge as the jurisdictions most closely aligned with the full suite of international standards. Both have comprehensive, purpose-built stablecoin regulatory frameworks that address FSB, FATF, IOSCO, and CPMI-IOSCO expectations. South Korea ranks lower on the FSB axis specifically because its dedicated stablecoin regime (DABA) remains a pending bill -- introduced 10 June 2025 and re-proposed in 2026, but not passed (review pushed to H2 2026) -- so its consumer-protection baseline (VAUPA) is in force while the issuance/reserve regime is not. The primary gap across all jurisdictions is Basel d545 implementation, which was extended to January 1, 2026 and remains incomplete in several major banking jurisdictions.

5. Gaps in International Standards

5.1 Algorithmic Stablecoins -- Exclusion Without Alternative

The FSB and Basel Committee both exclude algorithmic stablecoins from compliant treatment but provide no regulatory pathway for these instruments. The FSB states they "do not meet recommendation 9"; the Basel Committee classifies them as Group 2b (1,250% risk weight). The international framework effectively says algorithmic stablecoins cannot comply with international standards but does not prescribe what national authorities should do with them -- permit them under a separate regime, restrict them, or ban them. Some jurisdictions (e.g., the US GENIUS Act, which excludes algorithmic/endogenously-collateralised stablecoins from PPSI status, and EU MiCA's treatment under its general crypto-asset framework) have developed national approaches, but there is no international guidance.

5.2 DeFi Governance -- No Framework

Decentralised stablecoin protocols (e.g., DAI/Maker, decentralised lending platforms that issue stablecoins) operate without identifiable legal entities in many cases. All six international bodies require identifiable governance bodies, creating a fundamental incompatibility. The FATF acknowledges the challenge but has not resolved it. IOSCO consulted on DeFi in September 2023. The FATF is scheduled to issue analysis on stablecoins and DeFi in 2026. Until then, decentralised stablecoin issuance exists in a regulatory gap at the international level.

5.3 Cross-Border Resolution -- No Binding Framework

The FSB's Recommendation 7 requires recovery and resolution plans, but there is no binding international framework for coordinating cross-border resolution of stablecoin arrangements. The CPMI-IOSCO PFMI include recovery and resolution expectations for systemically important FMIs, but no stablecoin has been designated as systemically important. The October 2025 FSB peer review found that "frameworks frequently lack comprehensive requirements for recovery and resolution planning, including insolvency procedures."

5.4 Stablecoin Yield/Interest -- Unaddressed

Several stablecoin arrangements now offer yield or interest to holders. The international framework does not specifically address whether stablecoins that generate returns should be regulated as investment products (securities), deposits, or some other category. This creates jurisdictional fragmentation: some treat yield-bearing stablecoins as securities (potentially under IOSCO frameworks), others as banking products (potentially under Basel frameworks), and others as payment instruments with ancillary returns. Several national frameworks now prohibit interest to holders outright (e.g., the US GENIUS Act bars issuers from paying interest to holders), but there is no international standard.

5.5 Non-Fiat-Pegged Stablecoins -- Limited Coverage

The CPMI-IOSCO guidance explicitly excludes multicurrency stablecoins. The FSB and Basel Committee provide limited guidance on stablecoins pegged to commodities (e.g., gold-backed tokens) or baskets. National frameworks vary significantly in their treatment of non-fiat-pegged stablecoins.

5.6 Tax Transparency -- Fragmenting CARF Adoption

The OECD's Crypto-Asset Reporting Framework is the closest thing to an international tax-transparency standard for stablecoins, but adoption is fragmenting. Among the surveyed jurisdictions, Canada, the EU (DAC8), the UK, and Nigeria begin reporting from 1 January 2026; Brazil is already live (DeCripto, July 2025); Switzerland follows from 2027; Turkey is aligning for 2025-2026. The United States has not adopted CARF, relying on domestic Form 1099-DA reporting. For several jurisdictions (Bermuda, Australia, Hong Kong, India, Japan, Singapore, South Korea, Bahrain, South Africa, UAE) the jurisdiction files do not yet establish a CARF position. This produces uneven multilateral exchange coverage for stablecoin flows.

5.7 Developing Economy Capacity -- Acknowledged but Unresolved

The IMF, uniquely among the six bodies, addresses the disproportionate risks to developing economies. The FSB recommendations acknowledge differing impacts on EMDEs but do not provide differentiated implementation guidance. No international body provides a simplified or phased implementation pathway for jurisdictions with limited regulatory capacity. Nigeria illustrates the tension: its regulated stablecoin (cNGN) launched in February 2025, with the issuer admitted to the Regulatory Incubation / Accelerated Regulatory Incubation Programme (RI/ARIP) track on 29 August 2024 -- a test-and-learn admission rather than a full Approval-in-Principle -- while a dedicated stablecoin issuance/reserve regime does not yet exist.

6. Implementation Timeline and Sequencing

6.1 Key Milestones

6.2 Implementation Pressure Points

Basel d545 (1 January 2026). The most immediately consequential prudential deadline. Banks in member jurisdictions must classify crypto-asset exposures under the two-group framework and hold capital accordingly. Stablecoins that fail the four classification conditions face the punitive 1,250% risk weight, effectively capping bank engagement. National implementation varies: the EU is incorporating into CRR III; the US, UK, and Japan are proceeding but not yet finalised.

FATF mutual evaluation cycle. The FATF's 5th round of mutual evaluations is ongoing and now incorporates VA/VASP compliance assessment. Jurisdictions found non-compliant risk grey-listing, with significant consequences for cross-border financial access. The UAE's exit from the grey list (23 February 2024, with its next mutual evaluation expected 2026) illustrates both the pressure and the path back. This creates sustained implementation pressure regardless of formal deadlines.

OECD CARF (2026-2028). While not one of the six core bodies, the OECD's Crypto-Asset Reporting Framework creates a parallel tax-transparency timeline. Reporting begins 1 January 2026 in Canada, the EU (via DAC8), the UK, and Nigeria; Brazil is already live via DeCripto (July 2025); Switzerland follows from 1 January 2027. The EU's first DAC8 reports (reporting year 2026) are due by 30 September 2027. The United States is a notable non-adopter, using domestic Form 1099-DA reporting instead. For Hong Kong, Singapore, the UAE, and several others, no CARF date is yet established in the jurisdiction files. Stablecoin issuers and exchanges must build data-collection infrastructure wherever CARF (or DAC8) applies.

7. Recommended Approach for New Regulators

For a regulator building a stablecoin framework from scratch, the following sequencing prioritises the most critical and enforceable international standards first.

Phase 1: Foundation (Months 1-6) -- AML/CFT and Legal Certainty

Priority standards: FATF Recommendation 15 (INR.15) + FATF Recommendation 16 (Travel Rule) + IMF Element 4

Rationale: FATF compliance is non-negotiable. Failure to implement VA/VASP AML/CFT requirements exposes the jurisdiction to grey-listing risk, with cascading consequences for the entire financial sector. The Travel Rule (R.16) is the single most consistently implemented international standard across surveyed jurisdictions and is the first thing FATF mutual evaluations test. Legal certainty (IMF Element 4) is prerequisite for all subsequent regulation -- without clear legal status for stablecoins, no regulatory framework can function.

Actions:

• Define stablecoins under domestic law (VA, e-money, payment instrument, or bespoke category)
• Establish licensing/registration requirements for VASPs including stablecoin issuers
• Implement CDD, record-keeping, suspicious transaction reporting
• Implement the Travel Rule (R.16); choose a de minimis threshold deliberately (jurisdictions range from zero to USD 3,000) and align with cross-border counterparties where possible
• Establish the legal status of stablecoin holdings, reserve asset claims, and insolvency treatment
• Decide on OECD CARF adoption (or a domestic broker-reporting equivalent) early, since data-collection obligations shape issuer/exchange infrastructure

Phase 2: Core Prudential Framework (Months 6-12) -- FSB Recommendations

Priority standards: FSB 10 High-level Recommendations + IMF Element 5

Rationale: The FSB recommendations provide the comprehensive framework endorsed by the G20. They are principles-based and can be implemented through existing regulatory structures or bespoke legislation.

Actions:

• Establish licensing requirements for stablecoin issuers (FSB Rec 10)
• Require governance frameworks with identifiable legal entities (FSB Rec 4)
• Set reserve asset requirements: high-quality liquid assets, full backing, segregation (FSB Rec 9)
• Establish redemption rights: at par, timely, without undue restrictions (FSB Rec 9)
• Require disclosure of reserve composition, governance, and risk information (FSB Rec 8)
• Mandate risk management frameworks including operational resilience (FSB Rec 5)
• Require recovery and resolution planning (FSB Rec 7)
• Address algorithmic stablecoin policy (permit, restrict, or prohibit)

Phase 3: Market Conduct and Infrastructure (Months 12-18) -- IOSCO and CPMI-IOSCO

Priority standards: IOSCO 18 Recommendations + CPMI-IOSCO PFMI (if applicable)

Rationale: Once the licensing and prudential framework is in place, market conduct regulation ensures investor protection and market integrity for the platforms listing and trading stablecoins.

Actions:

• Apply market conduct requirements to stablecoin trading platforms (IOSCO Recs 2-10)
• Establish custody and client asset protection standards (IOSCO Recs 12-16)
• Implement stablecoin-specific disclosure requirements (IOSCO Rec 6 box text)
• Assess whether any stablecoin arrangement warrants systemic importance designation (CPMI-IOSCO four-factor test)
• If designated, apply PFMI standards to the arrangement

Phase 4: Bank Prudential Integration (Months 18-24) -- Basel Committee

Priority standards: Basel d545

Rationale: Banks' engagement with stablecoins must be governed by the Basel framework to maintain banking system stability. This requires the earlier phases' work on legal certainty and reserve requirements to enable classification.

Actions:

• Implement the two-group classification framework (SCO60)
• Ensure domestic stablecoin regulation enables Group 1b classification for compliant stablecoins
• Apply capital requirements, exposure limits, and disclosure requirements
• Establish supervisory review processes for banks' crypto-asset exposures

Phase 5: Macroeconomic Safeguards and International Cooperation (Ongoing) -- IMF Elements

Priority standards: IMF Elements 1, 2, 3, 6, 7, 8

Rationale: Macroeconomic safeguards are ongoing policy commitments rather than one-time regulatory implementations. They require continuous monitoring and adjustment.

Actions:

• Ensure stablecoins are not granted legal tender status (IMF Element 1)
• Assess and address capital flow management implications (IMF Element 2)
• Clarify tax treatment (IMF Element 3)
• Establish domestic inter-agency coordination (IMF Element 6)
• Enter into international cooperation arrangements (IMF Element 7, FSB Rec 3)
• Monitor stablecoin adoption for monetary sovereignty implications (IMF Element 8)

Phase Sequencing Diagram

Phase 1: FATF (R.15 + R.16 Travel Rule) + Legal Certainty + CARF decision -----> Foundation
     |
Phase 2: FSB 10 Recommendations ----> Core Framework
     |
Phase 3: IOSCO + CPMI-IOSCO --------> Market Conduct + Infrastructure
     |
Phase 4: Basel d545 -----------------> Bank Integration
     |
Phase 5: IMF Macroeconomic ----------> Ongoing Safeguards

8. Verification Notes

This synthesis mirrors the canonical per-jurisdiction fact matrix for this research series, together with the six international framework files. The per-jurisdiction FATF, Travel Rule, and CARF statements in Section 2.1 are reflected directly from the matrix; entries recorded as "NOT VERIFIED" or "Not specified" are honest gaps in the underlying jurisdiction files, not asserted negatives. The following table documents verification of key factual claims at the international-standards layer.

Sources Referenced

• FSB High-level Recommendations for GSC Arrangements (July 2023)
• FSB Thematic Peer Review (October 2025)
• FATF Updated VA/VASP Guidance (October 2021)
• FATF 2025 Targeted Update on VA/VASP Implementation
• IOSCO FR11/2023 Policy Recommendations
• IOSCO October 2025 Implementation Review
• CPMI-IOSCO d206 PFMI Application to Stablecoin Arrangements (July 2022)
• IMF Elements of Effective Policies for Crypto Assets (February 2023)
• IMF-FSB Synthesis Paper (September 2023)
• Basel Committee d545 Prudential Treatment of Cryptoasset Exposures (December 2022)
• Basel Committee July 2024 Amendments and Disclosure Framework
• GENIUS Act (S.1582, 119th Congress)
• MAS Stablecoin Regulatory Framework (August 2023)
• OECD CARF Implementation Commitments
• FSB Framework (this series)
• FATF Framework (this series)
• IOSCO Framework (this series)
• CPMI-IOSCO Framework (this series)
• IMF Framework (this series)
• Basel Committee Framework (this series)
• Crypto Mining International Organization Frameworks (cross-domain reference)