On October 12, 2026, the Financial Stability Board published a note on cross-border stablecoin vulnerabilities. It puts the stablecoin market at around $300 billion as of mid-2026, essentially unchanged from a year earlier, and says 99 per cent of that value is pegged to the US dollar. The document does not give a publication time or identify a transaction amount.
The FSB defines a global stablecoin by its existing or potential use across jurisdictions and its capacity to become systemically important. That potential can come from use as a payment instrument, a store of value, or links to other financial markets. The note focuses on how the entities, reserves, legal claims, and markets behind one token can sit under different national authorities.
Where cross-border stress can concentrate
Stablecoins now provide liquidity for entering, exiting, and trading in crypto markets. The FSB also sees use in some emerging market and developing economies as an alternative store of value and a route to financial inclusion. It says future systems may support faster, more transparent, and cheaper domestic and cross-border transactions at scale. Some of those benefits may come from distributed ledgers and tokenization rather than the stablecoin itself.
The same circulation model changes the shape of a run. Tokens trade around the clock on secondary markets and can move globally through pseudonymous addresses. An issuer may not know who holds its liabilities, where those holders live, or where redemption demand will appear. Reserve assets and holders’ legal protections can still be tied to particular jurisdictions, while reserve management follows the hours and settlement practices of the markets where the assets sit.
That timing gap can matter under stress. Continuous secondary trading can accelerate selloffs and pressure a peg when fiat redemptions cannot keep pace. Deep secondary markets can also support arbitrage back toward the peg. The FSB identifies three channels through which a run could reach traditional finance: reserve-asset fire sales, withdrawals of bank deposits to fund redemptions, and disruption where the stablecoin is used for real-economy payment or settlement. It also points to foreign exchange exposure when stablecoins carry cross-border transactions.
The note gives special attention to multi-issuer arrangements. Affiliated issuers can share liability for one token while holding separate reserve pools. If holders may redeem with any affiliate, demand can pile up at one entity even when another affiliate holds the corresponding reserves. The system then depends on cross-border reserve rebalancing and secondary trading to bring liabilities and assets back into line.
Those mechanisms rely on reserve mobility, market access, information flows, and coordination. Each can weaken during stress. Pseudonymous holdings make it harder to assign liabilities among issuers, leaving uncertainty over which entity a holder can claim against during insolvency. The FSB also says it may be difficult to determine which national insolvency regime applies to a global arrangement.
Reserve quality remains central. The note says lower-quality or less-liquid assets can amplify liquidity and operational vulnerabilities, especially when reserves sit in jurisdictions that have not implemented the FSB recommendations. Emerging market and developing economies may reach systemic exposure at a lower level of adoption because of currency substitution, bank disintermediation, and capital-flow management pressures.
What supervisors can and cannot see
The FSB wants monitoring to cover secondary-market depth, liquidity, and structure, alongside the geographic distribution of holdings, redemptions, and reserves. The geographic fields are particularly important for multi-issuer systems because supervisors need to compare where redemption liabilities may surface with where reserve assets are available.
Public blockchains produce abundant transaction data, but they do not automatically answer those questions. Pseudonymity and smart-contract routing make it difficult to attribute activity to a particular use or geography. Where attribution is possible, the method may be proprietary, non-standard, undisclosed, or impossible for another analyst to verify.
Authorities therefore rely mostly on private stablecoin data compilers. Those providers combine and filter primary data with proprietary methods that vary in accuracy and transparency. The high volume and complex structure of the data also demand sophisticated infrastructure, tools, and technical skills. Different methods can produce inconsistent datasets, extra noise, and weak comparability. The FSB says the technical workload may be substantial for authorities, particularly in emerging market and developing economies.
Some gaps are more tractable than pseudonymity. Data may already exist but remain undisclosed to the public or authorities. Compilers can also use incompatible heuristics, formats, and coverage. The note says better disclosure of methods, combining sources, and new techniques for estimating stablecoin use could improve monitoring. Changes to reporting rules, smart-contract design, or data standards could also make on-chain and off-chain records more consistent.
The next supervisory work
The FSB identifies three next steps. Members and relevant authorities could develop financial-stability metrics and name the remaining data gaps. They could share analytical expertise and information across borders. They could also explore industry practices for collecting and compiling on-chain and off-chain data so that quality and comparability improve over time.
The policy problem extends beyond data. The FSB says foreign-issued stablecoins still receive uncertain or undefined treatment in many jurisdictions. Issuers can operate through entities in several regulatory regimes, which can complicate oversight, crisis management, accountability, and cooperation during stress or insolvency. Neither global stablecoins nor the national frameworks around them have been tested in severe stress and insolvency.
The unresolved question is whether supervisors can obtain reliable geographic data on holdings, redemptions, and reserves before a cross-border run forces those legal and operational links into view. The FSB proposes internationally aligned monitoring and information sharing, but its note does not set a dated milestone for that work.
