FSB Global Stablecoin Note: Tracking Where Tokens and Reserves Sit

On 12 October 2026 the Financial Stability Board (FSB) published a five-page note to the G20, Global stablecoin arrangements: Cross-border vulnerabilities and financial stability monitoring, together with a letter from its Chair, Andrew Bailey, to G20 Finance Ministers and Central Bank Governors ahead of their 15 October meeting. The FSB global stablecoin note sets out how stress in a stablecoin used across many jurisdictions could travel across borders, and it names what authorities could monitor to see that coming: the depth, liquidity and structure of secondary markets, and the geographic distribution of stablecoin holdings, redemptions and reserve assets, especially where several affiliated entities issue the same token.

FSB publications state that its activities, including any decisions reached in their context, “shall not be binding or give rise to any legal rights or obligations”. The note matters for the work programme it sets out: further work on monitoring cross-border vulnerabilities, on cross-border cooperation and information sharing, and on emerging approaches to planning for the distress or failure of global stablecoin arrangements.

For issuers, crypto-asset service providers (CASPs) and payment firms, the practical question is which parts of that data can already be produced from returns and records that exist today, such as the quarterly reporting under Article 22 of the EU’s Markets in Crypto-Assets Regulation (MiCA), and which parts the FSB itself says the available data often cannot answer.

Related reading: MiCA Review: The EBA’s Priorities for Token Issuers and CASPs

What the FSB published on 12 October 2026

Three documents appeared together on the FSB website:

• The Chair’s letter to G20 Finance Ministers and Central Bank Governors, dated 8 October 2026 and published on 12 October.
• The stablecoin note, dated and published 12 October 2026, filed under Reports to the G20 with the policy areas Crypto Assets, Data Gaps and Financial Innovation.
• A press release of the same day, “FSB Chair sets out FSB work on AI and stablecoins”, which also introduces the FSB’s finalised sound practices on AI adoption and its other G20 deliverables.

The note builds on two earlier FSB documents. The first is the final report of 17 July 2023, High-level Recommendations for the Regulation, Supervision and Oversight of Global Stablecoin Arrangements: ten recommendations addressed to authorities, which also set out expectations for providers of services within those arrangements. The second is the thematic peer review of 16 October 2025 on implementation of the FSB’s crypto framework, which reflects information as of August 2025. The note describes its content as a summary of ongoing work in two strands. One analyses how global stablecoin arrangements are structured, how vulnerabilities could propagate and which metrics could support monitoring. The other assesses the data currently available for monitoring stablecoin activity, its sources, benefits and limitations.

The letter is blunter than the note in one place. Bailey writes that national regulations “are taking shape at different speeds and cross-border cooperation in this area is still in its infancy”, and that global stablecoins “continue to feature prominently in discussions on fraud and related financial crime issues, particularly those operating from lightly regulated jurisdictions”. The note keeps financial crime outside its own analysis and says it complements work at the standard-setting bodies on monetary sovereignty, payments, consumer protection and AML/CFT. Travel Rule and other AML/CFT questions therefore sit with the FATF standards, covered in our FATF stablecoins and unhosted wallets article.

There is no template, threshold or implementation date in the note. Nothing in it moves a filing calendar in the EU, the US or anywhere else.

How the FSB global stablecoin analysis frames the cross-border problem

The FSB works with a functional definition. A global stablecoin is one with an existing or potential reach and use across multiple jurisdictions, which could become systemically important in one or more of them, including as a means of payment or store of value. The label is a supervisory concept. MiCA has its own categories, asset-referenced tokens (ARTs) and e-money tokens (EMTs), and its own significance classification under Articles 43 and 56. The two labels are assessed against different criteria, so one does not settle the other.

The market the note describes is concentrated. As of mid-2026 the FSB puts the total market value of stablecoins at around $300 billion, essentially unchanged from a year earlier, with 99 per cent by value pegged to the US dollar. Stablecoins are still mainly used inside crypto-asset markets, as a source of liquidity to enter, exit and trade. In some emerging market and developing economies (EMDEs) they may also serve as an alternative store of value.

The core of the analysis is a contrast with bank deposits. A bank has an account-based relationship with depositors it knows, and it can manage redemptions with a view of its whole balance sheet. A global stablecoin issuer, the FSB writes, may not know who holds its liabilities, where those holders are domiciled or, in some cases, where redemption demand will materialise. The tokens are pseudonymous, accessible worldwide and transferable around the clock on secondary markets, so the issuer’s liabilities are internationally mobile and may be partly unobservable.

The other side of the balance sheet may remain, at least partially, anchored in specific jurisdictions. Issuers design their programmes, including undertakings on reserve assets and on redemption into fiat currency, to be enforceable under at least one jurisdictional framework. Redemption and reserve management follow the operating hours and settlement practices of the markets involved and, increasingly, regulatory requirements. Holdings move across borders at any hour, while the assets and legal claims behind them may stay tied to particular places and keep particular hours.

Four channels from a run into the wider financial system

The note identifies the routes by which a run on a global stablecoin could reach traditional finance:

• Fire sales of reserve assets to meet redemptions.
• Withdrawals of bank deposits to fund redemptions.
• Dependencies on a stablecoin used for payment and settlement in the real economy.
• Foreign exchange markets where stablecoins are used for cross-border transactions.

Round-the-clock access and fast secondary trading can increase the speed and size of sell-offs and put pressure on the peg if redemptions cannot keep up with demand. The note adds the opposite effect in the same paragraph: deep and liquid secondary markets could support arbitrage that helps pull prices back toward the peg. Secondary-market depth cuts both ways, and the FSB lists it among its monitoring metrics.

Several factors can amplify these channels. Complex cross-border governance and distribution, together with less liquid or lower-quality reserve assets held in jurisdictions that have not implemented the FSB recommendations, can magnify liquidity and operational weaknesses. It may also be difficult to determine which national insolvency regime, or regimes, would apply if a global stablecoin failed. For EMDEs the FSB adds currency substitution, bank disintermediation and difficulties with capital flow management, so that a stablecoin could become systemic there at a lower threshold of use.

Three of the four channels pass directly through banks and payment firms. A bank holding an issuer’s reserve deposits sits in the second. The EBA, in its September 2026 response to the European Commission’s targeted consultation on the MiCA review, observes that stablecoin reserve deposits can be expensive for banks to take because of their prudential liquidity treatment. Under the liquidity coverage ratio (LCR), relevant deposits may attract high outflow rates; under the net stable funding ratio (NSFR), their funding value is set through available stable funding factors rather than outflow rates. The EBA also notes that holding a substantial proportion of reserves as deposits may help an issuer avoid immediate securities sales during stress.

A payment firm that settles merchant, payroll or remittance flows in a stablecoin sits in the third and fourth. The FSB’s 2025 peer review gives one example of an authority acting on the foreign exchange side: the Central Bank of Brazil requires CASPs to report customer transactions as part of bringing crypto-asset oversight into its foreign exchange framework.

Multi-issuer stablecoins: one token, several balance sheets

The note gives the multi-issuer configuration its own paragraph. Affiliated issuers jointly share liability for a single global stablecoin but hold separate reserves, and holders might be able to redeem with any of them. The arrangement relies on cross-border rebalancing of reserves and on secondary-market trading to keep reserve locations aligned with redemption flows. The FSB says that alignment depends on reserve mobility, market access, information flows and coordination that may break down in stress. If holders can redeem with any issuer regardless of where their tokens were issued, redemption demand could concentrate on one entity in the group. If holder location cannot be established, the attribution of liabilities to individual issuers, and the legal claims of holders, may be unclear in stress and in insolvency.

In the EU this is an open file. The European Systemic Risk Board’s Recommendation on third-country multi-issuer stablecoin schemes (ESRB/2025/9), announced on 20 October 2025, recommends that the Commission should not consider such schemes permitted under the existing MiCA framework. If the Commission takes a different view, the ESRB recommends a dedicated framework with safeguards. The Recommendation sets follow-up reporting dates for its addressees: 31 December 2025 for Recommendation A; 31 December 2026 for Recommendations B to E and H to J; and 31 December 2027 for Recommendations F and G. These dates concern reporting by the relevant authorities on actions undertaken or reasons for inaction; they are not direct implementation or filing deadlines for stablecoin issuers.

The EBA’s September 2026 consultation response adds the supervisory detail. MiCA, it says, does not explicitly refer to third-country multi-issuer schemes, although it does refer to multi-issuance by EU entities, and permissibility questions raised through the MiCA Q&A process remain unanswered by the Commission. The EBA counts two e-money institutions participating in such schemes, both for US dollar EMTs. It rates as significant the risks of run and reserve depletion in the EU, unbalanced reserve distribution across jurisdictions, third-country restrictions on moving reserves in stress, and difficulty measuring EU holdings, especially in self-custodial wallets.

The EBA states that Article 45(4) MiCA and its Guidelines on liquidity stress testing (EBA/GL/2024/08) enable supervisors, based on stress test results, to require an issuer to hold additional own funds and reserves in the EU, sized to cover both the tokens in circulation in the EU and those expected to be transferred into the EU for redemption in stress. The statutory text is narrower: Article 45(4) provides that, depending on the outcome of liquidity stress tests, EBA may strengthen the liquidity requirements for issuers of significant asset-referenced tokens, and higher own funds for issuers of asset-referenced tokens arise under Article 35(3) and (5). For e-money institutions issuing significant e-money tokens, Article 58(1) applies Article 45(1) to (4) and Article 35(2), (3) and (5), and Article 58(2) allows competent authorities to require e-money institutions issuing e-money tokens that are not significant to comply with those requirements where necessary to address risks such as liquidity risks. Even so, the EBA rated each MiCA safeguard it was asked about as only “slightly effective” against multi-issuance risk. Our article on the EBA’s MiCA review priorities covers the measures it proposes.

The US statute approaches reserve location from the other direction. Section 18 of the GENIUS Act (Public Law 119-27, enacted 18 July 2025) provides a conditional exception from section 3 for foreign payment stablecoin issuers. The conditions include a Treasury determination that the home regulatory regime is comparable, registration with the Comptroller of the Currency, reserves held at a US financial institution sufficient to meet US customer liquidity demands unless a qualifying reciprocal arrangement permits otherwise, and the statutory sanctions and money-laundering restrictions.

Under section 20, the Act’s general commencement is the earlier of 18 months after enactment (18 January 2027) or 120 days after the primary federal payment stablecoin regulators issue final implementing regulations. Separately, the section 3(b)(1) prohibition on a digital asset service provider offering or selling to a person in the United States a payment stablecoin not issued by a permitted payment stablecoin issuer begins three years after enactment, on 18 July 2028, except as provided in section 3(c) and section 18. The section 18 reserve condition is a statutory version of the FSB’s point that reserves may remain, at least partially, anchored in specific jurisdictions. The Federal Reserve’s proposed reporting under the Act is covered in our FR UU reporting guide.

MiCA already aggregates across issuers in at least one test. Under Article 23(3), where several issuers issue the same asset-referenced token, the competent authority assesses the means-of-exchange thresholds of 1 million transactions and EUR 200 million per day after aggregating data from all issuers, and Article 58(3) extends Article 23 to EMTs denominated in a non-EU currency.

The FSB’s monitoring metrics, set against EU reporting

The metrics paragraph is short. The FSB says its analysis supports monitoring “the depth, liquidity and structure of secondary markets and the geographic distribution of stablecoin holdings, redemptions and reserve assets, especially under the multi-issuer configuration”, and that authorities may consider additional metrics. It defines none of them.

For an EU issuer of an ART, or of an EMT denominated in a non-EU currency, part of that list already exists as a quarterly return. Article 22(1) MiCA requires issuers of such tokens with an issue value above EUR 100 million to report the number of holders, the value issued and the size of the reserve, average daily transactions, and an estimate of average daily transactions associated with use as a means of exchange within a single currency area. Competent authorities may extend the duty to smaller tokens under Article 22(2). Commission Implementing Regulation (EU) 2024/2902 of 20 November 2024 sets the templates, and its recital 1 asks for the number of holders broken down by holder location, by custodial and non-custodial wallets, and by retail holders. The EBA’s own-initiative Guidelines on templates (EBA/GL/2024/16) add further templates, including a maturity ladder for the reserve. Our MiCAR token classification and reporting guide explains which token category triggers which return.

The means-of-exchange figure is narrower than a geographic distribution of use. Under Commission Delegated Regulation (EU) 2025/298, the applicable regulatory technical standards, the estimate includes eligible means-of-exchange transactions only where both payer and payee are located in the same single currency area within the EU. Location is determined by habitual residence for natural persons and registered office for legal persons. Transactions solely between non-custodial wallets are excluded from this estimate. A payment from a payer in one currency area to a payee in another falls outside the estimate for both. CIR 2024/2902 collects transactions and transfers between non-custodial wallets separately in S 04.03, with the transactions reported on a best-effort basis and the issuer’s estimation method described in S 04.04.

For public disclosure, the FSB’s own model is Annex 2 of the 2023 recommendations: an illustrative reserve template for authorities that want to supplement or introduce disclosure rules. It asks, by asset category, for market value at month end, weighted average maturity and a daily-average market value, and it carries a separate row for loans or extensions of credit to entities affiliated with the arrangement. In a multi-issuer group, that affiliate row discloses how much of the reserve portfolio consists of loans or extensions of credit to entities affiliated with the arrangement.

Why abundant stablecoin data still leaves supervisors short

The second half of the note corrects an easy assumption, that public blockchains already give supervisors the full picture. The FSB agrees that stablecoin activity generates abundant data and then sets out why several challenges currently limit its use for financial stability monitoring.

Authorities rely mostly on private compilers of stablecoin data, which use proprietary methods to compile, filter and aggregate data from primary sources. Those methods may vary in accuracy and transparency, and differences between providers can produce inconsistencies, noise and limits on comparability. The FSB suggests authorities may consider deepening their own analytical expertise with blockchain data, while noting that this may be a significant undertaking in some jurisdictions such as EMDEs.

The note splits the constraints into two kinds. Some are structural: public blockchains are pseudonymous, and that is likely to persist absent significant changes in the crypto-asset ecosystem. Others are more tractable, namely data that technically exists but is not disclosed publicly or to authorities, and the use of non-standard methods, heuristics, formats or coverage when data is compiled and shared. The note describes attribution as a more structural challenge. Understanding concentrations and cross-border flows requires attributing activity to uses and geographies, and that is often not possible because of transaction pseudonymity and the smart contract infrastructure underlying most stablecoins. Where attribution is possible, it may not be verifiable.

The FSB also records that stablecoin data availability has improved significantly, mostly through industry effort, and that changes in disclosure and reporting requirements, smart contract design or data standards could increase consistent on-chain and off-chain data. It says members and relevant authorities could consider three next steps: develop a set of metrics for financial stability monitoring and identify data gaps; make better use of existing data, including by encouraging cross-border analytical expertise, information sharing and coordination; and explore possible industry best practices for data collection and compilation on and off chain. The steps should be aligned internationally where helpful and iterated as market practice evolves.

I read the first tractable category, data that exists but is not disclosed, as pointing mainly at off-chain records: the residence data a CASP holds for its customers, an issuer’s redemption ledger, and custody statements for reserve assets. The note does not list those records itself, so treat that as interpretation.

CASPs as the data source issuers depend on

For CASPs, the note’s data findings land on an obligation that already exists in the EU. Article 22(3) MiCA requires CASPs providing services related to ARTs, and through Article 58(3) to non-EU-currency EMTs, to give the issuer the information it needs for the Article 22 report, including transactions settled outside the distributed ledger. Annex III of CIR 2024/2902 sets the CASP templates: S 06.00 on holders, S 07.01 to S 07.04 on transactions and distributed ledger addresses used on behalf of clients, and S 08.00 on tokens held by the CASP. Under Article 3(2), S 08.00 must be submitted to the issuer daily by close of business. The other CASP templates are submitted quarterly, by 21 January, 21 April, 21 July and 21 October. A CASP that issues nothing is still part of the issuer’s reporting chain.

The EBA’s September 2026 response shows where that chain is weak. MiCA, it says, provides no holistic mandate to set reporting requirements for ART and EMT issuers or for CASPs, and the Article 22(7) mandate for implementing technical standards cannot cover all relevant data points, such as those needed to assess own funds and liquidity compliance or significance. Its own-initiative Guidelines (EBA/GL/2024/16) are addressed to competent authorities and issuers, so for data beyond the ITS, issuers have to obtain information from CASPs through contractual agreements, which the EBA calls a weaker and more convoluted basis. The EBA considers it vital that any revision of MiCA include a mandate for cohesive reporting by issuers and CASPs, proportionate to the scale of issuance.

Outside the EU the reporting base is thinner still. The 2025 peer review found that 19 jurisdictions had finalised a comprehensive regulatory framework for CASPs, while 11 jurisdictions, not all of them among those 19, had comprehensive reporting requirements in place to monitor the financial stability implications of CASP activity. In the EU, CASPs report to their national competent authority the information needed to assess compliance with governance requirements, ICT-related incidents and suspicious transactions or orders, while other reporting, including on financial condition and risks, is left to national authorities, and the review found progress varies significantly across member states.

On the global stablecoin side, the same review placed five jurisdictions at the “regulatory framework finalised” stage for the FSB’s stablecoin recommendations as of August 2025: The Bahamas, Bermuda, the EU, Hong Kong and Japan. Eleven had no framework in place.

Where the FSB’s next steps point for issuers, CASPs and payment firms

The note ends with two lists, and neither carries a date. On vulnerabilities, it highlights three areas relating to implementation of the 2023 recommendations that may warrant continued consideration: enhancing monitoring of cross-border vulnerabilities, supported by the indicators above and the data work; supporting implementation, particularly by encouraging cross-border cooperation and information sharing, which may also help with the interplay of regulatory frameworks across borders; and gathering information on emerging approaches to planning for the distress or failure of global stablecoin arrangements, with a focus on cross-border issues. On data, it sets the three steps described in the previous section.

Firms meet those themes through three of the 2023 recommendations as implemented in national rules. Recommendation 3 covers cross-border cooperation, coordination and information sharing. Recommendation 6 covers data storage and access to data, and expects authorities to obtain timely and complete access to relevant data wherever the data is located. Recommendation 7 expects arrangements to have appropriate recovery and resolution plans. The 2025 peer review pointed the same way, recommending that jurisdictions improve their data capabilities by drawing on regulatory and supervisory reporting from CASPs, stablecoin issuers and other market participants, and that the FSB analyse the vulnerabilities stemming from global stablecoins with multi-jurisdictional issuances.

Bilateral cooperation instruments of the kind Recommendation 3 describes already exist. Article 126 MiCA allows the EBA to conclude administrative agreements on information exchange with third-country supervisory authorities, and in June 2026 the EBA published one with the New York State Department of Financial Services, analysed in our EBA-NYDFS stablecoin MoU article.

My reading of the practical consequence is narrow. The note identifies the questions supervisors are being encouraged to answer in stress, without pointing to a particular new return, and each group can test its own data against them:

• Issuers, especially in multi-issuer groups: by issuing entity, where are the holders, where would redemptions be presented and paid, and where are the reserves that back them, held with whom and on what settlement hours.
• CASPs: whether holder-location and off-ledger transaction data can be supplied to each issuer under Article 22(3) MiCA, using the Annex III templates of Commission Implementing Regulation (EU) 2024/2902 in a data-exchange format specified by the issuer, or obtained contractually where the provider falls outside the applicable MiCA reporting perimeter.
• Payment firms and banks: whether stablecoin settlement exposure, reserve deposits and the foreign exchange legs they create are visible by token and by issuing entity.

Frequently Asked Questions

Does the FSB note change what EU issuers report under MiCA Article 22 or what US issuers will report under the GENIUS Act?

Neither changes because of the note; amending them takes EU or US law. A related point concerns data already reported: under Article 22(4) MiCA, the competent authority shares an issuer’s Article 22 report with the ECB, where applicable with the central bank referred to in Article 20(4), and with the competent authorities of host Member States, so a single quarterly return already reaches several authorities.

Is a euro-denominated EMT inside the Article 22 quarterly return?

Article 22 reaches EMTs only through Article 58(3), which covers EMTs denominated in a currency that is not an official currency of a Member State, and CIR 2024/2902 is scoped the same way. A euro EMT is therefore outside the Article 22 templates. The EBA guideline templates follow their own triggers: the instructions for the own funds templates S 09.01 and S 09.02, for example, cover e-money institutions issuing significant EMTs and, where the competent authority requires it under Article 58(2), those issuing non-significant EMTs.

Our platform is outside the EU but lists an EU-issued dollar EMT. Does Article 22(3) apply to us?

Article 22(3) is addressed to crypto-asset service providers within MiCA’s scope. On my reading, a platform outside that perimeter is not a direct addressee, so an EU issuer that needs its holder or transaction data has to obtain it by contract. The EBA’s September 2026 response describes reliance on contracts with CASPs as a weaker basis even for data held by EU firms.

Does a stablecoin need to be large to count as global in the FSB’s sense?

The definition turns on existing or potential reach, so there is no size floor. Annex 3 of the 2023 recommendations lists potential elements for judging global status, including the number of jurisdictions with users, market share in cross-border payments and remittances, and redemption linked to a foreign currency or several currencies. The 2023 report also lets authorities apply relevant recommendations to stablecoin arrangements more widely, taking account of their size, complexity and risks.

Does the note cover algorithmic stablecoins or tokenised deposits?

The 2023 recommendations already deal with algorithmic designs: they state that algorithmic stablecoins do not meet Recommendation 9 because they do not use an effective stabilisation method. The October 2026 note does not discuss tokenised deposits; its analysis concerns stablecoins used across jurisdictions as a means of payment or store of value.

Where do payment services rules fit for an EU firm that transfers EMTs for clients?

That interplay sits outside the FSB note. In the EU, the EBA published an opinion on 12 February 2026 on the end of the transition period under its no-action letter on PSD2 and MiCA interplay, which ended on 2 March 2026, covering authorisation processes and conditions for continued EMT transactions. The FSB’s 2025 peer review also notes that EMT issuers are bound by reporting obligations under the payment services directive, including reporting on fraud events.

Can an issuer rely on a blockchain analytics vendor for holder location?

It can use one, but the FSB’s caution applies: compilers’ methods may vary in accuracy and transparency, and attribution, where possible, may not be verifiable. The 2025 peer review records that authorities in France, Nigeria, Singapore, Spain and the UK highlighted limitations in data from blockchain analytics firms and over-reliance on a small number of vendors. In CIR 2024/2902, the counts of non-custodial wallet holders in S 01.00 are reported as best-effort estimates, and S 04.04 carries the issuer’s methodology only for the non-custodial transaction and transfer estimates in S 04.03.

Related Articles

• MiCAR Token Classification: Reporting Obligations for ARTs, EMTs, and Utility Tokens: how the ART, EMT and utility token categories map to authorisation, reserve and reporting duties under MiCA.
• MiCA Review: The EBA’s Priorities for Token Issuers and CASPs: the EBA’s September 2026 consultation response, including its position on third-country multi-issuer schemes and reporting mandates.
• EBA-NYDFS Stablecoin MoU: What EU EMT Issuers Should Know: the information-sharing arrangement between the EBA and New York’s financial regulator, signed in April and May 2026 and published by the EBA in June 2026.
• FR UU Reporting: The Fed’s New Stablecoin Collection and FR Q Changes: the Federal Reserve’s proposed GENIUS Act reporting collection and its burden estimates.
• Hong Kong Stablecoins Ordinance: HKMA Grants the First Issuer Licences: the licensing regime in one of the jurisdictions the FSB peer review placed at the finalised stage.

Key Takeaways

• Treat the 12 October 2026 note as a statement of supervisory questions: it carries no binding effect, template or date.
• Multi-issuer groups: a per-entity map of which reserves back which holders is the artifact that answers the FSB’s warning on attribution of liabilities in stress and insolvency.
• EU ART and non-EU-currency EMT issuers above EUR 100 million already report holders by location in S 01.00; that breakdown is the existing anchor for the FSB’s holdings metric.
• Redemptions by geography and secondary-market depth have no Article 22 template, so the answers have to come from other records.
• CASPs: data an issuer needs beyond the ITS currently travels by contract, the link the EBA wants replaced by a MiCA reporting mandate.
• Under GENIUS Act section 18, foreign payment stablecoin issuers seeking the statutory exception must, once the relevant provisions take effect, generally hold sufficient reserves at a US financial institution to meet US customer liquidity demands, unless a qualifying reciprocal arrangement permits otherwise.
• Payment firms settling in stablecoins sit in two of the four spillover channels the FSB names: real-economy settlement dependencies and foreign exchange use.

Sources and References

• FSB, Global Stablecoin Arrangements: Cross-border vulnerabilities and financial stability monitoring (12 October 2026): FSB publication page and FSB (PDF)
• FSB, press release “FSB Chair sets out FSB work on AI and stablecoins” (12 October 2026): fsb.org
• FSB, Chair’s letter to G20 Finance Ministers and Central Bank Governors (dated 8 October 2026, published 12 October 2026): fsb.org and FSB (PDF)
• FSB, High-level Recommendations for the Regulation, Supervision and Oversight of Global Stablecoin Arrangements: Final report (17 July 2023), including Recommendations 3, 6, 7 and 9 and Annexes 2 and 3: FSB (PDF)
• FSB, Global Regulatory Framework for Crypto-asset Activities (17 July 2023): fsb.org
• FSB, Thematic Review on FSB Global Regulatory Framework for Crypto-asset Activities: Peer review report (16 October 2025), executive summary and sections 4 and 5: fsb.org and FSB (PDF)
• Regulation (EU) 2023/1114 on markets in crypto-assets (MiCA), including Articles 20, 22, 23, 35, 43, 45, 56, 58 and 126: EUR-Lex
• Regulation (EU) No 575/2013 (CRR), Part Six on liquidity, and Commission Delegated Regulation (EU) 2015/61 on the liquidity coverage requirement, for the LCR and NSFR treatment of reserve deposits: CRR on EUR-Lex and Delegated Regulation (EU) 2015/61 on EUR-Lex
• Commission Implementing Regulation (EU) 2024/2902 of 20 November 2024 on reporting related to ARTs and EMTs denominated in a non-EU currency (OJ L, 28.11.2024): EUR-Lex
• EBA, Implementing Technical Standards on the reporting on ARTs and EMTs denominated in a non-EU currency under MiCAR: EBA
• EBA, Explainer on MiCAR reporting templates (December 2024): EBA (PDF)
• EBA, Guidelines on templates to assist competent authorities in performing their supervisory duties regarding issuers’ compliance under MiCAR (EBA/GL/2024/16), Annex II instructions: EBA
• Commission Delegated Regulation (EU) 2025/298 of 31 October 2024 specifying the methodology for estimating means-of-exchange transactions involving ARTs and non-EU-currency EMTs (OJ L, 13 February 2025; in force since 5 March 2025): EUR-Lex
• EBA, Response to the European Commission’s targeted consultation on the review of MiCA (September 2026): EBA (PDF)
• EBA, Opinion on the supervisory priorities at the end of the transition period under the EBA’s No Action letter on the interplay between PSD2 and MiCA (EBA/OP/2026/01, 12 February 2026): EBA (PDF)
• EBA, Asset-referenced and e-money tokens (MiCA) page, including the Guidelines on liquidity stress testing (EBA/GL/2024/08): EBA
• EBA and NYDFS, Memorandum of Understanding on cooperation, exchange of information and coordination on stablecoin activities (June 2026): EBA (PDF)
• ESRB, Recommendation of 25 September 2025 on third-country multi-issuer stablecoin schemes (ESRB/2025/9) (OJ C, C/2025/6342, 21.11.2025), including Recommendation A and the timeline for the follow-up: EUR-Lex and ESRB (PDF)
• ESRB, press release on its crypto-asset report and Recommendation on third-country multi-issuer stablecoin schemes (ESRB/2025/9) (20 October 2025): ESRB
• Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act), Public Law 119-27, sections 3, 18 and 20: govinfo.gov

Holdings, redemptions and reserves by issuing entity

The note sets no deadline, so the operative output is internal: for each stablecoin issued, serviced or used for settlement, a reconciliation by issuing entity of holder location, redemption venue and reserve location, built where possible from the same records that feed the Article 22 templates. For EU participants in third-country multi-issuer schemes, the ESRB’s 31 December 2026 milestone is a follow-up reporting date for several recommendations addressed to public authorities, not a new firm implementation deadline. The EBA’s September 2026 consultation response records the related MiCA interpretation questions as unanswered at the time of that response.

Disclaimer: The information on RegReportingDesk.com is for educational and informational purposes only. It does not constitute legal, regulatory, tax, or compliance advice. Always consult your compliance officer, legal counsel, or the relevant supervisory authority for guidance specific to your institution.