FSB Warns Stablecoins Untested in Crisis, Calls for Cross-Border Cooperation
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- Financial Stability Board menilai stablecoin belum pernah melewati ujian tekanan pasar ekstrem maupun kebangkrutan penerbit.
- Koordinasi antarnegara masih minim, sementara aturan domestik bergerak dengan kecepatan berbeda-beda.
- Rekomendasi FSB tidak mengikat secara hukum, tetapi menjadi acuan bagi negara G20 untuk menyusun regulasi domestik.
The Financial Stability Board (FSB) has highlighted gaps in cross-border rules that could open up when the stablecoin market is hit by a crisis. In its latest report, the financial watchdog for G20 countries assessed that stablecoins—crypto tokens whose value is pegged to fiat currencies—have never been tested under severe stress or issuer insolvency. The warning comes just days before the meeting of G20 finance ministers and central bank governors on 15 October.
The FSB's main concern is not the size of the market capitalization, but the ecosystem's lack of readiness in the event of a default. The market value of stablecoins surged from around US$206 billion in early 2025 to US$306 billion, with the majority denominated in US dollars. Most of those funds are used to move in and out of crypto investment positions, but in the future stablecoins could become a faster and cheaper means of cross-border payment. Unfortunately, regulatory frameworks in each country are developing at uneven speeds, raising a fundamental question: how can token holders withdraw their funds if the issuer collapses?
FSB Chair Andrew Bailey, who is also Governor of the Bank of England, stressed that the stablecoin architecture is inherently cross-border. "Global stablecoin arrangements are inherently cross-border, yet national regulations are taking shape at different speeds and cross-border cooperation in this area is still in its infancy," he wrote in the report's cover letter. This means that although tokens can move across jurisdictions in seconds, the rules that bind them remain fragmented and cross-border cooperation is still at an early stage.
The FSB report highlights specific risks in multi-issuer structures. Affiliated companies can issue the same stablecoin and share responsibility, while reserve assets are held in different jurisdictions. If token holders can redeem from any issuer in the group, demand could pile up on one entity, while the assets needed are elsewhere. In a crisis situation, moving reserves becomes far more difficult. Legal claims can also become murky if an issuer fails, because it is unclear which country's insolvency rules apply.
Stablecoins can be traded 24 hours a day, while the markets for the underlying assets have limited operating hours. This timing mismatch can worsen panic when redemptions cannot keep pace with selling, potentially causing the token to lose its value peg.
The FSB also noted that deep and liquid secondary markets can help pull the token price back to its peg through arbitrage. However, if panic occurs, forced sales of reserves and bank deposit withdrawals can spread shocks to traditional financial markets. Investors seeking liquidity will rush to withdraw funds, amplifying systemic pressure.
Another problem is weak data. The pseudonymous nature of crypto transactions makes it difficult for authorities to identify the domicile of token holders and the applicable jurisdiction. Without adequate data, cross-border supervision becomes ineffective. The FSB urged improved information sharing, monitoring, and planning to handle distress or failure conditions of stablecoins.
Although the FSB recommendations have no legal force, G20 member countries are generally committed to implementing the agreed standards into national regulations. Bailey had previously warned that the formulation of international stablecoin rules had stalled. This report signals that pressure to accelerate regulatory harmonization is growing.
For Indonesia, this development is relevant even though the domestic stablecoin market is still small. Bank Indonesia and OJK are drafting a regulatory framework for crypto assets, including stablecoins, which will affect the fintech and cross-border payments industry. If stablecoins are increasingly used for remittances or international trade, Indonesia needs to ensure consumer protection and financial system stability remain intact. Cooperation with international forums such as the FSB is key so that domestic rules do not fall behind.
Going forward, the big question is no longer whether stablecoins will be more widely adopted, but how ready the global legal and supervisory infrastructure is to face the worst-case scenario. If a crisis occurs before the cross-border framework matures, who will bear the losses—the issuer, the token holders, or the broader financial system?
