The FSB Wants to Track Where Stablecoin Holders Are. Its Own Data Review Says That Is Often Not Possible.

A bank knows who its depositors are. It knows where they live, it can see its whole balance sheet, and when withdrawals start it can manage them with that picture in front of it. A global stablecoin issuer, the Financial Stability Board observes in a note published on 12 October 2026, may not know who holds its liabilities, where those holders are domiciled, or where redemption demand will come from.

That single contrast is the centre of the note. Everything else follows from it: liabilities that move freely across borders, reserves that stay put, legal protections tied to one jurisdiction, and supervisors trying to monitor a risk whose location they cannot always see.

The note also does something less common. It sets its vulnerability analysis next to a review of the data authorities would need to monitor those vulnerabilities, and the two sections do not quite meet. We've focused on that gap, and on the multi-issuer structure the FSB singles out as the hardest case.

Why this matters now

The note is short, and it is explicitly a summary of work in progress rather than new recommendations. It builds on the FSB's 2023 high-level recommendations for global stablecoin arrangements and its 2025 thematic peer review of how they have been implemented, and it is non-binding.

It arrives while one of the questions it raises is live in Europe. In October 2025 the European Systemic Risk Board recommended that the European Commission should not treat third-country multi-issuer stablecoin schemes as permitted under MiCA, and asked that safeguards be put in place if the Commission did not. In May 2026 the Commission opened consultations on its MiCA review, asking among other things how multi-issuer models should be treated and whether an equivalence regime for foreign frameworks should exist. That consultation closed at the end of September 2026, and the review report is due by mid-2027.

Liabilities travel. Reserves don't.

The FSB's core observation is an asymmetry. Stablecoin tokens are pseudonymous, globally accessible and transferable around the clock on secondary markets, so an issuer's liabilities are, in the note's words, internationally mobile and may be partly unobservable. The reserve assets backing them, and holders' legal protections, remain at least partly anchored in specific jurisdictions. Issuers design their programmes so that reserve and redemption undertakings are enforceable under at least one legal framework, and redemption and reserve management run on the operating hours and settlement practices of the markets where those reserves sit.

In normal conditions this works, and the FSB is careful to say that the same accessibility is part of what makes stablecoins potentially useful. Under stress, the asymmetry starts to matter. Secondary markets that never close can move faster than redemptions that depend on banking hours, putting pressure on the peg if redemptions cannot keep up. The note is balanced here too: deep secondary markets can also support arbitrage that pulls prices back toward par.

The transmission channels into the traditional system are the familiar ones, listed plainly: fire sales of reserve assets, bank deposit withdrawals to fund redemptions, dependence on a stablecoin used for real-economy payments, and foreign exchange markets where stablecoins carry cross-border flows.

The multi-issuer case is where the asymmetry bites hardest

The FSB gives one structure its own section. In a multi-issuer arrangement, affiliated issuers in different jurisdictions jointly share liability for a single stablecoin while holding separate reserves. A holder may be able to redeem with any of them.

The problem is what happens when redemption demand does not arrive where the reserves are. If holders can redeem with any issuer regardless of where their tokens were originally issued, demand could concentrate on one entity in the group. The arrangement relies on rebalancing reserves across borders and on secondary-market trading to bring flows and reserves back into line, and the FSB notes that both depend on reserve mobility, market access, information flows and coordination, all of which may break down under stress.

The note's sharpest sentence follows. If the location of some holders cannot be established, attributing liabilities to individual issuers, and establishing the legal claims of those holders, may be unclear in stress and in insolvency. That is a question of who owes what to whom, left open at the moment it most needs an answer. It is the same unresolved territory we covered when we asked what a stablecoin holder actually owns once the token is regulated, now with the added problem of not knowing which issuer's insolvency the holder is caught in.

It also explains why the European debate has focused on this structure specifically. When we looked at how MiCA regulates issuers rather than stablecoins, the underlying issue was the same: rules attach to legal entities, while a fungible token does not respect the boundaries between them.

The monitoring recommendation and the data review pull in different directions

This is the part of the note worth reading twice.

In its vulnerability section, 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 for multi-issuer arrangements.

In its data section, it says that a more structural challenge is the difficulty of attributing stablecoin activity to specific uses or geographies, that such attribution is often not possible because of the pseudonymity of public blockchain transactions and the smart contract infrastructure behind most stablecoins, and that where attribution is possible it may not be verifiable or reliable because the methods used are non-standard, proprietary or undisclosed.

Put side by side, the metric the FSB identifies as most important for the hardest case is the one its own data review describes as structurally difficult to produce. The note is honest about this rather than hiding it: it acknowledges that data gaps may exist in practice, and it separates structural constraints, such as pseudonymity, which are likely to persist, from more tractable ones, such as data that exists but is not disclosed, and inconsistent compilation methods.

The practical consequence is in who currently fills the gap. Authorities rely mostly on private compilers of stablecoin data, using proprietary methods that vary in accuracy and transparency, which improves access but creates comparability and credibility risks. The FSB notes that building in-house blockchain analytics may be a significant undertaking, particularly in emerging market and developing economies.

A small illustration of the data point

The note's own market figure is a useful example. It puts total stablecoin market value at around $300 billion as of mid-2026, essentially unchanged from a year earlier.

Other published figures tell a different growth story. A roundup by Reap, citing DefiLlama, put the market at roughly $313 billion in mid-2026, up about 23% year on year. Reporting by crypto.news in July 2026 cited about $309.7 billion, up from roughly $260 billion a year earlier. Transak, also citing DefiLlama, recorded about $308 billion at the end of 2025 and $316 billion in June 2026.

The levels are close. The trajectories are not: one source describes a flat year, others show growth of around a fifth. The FSB does not say which source its figure comes from, and we are not suggesting it is wrong. Market capitalisation is the simplest number in this market and it still depends on which tokens are counted, at what date, and by whom. That is precisely the comparability problem the note describes, in miniature.

What this means for each group

Issuers. Multi-issuer structures are the configuration supervisors are most focused on, and the questions they are asking are operational: where reserves sit, how quickly they can be moved, and how redemption demand would be routed under stress. In Europe, the treatment of these schemes is under active review.

Banks. The FSB names bank deposit withdrawals to fund redemptions as one of the transmission channels. Banks holding stablecoin reserve deposits are, by design, inside the channel through which stress would reach the traditional system.

Supervisors, particularly in EMDEs. The note says stablecoins could become systemic at a lower threshold of use in emerging and developing economies, because of currency substitution, bank disintermediation and capital flow management challenges, and that building blockchain analytics capacity may be hardest in exactly those jurisdictions.

Policymakers. The FSB points to three areas for continued work: better monitoring of cross-border vulnerabilities, cross-border cooperation and information-sharing to help regulatory frameworks interact, and gathering information on planning for the distress or failure of global stablecoin arrangements. It also states that the interaction of regulatory frameworks across borders, including the treatment of foreign-issued stablecoins, remains uncertain or undefined in many jurisdictions. Mapping that interaction jurisdiction by jurisdiction is part of why we maintain the free Stablecoin Regulation Tracker across 200+ markets.

Untested, and partly unobservable

The note closes its vulnerability analysis with a sentence that summarises the whole position: global stablecoins and national regulatory frameworks remain untested in severe stress and insolvency.

What makes that more than a routine caution is the data section that follows it. Supervisors are being asked to prepare for a stress event whose most important variable, where the holders actually are and where they will try to redeem, is the one the public blockchain is structurally designed not to reveal. The tractable parts of the problem are real: better disclosure, common data standards, and shared methods can all narrow the gap. But the FSB is clear that some of it will persist, and the multi-issuer case shows why that matters. A reserve can be counted and audited. A holder who cannot be located cannot be counted at all, and in insolvency that is the difference between a claim and a question.

Source: Global Stablecoin Arrangements: Cross-border vulnerabilities and financial stability monitoring, Financial Stability Board, 12 October 2026. The note summarises ongoing FSB work and is not binding.

Additional data: ESRB Recommendation ESRB/2025/9 on third-country multi-issuer stablecoin schemes, published 20 October 2025, as reported by the Banque de France. European Commission MiCA review consultation, opened May 2026 with responses extended to the end of September 2026 and a review report due by mid-2027, as reported by Crowdfund Insider. Market capitalisation figures from Reap (mid-2026, citing DefiLlama), crypto.news (July 2026) and Transak (June 2026, citing DefiLlama).

Methodology: We focused on the relationship between the note's two sections, its vulnerability analysis and its data review, and on the multi-issuer configuration. The observation that the monitoring metric it recommends for multi-issuer arrangements is one its data review describes as structurally difficult to produce is our reading of the note, not a claim the FSB makes. The market capitalisation comparison is ours; the note does not identify the source of its figure.

This article is for informational purposes only and does not constitute financial, investment, or legal advice.