TLDR
- The IMF released new guidelines warning that fragmented stablecoin regulations across countries create risks to financial stability and cross-border payments
- The global stablecoin market is worth over $300 billion, with USDT and USDC dominating and holding reserves mostly in short-term U.S. Treasury bills
- Different countries treat stablecoins as securities, payment instruments, or leave them unregulated, creating regulatory arbitrage opportunities
- Foreign currency stablecoins can weaken domestic monetary control and accelerate digital dollarization in developing economies
- The IMF recommends harmonized definitions, consistent reserve rules, and the principle of “same activity, same risk, same regulation” for all issuers
The International Monetary Fund released a comprehensive assessment of the stablecoin market on Thursday. The report warns that inconsistent regulations across countries are creating structural problems for financial oversight and cross-border payments.
Stablecoins have the potential to reshape cross-border payments and capital flows. They offer opportunities, but also bring new risks—financial integrity, regulatory oversight, consumer protection, capital flow management, monetary sovereignty, and more. Learn more:… pic.twitter.com/cOlZKuqLDF
— IMF (@IMFNews) December 4, 2025
The report titled “Understanding Stablecoins” examined regulatory approaches in the United States, United Kingdom, European Union, and Japan. The IMF found that national frameworks remain widely inconsistent.
Some countries classify stablecoins as securities. Others treat them as payment instruments or only permit bank-issued tokens. Large portions of the market remain unregulated in certain jurisdictions.
The IMF stated this regulatory patchwork allows stablecoins to move across borders faster than oversight can follow. Issuers can operate from lightly regulated jurisdictions while serving users in stricter markets. This limits authorities’ ability to monitor reserves, redemptions, and anti-money laundering controls.
The global stablecoin market is now worth more than $300 billion. Tether’s USDT and Circle’s USDC represent the majority of that supply. About 97% of all stablecoins are denominated in U.S. dollars.
Reserve Concentration in Treasury Markets
Circle holds approximately 40% of USDC reserves in short-term U.S. Treasury bills. Tether holds roughly 75% of USDT reserves in short-term treasuries, with another 5% in Bitcoin. This concentration links stablecoins directly to traditional financial systems.
The IMF warned that large-scale redemptions could force rapid sales of Treasury bills and repo assets. This could disrupt short-term funding markets that are critical for monetary policy transmission.
The fund identified currency substitution as a major risk. Widespread use of foreign-currency stablecoins can weaken domestic monetary control and lower demand for local currency. This process accelerates digital dollarization in developing regions.
Stablecoin holdings in Africa, the Middle East, Latin America, and the Caribbean are rising relative to foreign exchange deposits. These deposits help central banks influence monetary policy. The IMF noted that stablecoins can penetrate economies rapidly through internet access and smartphones.
Cross-Border Risks and Policy Recommendations
The IMF said stablecoins make it easier to bypass capital controls through unhosted wallets and offshore platforms. A central bank would have less control over domestic liquidity and interest rates if economic activity transitions away from the local currency.
The fund released new global policy guidelines to address these risks. It called for harmonized definitions of stablecoins and consistent rules for reserve assets. The IMF said issuers should follow the principle of “same activity, same risk, same regulation.”
The guidelines state that stablecoins should be backed only by high-quality liquid assets. Short-term government securities should make up the bulk of reserves with strict limits on risky holdings. Issuers must guarantee full one-to-one redemption at par on demand at all times.
The IMF also called for strong international coordination on anti-money laundering enforcement. Licensing and supervision of large global stablecoin arrangements should be standardized across jurisdictions.
The report noted technical fragmentation as another concern. Stablecoins operate across different blockchains and exchanges that are not always interoperable. This lack of coordination raises transaction costs and creates barriers to efficient global payments.
The European Central Bank warned in November that dollar-denominated stablecoins could cause retail deposit outflows from banks. The Bank of England and Basel regulators are reassessing how banks should hold capital against stablecoin exposure.
China’s central bank has described stablecoins as a threat to financial stability and monetary sovereignty. The European Systemic Risk Board has called for urgent safeguards against cross-border stablecoin structures operating under the EU’s MiCA framework.
U.S. Treasury Secretary Scott Bessent said earlier this year that stablecoin legislation could create new demand for government debt. He stated this could lower government borrowing costs and onramp millions of new users to the dollar-based digital asset economy.
Get 3 Free Stock Ebooks
Discover top-performing stocks in AI, Crypto, and Technology with expert analysis.
- Top 10 AI Stocks - Leading AI companies
- Top 10 Crypto Stocks - Blockchain leaders
- Top 10 Tech Stocks - Tech giants
