FSB kicks off new implementation phase to enhance cross-border payments through public-private partnership

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Ref: 3/2026

  • At the FSB Cross-border Payments summit, FSB Chair Andrew Bailey renews commitment to the goals of the G20 Roadmap for Enhancing Cross-border Payments, urging intensified action from authorities and the industry.
  • The FSB will ask its members to develop action plans, identifying practical steps and priorities for enhancing payment systems within their jurisdictions and at broader regional level.
  • The Institute of International Finance and Swift also outlined initiatives aimed at supporting progress towards the Roadmap’s goals.

The Financial Stability Board (FSB) held the FSB Cross-border Payments Summit today in London to take stock of efforts to make cross border payments cheaper, faster, more transparent and more accessible. Hosted by the Bank of England, the Summit brought together senior policymakers and industry leaders to kick off a new implementation phase of the work.

“There are few issues in our responsibilities that have as universal a reach as cross‑border payments”, said Andrew Bailey, Chair of the FSB, in his opening speech. “The clear message from today’s Summit is that we are not stopping until the job of making a genuine difference to the user experience of cross-border payments is done. Strong commitment and collective action from both the public and private sector are essential for delivering on the Roadmap’s goals.”

The next phase of work will focus on two key aspects: encouraging the development of jurisdictional and regional action plans by public authorities to drive domestic and regional implementation; and the promotion of private-sector action and closer private-public collaboration, with industry playing a decisive role in delivering real benefits for end users.

At the Summit, participants discussed public and private-sector initiatives undertaken so far to advance the Roadmap’s goals, explored ways to accelerate implementation to ensure progress as the end-2027 deadline approaches, and discussed the future of the cross-border payments ecosystem.

The Institute of International Finance (IIF) committed to working with its members throughout 2026 to assess how the external environment has changed since the Roadmap was first published in 2020 and how the Roadmap may need to evolve in response. “The operating environment has shifted, and progress has been made in important areas of cross-border payments”, said Tim Adams, CEO of the IIF. “We have new options for sending payments, enabled by new technologies, while, at the same time, growing payments fraud requires security to retake a prominent place in the agenda.” The IIF will produce a report later this year with the findings of its assessment and industry recommendations for a path forward for the G20 cross-border payments agenda. The IIF will convene stakeholders alongside the upcoming IMF and World Bank Spring Meetings to kick off this work.

Swift is driving global industry action. Currently, 75% of payments reach beneficiary banks in just 10 minutes, with many arriving in seconds. Last week, Swift announced that banks would introduce a new retail payments framework by June, ensuring consumer payments over Swift benefit from the fastest possible speeds, cost certainty and end-to-end transparency. In parallel, Swift is creating infrastructure for the future by integrating a shared, blockchain-based ledger, initially targeting 24/7 real-time cross-border payments. Javier Pérez-Tasso, CEO of Swift, said: “We’ve driven significant improvements since the G20 targets were introduced, especially between banks. And now we’re taking that a step further, innovating and collaborating with both the public and private sectors to drive unified action on improving the end-to-end payments experience.”

“Without genuine public-private collaboration, the G20 Roadmap risks remaining just an agenda. Our goal is real-world outcomes, at system level”, emphasised Fabio Panetta, Governor of the Bank of Italy and Co-Chair of the FSB’s Cross-border Payments Coordination Group, in his closing remarks, Mr Panetta underscored the importance of joint action to modernise payment infrastructures, foster greater harmonisation and interoperability, and leverage technology to enhance transparency and compliance automation. “We should never lose sight of the human dimension: every improvement in speed, transparency and cost efficiency translates into meaningful and tangible enhancements to people’s lives. That is a key reason why this work matters.”

Notes to editors

In 2020, the FSB, in coordination with the CPMI and other relevant international organisations and standard-setting bodies, developed the G20 Roadmap to enhance cross-border payments, at the request of the Saudi Arabian G20 Presidency. In 2023, the FSB, in collaboration with the CPMI, prioritised the actions that were considered to be most impactful in progressing towards the G20 Roadmap goals, with the aim of achieving significant improvements by the end of 2027.

The FSB coordinates at the international level the work of national financial authorities and international standard-setting bodies and develops and promotes the implementation of effective regulatory, supervisory, and other financial sector policies in the interest of financial stability. It brings together national authorities responsible for financial stability in 24 countries and jurisdictions, international financial institutions, sector-specific international groupings of regulators and supervisors, and committees of central bank experts. The FSB also conducts outreach with approximately 70 other jurisdictions through its six Regional Consultative Groups.

The FSB is chaired by Andrew Bailey, Governor of the Bank of England. The FSB Secretariat is located in Basel, Switzerland and hosted by the Bank for International Settlements.

Reforming Cross-border payments: keynote speech at the FSB Payments Summit

Keynote speech by Andrew Bailey, Chair of the Financial Stability Board, at the FSB Payments Summit, Bank of England, Thursday 12 March 2026.

The views expressed in these remarks are those of the speaker in his role as FSB Chair and do not necessarily reflect those of the FSB or its members.

Good morning and welcome to the Bank of England. It is our pleasure to host this important event. This is the third Financial Stability Board (FSB) Payments Summit, but the first to be held in person. As Chair of the FSB, can I thank you for joining us. I think it is very much the right time to meet in person as we have reached an important point in this critical work.

I have two goals in mind for today. First, to recognise the very good work that has taken place over the last few years. Second, to start to firm up what more we need to do to achieve the G20’s goals on cross-border payments.1 And, by “we” I mean the private sector as well as the public authorities and international bodies. Moreover, as a spoiler, and I am going to be quite clear and honest, we have some tough challenges ahead. They are ones that we must take on because they are so important, not just to the financial system but for billions of people around the world – indeed, in all parts of the world. There are few issues in our responsibilities that have as universal a reach as cross-border payments.

For as long as I can remember – and I have been here at the Bank over 40 years – it has been said that cross-border payments are slow, expensive and inefficient. While this is not universally true – some cross-border payments are very efficient – there can be no doubt that, overall, cross-border payments are slow and expensive, especially when compared to increasingly effective domestic payments. So, when I became Chair of the FSB last year, I identified cross-border payments as a continuing key priority. To be clear, what I mean by “continuing” is that we are not stopping until the job is done. Moreover, I added that there are several big reasons why the issue is important. One of those is that frictions in international payments have the potential to act as a driver of fragmentation of the global system, and this can ultimately reduce the system’s ability to absorb shocks and support sustainable economic growth. Another reason is that when I am asked to describe what we do at the Bank of England, I usually start by saying that we are in the money business. Money is the common factor in the things we do. Well, payments are a core function of money, so they are central to our interests.

With all of this in mind, the state of affairs on cross-border payments leaves me with three big, framing questions. Why is it proving to be so challenging? Are the problems insurmountable (this is something I seriously doubt, but it has to be asked)? And what are the root causes of the remaining problems?

Now, I do not want to come across as negative on what has been done so far. Quite the opposite. I am hugely positive about the work done and want to praise everyone involved. You have changed things for the better. Rather, I think the reality is that in doing this excellent work, you have uncovered more issues that need tackling. Again, well done, this needed doing. But, we can’t stop here. Today is about focusing on the remaining challenges and starting to identify the steps we – public authorities and the private sector – need to take to finish the job of making a genuine difference to the user experiences of cross-border payments.

In taking stock, it’s worth going back to the creation of the G20 Roadmap, which was launched in October 2020. It brought together many official bodies – domestic and international – and the private sector to energise the case for reforming and enhancing cross-border payments. To quote from the launch material, it set the objective of:

“Faster, cheaper, more transparent and more inclusive cross-border payment services, including remittances, while maintaining their safety and security, would have widespread benefits for citizens and economies worldwide, supporting economic growth, international trade, global development and financial inclusion.”

Nothing has changed, in that these remain our objectives. But the world has changed since 2020, far more than the architects of the Roadmap could have imagined. The geopolitical landscape looks different and technological innovation has accelerated. Both of these developments serve to emphasise the importance of achieving reform of cross-border payments while maintaining and enhancing their safety and security. The emphasis on safety and security also serves as a reminder that, sadly, developments since 2020 underline the increasing sophistication of threats from criminal actors. On this point, I welcome the US G20 Presidency’s prioritisation of work on cross-border payments fraud. In the FSB, we look forward to continuing to work with the Financial Action Task Force on these issues.

Over five years on from the launch of the Roadmap, most of the priority actions identified have been completed. We can point to real wins: ISO 20022 harmonised requirements2 (which smooths the flow of cross-border payments through more consistent transaction data); extending RTGS (Real Time Gross Settlement) operating hours to increase time zone overlaps (so that we’re open for business at the same time and can settle payments more quickly); and FATF’s revision of standards for the information that must accompany a cross-border payment for Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) purposes (to ensure that these rules take account of developments in technology).

And we have seen some progress in the results of the most recent cross-border payments monitoring survey, published by the CPMI (Committee on Payments and Market Infrastructure) in December. That report shows that over half of jurisdictions are already operating with extended RTGS operating hours, or actively planning or considering an extension – a notable increase from the previous survey. More than three quarters of faster payment systems covered by the survey, and approaching half of RTGS systems, are now using ISO 20022. If the payment systems that are considering or planning on aligning with the CPMI’s harmonised ISO 20022 data requirements follow through with their plans, around two thirds of FPS (Faster Payment Systems) and RTGS systems could align with the requirements in the next few years – a huge step forward from where we were. Certain regions – in particular Asia-Pacific – have driven forward initiatives to interlink faster payment systems. Together interlinking arrangements cover around 17 bilateral corridors, with more links planned to go live. I want to particularly thank the CPMI for leading important parts of the work.

The bottom line then is that much of what we set out to do in terms of producing guidance and recommendations for upgrading payments systems and harmonising standards has been done at the international level. But more needs to be done now to implement. This is echoed in some tough messages from the monitoring survey. For example, only around one third of jurisdictions have implemented or reformed data privacy legislation or frameworks that may help mitigate data-related frictions in cross-border payments. There remains patchy adoption of Legal Entity Identifiers (LEIs), which would benefit cross-border payments by strengthening data standardisation and assisting KYC (know your customer) and sanctions screening. More importantly, the data show limited improvement to date in cross-border payments for end users.

In total then, while we have done a lot at the international level, ultimately we are far from reaching the targets the G20 set for 2027.

To come back to one of my key questions, does this mean the challenges are insurmountable? No, definitely not. To some degree, we can explain that the benefits of what has been done to date will take time to materialise. But that is not the full picture. The reality is that there is more we need to do to spur further action to tackle the remaining sources of friction in cross-border payments. As I said earlier, the great work done to date has revealed more issues, and so there is a gap between aspiration and achievement to date.

We stand therefore at a critical point. Over the coming year, we need to intensify efforts to drive the implementation of agreed guidance and recommendations as part of efforts to meet the G20 goals, and not just across the G20 but much more widely. I feel strongly about this as FSB Chair and have an eye towards the UK’s G20 Presidency next year as well.

Now, if you are a film buff, you may be worried that in setting this out, I am going to make the rest of my remarks in the style of the quite famous speech by Al Pacino in “Any Given Sunday”. If you aren’t familiar with it, look it up, it’s a classic.

I’m not going to do that – I will be more polite! More to the point, I am going to set out the key areas of focus. Critically, this involves international organisations, domestic public bodies (not just central banks) and the private sector. There are four important elements.

First, we are announcing today that the public sector should develop:

  • A review of implementation of FSB recommendations on data frameworks and bank and non-bank regulation and supervision, which will take place early in 2027.
  • Jurisdiction Action Plans – as a tool to support domestic implementation of international recommendations and guidance. Improving domestic payment infrastructure, in the widest sense, is critical for enhancing cross-border payments, as the first and last mile rely on domestic rails.
  • Regional Action Plans – different regions started from different baseline conditions and are progressing along diverse paths and at varying paces. But more can be done to support implementation at a regional level and we have already seen some advancements in payment systems interoperability and extensions at the regional level, including by fostering regional integration. This includes working with the World Bank and IMF to ensure Technical Assistance programmes deliver – this is critical to ensuring greater take up of the recommendations and tackling frictions in the domestic leg of cross-border payments.

Second, we need to emphasise further innovation and infrastructure development. This should build on the adoption of ISO and APIs (Application Programming Interface) and the extension of RTGS operating hours. It could be public or private sector infrastructure. And the infrastructure upgrades which give us biggest ‘bang for our buck’ may be different across retail and wholesale systems. Most important, we need to make sure that the benefits of digital technology are incorporated into payment systems. Again, we should start by being open to how this is done, but respecting the central principles of what is money. And that includes thinking about what role there could be for new innovations in digital payments in helping us to reach the Roadmap’s goals. I do not take a position on that, but I think it makes sense to include it in our analysis.

Third, we need to reduce regulatory compliance costs but without diluting standards. Work on the Roadmap has identified multiple sources of regulatory frictions in cross-border payments and started to address some of them. But further work could usefully help us (authorities) determine the extent to which these frictions are warranted or where the same objectives can be achieved more efficiently, for example through greater consistency across jurisdictions or by deploying new technology. BIS Innovation Hub experiments like Project Mandala3 show this is a real possibility. I am sure technology can be put to work to help us.

Fourth, we need strong commitment and collective action from the private sector. We have had a lot of important insights and recommendations from industry on technical and regulatory issues, for which I am very grateful. What we need now is practical and coordinated action. There are plenty of live examples of innovation in both retail and wholesale cross-border payments, including initiatives by firms represented here today. They are very welcome and we will hear more about some of these later. The question is whether they are enough or are there actions that industry could take today, including individually, to move us towards the goals of addressing cost and transparency, for example? My sense is that there are things that can be done now by firms, but some form of collective action will also be necessary to move the dial on cross-border payments from the perspective of end users.

Now, we need to work together closely to deliver improvements. A closer public-private partnership to guide the next steps will ensure that as we move forward, we focus on the right issues, prioritise what matters most, and identify deliverable actions for the private sector as well as public authorities and international bodies. Ultimately, leadership from the private sector is critical to unlocking progress to deliver cheaper, faster, more inclusive and more transparent cross-border payments.

That’s why I’m particularly pleased that both Swift and the Institute of International Finance (IIF) are here today. Their respective memberships are critical players in thework we need to do to enhance cross-border payments and we will hear from both on important initiatives they are planning.

To conclude, and return to my key questions. We have made a lot of progress, but have found there is more to be done. That’s frustrating, but we must take the challenge on. We can’t say “job done”. It isn’t. I don’t believe the remaining challenges are insurmountable. In this day and age with the technology we have and will be getting, that would be an extraordinary conclusion. There isn’t a quick win either. Nor do I think we have reached the point where we have to consider trade-offs, for instance between cost and speed.

We have plans, ambitious ones. They are not going to be easy, let’s be honest about that. But let’s always remember, by working together we can benefit, literally, billions of people, including many on low incomes who deserve better from payment services.

Thank you for being part of this important work.

  1. FSB (2020), FSB delivers a roadmap to enhance cross-border payments, October. ↩︎
  2. CPMI (2026), Harmonised ISO 20022 data requirements for enhancing cross-border payments – updated report, February. ↩︎
  3. BIS, Project Mandala: shaping the future of cross-border payments compliance. ↩︎

Thematic Peer Review on Public Sector Backstop Funding Mechanisms: Summary Terms of Reference

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The Financial Stability Board is seeking feedback from stakeholders as part of its thematic peer review on the implementation of public sector backstop funding mechanisms.

The FSB adopted the Key Attributes of Effective Resolution Regimes for Financial Institutions in 2011, with the aim of facilitating the resolution of financial institutions without severe systemic disruption or taxpayer losses, while protecting vital economic functions. One element of an effective resolution regime is a public sector backstop funding mechanism, which, if needed as a last resort, can provide temporary funding to firms in resolution to support orderly resolution.

The objective of the review is to examine progress made by FSB member jurisdictions in implementing Key Attribute 6 and the Guiding Principles on the Temporary Funding Needed to Support the Orderly Resolution of a Global Systemically Important Bank (“G-SIB”). The Summary Terms of Reference provides more details on the objectives, scope, and process for this review.

The FSB has distributed a questionnaire to FSB member jurisdictions to collect information. In addition, as part of this peer review, the FSB invites feedback from financial institutions, industry and consumer associations, academics, and other stakeholders on the implementation of public sector backstop funding mechanisms. This could include comments on:

  • how financial stability vulnerabilities associated with the liquidity needs of a G-SIB, or banks that may be systemically significant or critical if they fail (“banks systemic in failure”), during resolution differ across jurisdictions, and how these vulnerabilities are evolving;
  • the nature, credibility, and capabilities of public sector backstop funding mechanisms for banks in FSB jurisdictions, including:
    • the key design features of public sector backstop funding mechanisms to ensure their temporary, last-resort use to achieve an orderly resolution of a G-SIB or banks systemic in failure;
    • the conditions and provisions that mitigate taxpayer losses and minimise moral hazard risk;
  • experiences and challenges in addressing funding in resolution, and implications for public sector backstop funding mechanisms.

The peer review report is expected to be published in October 2026.

FSB Regional Consultative Group for Sub-Saharan Africa meets in Zanzibar

FSB Regional Consultative Group for Sub-Saharan meeting, 20-21 February 2026, Zanzibar, Tanzania
FSB Regional Consultative Group for Sub-Saharan meeting, 20-21 February 2026, Zanzibar, Tanzania

The Financial Stability Board (FSB) Regional Consultative Group for Sub-Saharan Africa (RCG SSA) met on 20-21 February in Zanzibar, hosted by the Bank of Tanzania. The meeting brought together senior officials from central banks, financial authorities, and regulatory bodies in the region to discuss key financial stability topics.

The meeting, co-chaired by Lesetja Kganyago, Governor of the South African Reserve Bank, and Denny Kalyalya, Governor of the Bank of Zambia, covered a range of topics, including global and regional financial vulnerabilities, non-bank financial intermediation (NBFI), the impact of debt and foreign exchange market strains on financial stability, and the use of artificial intelligence (AI) in finance. Members also discussed the FSB’s 2026 work programme.

Public responses to consultation on Scope of Insurers Subject to the Recovery and Resolution Planning Requirements in the FSB Key Attributes

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On 25 November 2025, the FSB published Scope of Insurers Subject to the Recovery and Resolution Planning Requirements in the FSB Key Attributes: Consultation report. Interested parties were invited to provide written comments by 6 February 2026. The public comments received are available below.

The FSB thanks those who took the time and effort to express their views. The FSB expects to publish the final guidance in Q2-Q3 of this year.

Strategic review of FSB crisis preparedness activities

Supporting member authorities in strengthening their crisis preparedness is a pillar of the FSB’s mandate to promote global financial stability.

Over 15 years of standard-setting by the Financial Stability Board (FSB), anchored in the Key Attributes of Effective Resolution Regimes for Financial Institutions and sectoral guidance, has laid a solid foundation for addressing financial crises. Several periods of turmoil have tested the resolution framework since its initial adoption in 2011.

These episodes highlighted its significant benefits but also uncovered gaps in the framework and its implementation, underscoring the need for better integration with broader crisis preparedness activities. A resilient global financial system depends on the ability of authorities to respond swiftly and effectively to financial institution distress or sectoral disruptions. This, in turn, requires thorough preparation by both authorities and financial institutions in advance of any potential failure.

The strategic review aims to:

  • strengthen and, where necessary, adapt the FSB’s crisis preparedness activities to respond to changes and emerging vulnerabilities in the global financial system, drawing on lessons learnt from the crises that have occurred since the FSB’s formation in 2009.
  • enhance the FSB’s crisis preparedness activities to consider all stages of a crisis, from early intervention measures through recovery and resolution to post-stabilisation restructuring.
  • refine internal processes and organisational structure to achieve the FSB’s strategic objectives for crisis preparedness.
  • strengthen the central role of the Key Attributes of Effective Resolution Regimes for Financial Institutions as the international standard for resolution regimes for financial institutions.

The FSB has appointed Andrea Enria, former Chair of the Supervisory Board of the European Central Bank and the first Chair of the European Banking Authority, to lead a high-level group who will conduct the strategic review of the FSB’s crisis preparedness activities. On his appointment, Mr Enria said, “The ability to manage crises effectively is not just a technical requirement but a cornerstone of global financial stability. I am honoured to chair this strategic review of the FSB’s crisis preparedness activities, which aims to ensure that the crisis management framework remains credible and fit for purpose.”

Vulnerabilities in Government Bond-backed Repo Markets

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Given the importance of repo markets within the global financial system, it is critical that their functionality is preserved, particularly during times of stress.

Repo markets play an important role in facilitating the flow of cash and securities throughout the financial system. They allow some market participants to source required short-term funding or collateral and others to undertake short-term, low-risk investment of cash. At the same time, the structure and use of repo markets give rise to vulnerabilities. Borrowing through repo markets enables leverage, can lead to over reliance on short-term funding, and facilitates greater liquidity and maturity transformation. Additionally, repo markets serve as a key channel through which the financial system is interconnected. Recent stress events have highlighted how these vulnerabilities could amplify shocks quickly across the financial system.

This report assesses vulnerabilities in government bond-backed repo markets and possible contagion channels to the broader financial system

The report explains how repo markets function, outlines key features of repo markets around the world, assesses ways to monitor vulnerabilities and associated data gaps, and concludes with relevant policy implications.

FSB warns of financial stability challenges in repo markets

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Ref: 2/2026

  • Repo markets are critical to the functioning of the global financial system and have been involved in several recent episodes of stress, including the March 2020 dash for cash and September 2022 gilt market episode.
  • Report warns that leverage, demand and supply imbalances, and high levels of concentration within repo markets have the potential to create strains.
  • Report calls on authorities to consider actions to close data gaps, strengthen surveillance, and address vulnerabilities around the build-up of liquidity imbalances and leverage.

The Financial Stability Board (FSB) today published a report on Vulnerabilities in Government Bond-backed Repo Markets.

Repo markets play an important role in facilitating the flow of cash and securities throughout the financial system. The report focuses on the repo markets backed by government bond collateral as this makes up the vast majority of collateral used by market participants. The report estimates that approximately $16 trillion in repo trades backed by government bonds were outstanding, representing around 80% of the total stock of all repo trades, at end-2024.

The report highlights how quickly repo markets were impacted in several recent episodes of market stress and warns that, given the importance of repo markets within the global financial system, it is critical to preserve their functionality, particularly during periods of stress.

The report identifies several vulnerabilities within repo markets that could pose risks to the broader financial system. First, repo markets can facilitate the build-up of leverage in the financial system. Approximately 70% of activity in the non-centrally cleared segment operates with zero haircuts and there are high levels of collateral rehypothecation. Second, demand and supply imbalances can arise quickly in periods of stress if repo lenders are unwilling or unable to provide funds to meet spikes in the demand for liquidity. Third, repo markets are highly concentrated along various dimensions. This concentration could lead to disruptions in the event of failures.

The core nature of repo markets may act as a conduit through several channels in spreading shocks across the financial system. Strains in repo and government bond markets may spill over into each other or across multiple jurisdictions, given the international nature of repo markets. If haircuts are insufficient, they further expose lenders to leveraged counterparties, amplifying risks across the financial system.

The report outlines several measures for authorities to consider in response to these vulnerabilities, including closing data gaps, strengthening surveillance capabilities, and addressing vulnerabilities related to liquidity imbalances and leverage by taking into account the FSB’s recommendations on leverage in nonbank financial intermediation (NBFI) and Global Securities Financing Transactions exercise, as well as other relevant international standards.

Notes to editors

This report forms part of the FSB’s work programme to enhance resilience in NBFI. Further details on this can be found in its latest progress report.

The FSB coordinates at the international level the work of national financial authorities and international standard-setting bodies and develops and promotes the implementation of effective regulatory, supervisory, and other financial sector policies in the interest of financial stability. It brings together national authorities responsible for financial stability in 24 countries and jurisdictions, international financial institutions, sector-specific international groupings of regulators and supervisors, and committees of central bank experts. The FSB also conducts outreach with approximately 70 other jurisdictions through its six Regional Consultative Groups.

The FSB is chaired by Andrew Bailey, Governor of the Bank of England. The FSB Secretariat is located in Basel, Switzerland and hosted by the Bank for International Settlements.

FSB Work Programme for 2026

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The 2026 work programme reflects the FSB’s commitment to fostering global financial stability by addressing systemic risks, modernising financial regulation, and enhancing resilience in an evolving economic and financial environment.

In 2026, the FSB will continue its mission to promote global financial stability by addressing systemic financial risks and fostering international cooperation. The work programme outlines key priorities, including:

  • Vulnerabilities assessments
  • Nonbank financial intermediation (NBFI)
  • Cross-border payments
  • Digital innovation and Artificial Intelligence
  • Operational resilience through public-private-sector collaboration
  • Modernisation of financial regulation and supervision
  • Crisis preparedness and resolution frameworks
  • Monitoring implementation of agreed reforms
Indicative timeline for key FSB work and external events planned for the remainder of 2026

Date

Work Programme Item

February

Report on vulnerabilities in government bond-backed repo markets

March

Payments Summit

FSB Annual Report

April

Public-private sector event on payments fraud

May

Report on vulnerabilities in private credit

June

Roundtable on audit quality and structural shifts in the global audit industry

Symposium on regulatory and supervisory modernisation issues and cost-benefit analysis

October

Implementation monitoring review: Report on the impact on implementation of FSB Recommendations

Report on regulatory and supervisory modernisation initiatives

Report on sound practices for AI adoption, use, and innovation

Summary of targeted analysis of critical cross-border issues in digital assets

Thematic peer review on public sector backstop funding mechanisms

Cross-border payments annual progress report (including KPI results)

November

Türkiye country peer review

2026 G-SIB list

List of insurers subject to Key Attributes resolution planning standards

December

Nonbank financial intermediation Global Monitoring Dashboard

“Sense and Sensibility” in nonbank regulation: a thoughtful approach to nonbank financial regulation

Speech by John Schindler at a seminar hosted by Volatility and Risk Institute and Center for Global Economy and Business, Stern School of Business, New York University.

The views expressed in these remarks are those of the speaker in his role as FSB Secretary General and do not necessarily reflect those of the FSB or its members.

Good afternoon everybody. Thanks, Professor Berner, for your kind invitation, it is a pleasure to be here with you today. 

I would like to speak about the importance of a resilient nonbank financial sector for global financial stability and the challenges regulators face in working toward that goal. To do that, I’m going to get some assistance from Jane Austen.

If you follow me on LinkedIn, you know that I’m fond of writing about the books that I’m reading, and I recently finished Jane Austen’s Sense and Sensibility. If you’ve read Austen, you know that she frequently writes about the relationships of young women. Those relationships are complex – there are often multiple suitors – and they aren’t always stable – presumed engagements end without warning. Patience, and sometimes outside interventions, can help lead to the desired outcome. In Sense and Sensibility, we have Marianne and Elinor, both seeking husbands. We root for them as outside events lead them both to lose the relationships they presume are secure.

Is the nonbank sector really so different? Its complex and the relationships are myriad and, unfortunately, not always stable. So, as I reflect today on the complexities of the non-bank sector and the challenges that we face in regulating it, I will start with a quote from Sense and Sensibility, where Elinor says of Marianne: “A few years, however, will settle her opinions on the reasonable basis of common sense and observation.” 

Regulators have had a few years to observe the nonbank sector and the roles it’s played in periods of financial stability and periods of turmoil. Our opinions are becoming settled (and I hope they’re based on common sense). And the opinion is that the nonbank sector is an essential component of the global financial system and its resilience is, therefore, critical.

Based on this opinion, then, our challenge is to act decisively and thoughtfully to ensure that the activities of this sector do not undermine the resilience of the global financial system.

Today, I will share thoughts in three areas:

  1. The importance of not misusing the term “nonbank.”
  2. The growing significance of nonbanks in the financial system and their role in recent periods of market turmoil.
  3. How the sector should be regulated for financial stability and some misconceptions surrounding that regulation.

Let me begin by unpacking the terminology itself.

Avoiding misuse of the term “nonbank”

When financial stability became a higher priority after the Global Financial Crisis (GFC), we called the nonbank sector “shadow banking.” That term carried a pejorative connotation, so, after a while we switched to the more descriptive term “nonbank financial intermediation” or NBFI for short. While the term NBFI served as a useful shorthand to describe a diverse and dynamic sector, the use of that term is most fitting when we are discussing the broad contours of this vastly diverse set of institutions and activities. (That is how I will use the term today.) As regulators, however, we sometimes misuse the term. Referring to NBFI as if it was a monolithic entity can be misleading and can actually hamper discussion of key issues, especially when we’re actually concerned about vulnerabilities in specific subsectors or activities. 

NBFI encompasses a vast array of entities and activities, each with its own unique characteristics, contributions, and vulnerabilities to the financial system. From money market funds (MMFs) and hedge funds to pension funds, insurance companies, broker dealers, commodity trading firms, and fintech firms, the sector is anything but homogeneous. These entities utilise different business models, perform distinct functions, and present varied risks to financial stability.

Using a single term like “NBFI” oversimplifies this complexity and it can lead to the misconception that the same vulnerabilities are uniformly distributed across the sector, which would in some cases over-play and, in others, under-play the associated financial stability risks.

For example, when the FSB was working to understand the financial stability implications of NBFI leverage, nonbanks that generally don’t use significant leverage, like money market funds (MMFs) and some insurance companies and pension funds, were worried that they were being lumped in with those that do, like some hedge funds. Our engagement was hampered by this anxiety. As our work matured, we examined the constituent entities and activities of NBFI in more detail. We analysed their behaviour during periods of stress. Thus, we could better identify potential threats to financial stability and develop tailored policy responses.

If we want to be effective as regulators, the use of precise terminology is not pedantry – it is essential. So, for example, when we set up a task force to look at nonbank data issues, we first homed in on leveraged trading strategies in sovereign bond markets and then decided we needed to be more specific and narrowed our focus to hedge funds.

The importance of nonbanks in the financial system

The nonbank sector has grown in size, complexity, and importance since the GFC. According to the FSB’s annual Global Monitoring Report on NBFI, as of 2024, nonbanks accounted for just over half of total global financial assets, amounting to approximately a quarter of a quadrillion dollars ($260 trillion). This growth has been driven by factors, including regulatory shifts, the global search for yield, and innovation.

Beyond the numbers, nonbanks play a crucial role in the financial ecosystem by providing a myriad of critical financial services and activities in addition to being a valuable alternative to traditional bank funding. This alternative financing is essential for supporting real economic activity, particularly in underserved sectors or markets, helping to bridge the financing gap that can exist when banks are unable or unwilling to lend. Moreover, by offering different types of financial products and services, nonbank entities reduce the concentration of risk within the banking sector, enhancing the resilience of the financial system. This diversification may be particularly important during economic downturns when banks may tighten their lending standards. Nonbank entities also foster healthy competition within the financial sector. This competition can lead to better pricing, improved services, and more innovative financial products for consumers and businesses alike. The presence of nonbank lenders encourages banks to enhance their offerings and remain competitive, which ultimately benefits the overall economy. 

While the growth of the nonbank sector has brought undeniable benefits, such as increased access to credit and diversified funding sources, it has also introduced systemic risks. To go back to Sense and Sensibility again, Elinor is speaking about her sister’s suitors and says, “I have not wanted syllables where activities have spoken so plainly.” In recent years, the activities of nonbanks have, indeed, spoken plainly and have provided stark reminders of the negative externalities that can arise when that sector is not resilient.

For example, during the onset of the COVID-19 pandemic, some investment funds and money market funds faced significant liquidity pressures, as investors sought to redeem their holdings amid the heightened uncertainty. These redemptions led to significant asset sales and created a negative feedback loop, amplifying stress in short-term funding markets and, in some cases, necessitating central bank intervention.1

During this episode, margin calls on leveraged positions created a spike in the demand for liquidity. While increases in margin requirements are to be expected in volatile markets, extremely high asset price volatility and large trading volumes led to significant increases in initial margin and variation margin flows. Caught off guard by the size and timing of these increases, some market participants were forced to utilise their cash buffers or obtain further funding to meet those margin requirements.

Leverage also played a significant role in the dash for cash during this period. One way to obtain leverage is through repo markets. As our upcoming report on repo markets outlines, this leverage is often very short-term and can be withdrawn quickly, and some repo arrangements have no haircuts, which allows a significant build-up of risk.

In the commodity market turmoil following the Russian invasion of Ukraine, commodity prices and volatility surged. This volatility led to a spike in margin calls on commodities derivatives contracts, particularly in Europe, resulting in an increased demand for liquidity to meet those calls and the emergence of liquidity strains in some markets.

Those first two examples followed external, non-financial shocks. The collapse of Archegos in March 2021 and the gilt market turmoil in September 2022 did not. The rapid unwinding of Archegos’s positions created significant market volatility, and following the default of the firm, dealer banks liquidated their derivatives positions, including through forced sales of stocks, resulting in significant losses for counterparty banks. The collapse of Archegos had significant spillover effects on financial markets and highlighted how leverage and concentrated exposures in nonbanks can lead to significant losses for counterparties and ripple effects across the financial system. It also raised concerns about the adequacy of risk management practices among prime brokers.

During the turmoil in the UK gilt market in September 2022, an abrupt rise in gilt yields led to a sharp, sudden increase in liquidity demand from liability-driven investment (LDI) funds. In response, LDI funds sought to rebalance their portfolios, either by selling other liquid assets or requesting additional capital from pension fund investors. While some LDI funds managed to execute this rebalancing, others struggled to secure the necessary funds quickly enough due to the rapid yield movements and operational constraints. LDI funds offloaded long-dated gilts in a very short time frame and the resulting rapid increase in yields created significant challenges for pension funds, as their liabilities were often tied to fixed-income investments. This situation required intervention from the Bank of England, which stepped in to stabilise the market and to restore liquidity.2

The message of these episodes is that NBFI has become so important to the financial system that we need to ensure its resilience, so let me turn to regulation and how the nonbank sector should be regulated.

Views and misconceptions on nonbank regulation

Banks and nonbanks are both part of the financial system, and both must be resilient to a wide range of financial and nonfinancial shocks to ensure stability. The financial risks of nonbanks are as varied as you would suspect given the heterogeneity of firms and activities that fall within this heading. As a result, the risk to financial stability from banks and nonbanks also differ both in aggregate and when we look at specific nonbank entities and activities. Risk-taking is a natural and necessary part of financial intermediation. However, if these risks are poorly managed or insufficiently regulated, they can have destabilising effects on the broader financial system. The interconnectedness of nonbanks with other market participants means that their vulnerabilities can propagate, amplifying shocks and creating systemic risks.

Historically, the regulation of the nonbank sector has focused more on investor protection or market integrity or other similar mandates. However, these mandates do not fully capture the systemic nature of risks that the sector can pose to the global financial system, which has grown as this sector has grown. The negative externalities that can arise from non-bank activities, for example, during times of stress like the examples I gave earlier, suggest that a financial stability perspective is necessary. This perspective requires us to consider not just the risks to individual investors or markets, but also the potential for systemic risks – risks that can have far-reaching implications for the global financial system and the global economy.

Here, I turn again to Sense and Sensibility. As Marianne’s mother debates what caused the questionable behaviour of Marianne’s suitor, she asks, “I wonder whether it is so. I would give anything to know the truth of it.” This brings me to the question that often arises in discussions about NBFI in light of their role in periods of financial turmoil: Should nonbanks be regulated like banks? The answer, in my view, is both yes and no.

The argument for regulating nonbanks like banks

There are instances where the vulnerabilities in nonbanks mirror those in banks, warranting the use of similar regulatory tools. For example, the need for liquidity or capital is not unique to banks and they can be essential for preserving financial stability. The FSB’s work on MMFs has emphasised the importance of liquidity management to prevent runs.3 Similarly, other work was meant to ensure that market participants have appropriate liquidity for margin and collateral calls during periods of stress. These measures were put in place because these bank-like rules were appropriate in order to ensure that the critical financial intermediation undertaken by nonbanks is resistant to shocks.

Another reason for bank-like regulation of nonbanks results from the need for central banks to intervene during some recent episodes of stress. This need to intervene reflects that difficulties at nonbanks can have repercussions beyond the immediate investors in nonbank products and services that may threaten financial stability. Further, some jurisdictions have either implemented or are considering the introduction of central bank liquidity backstops specifically designed for nonbanks. These developments strengthen the case for regulating nonbanks like banks, at least in some cases.

The argument for regulating nonbanks differently

However, it would be a mistake to blindly apply bank-like regulations to nonbanks. The two sectors have different business models and risk profiles, and regulation must reflect these differences. For example, while banks take deposits that can be redeemed on demand at par value, nonbanks often deal with investors who have different risk-return characteristics and liquidity profiles. Indeed, MMFs, open-ended funds (OEFs), hedge funds and other nonbanks each present unique challenges that require tailored regulatory approaches, which may involve entity-level and activity-level measures. The diversity I emphasised before screams out for different regulation. It is not one size fits all.

I think this is obvious, so why do I bring it up? Repeatedly, in FSB outreach events and consultations, we come across misconceptions about how regulators like the FSB and its membership think about nonbank regulation. Let me offer some examples.

One prevalent misconception is that imposing bank-like regulations on nonbanks represents a failure to recognise the important financial roles they play. During our consultations on MMFs, some stakeholders argued that stricter liquidity requirements could reduce the appeal of these funds as an investment vehicle. During our leverage consultation, respondents argued that overly broad policies could discourage investment in regulated funds, potentially driving capital to less-regulated, higher risk channels and undermining rather than supporting financial stability. Others expressed concerns that regulatory measures could limit financial institutions’ ability to provide financing to underserved markets. They suggested that associated costs and barriers created by these regulations might discourage institutions from engaging in necessary lending activities, ultimately reducing access to capital for those who need it most and potentially harming overall market stability.

To this, I would say it is not that we fail to recognise the importance of these activities. The points raised in consultation are valid and deserve consideration, but they must be balanced against the systemic risks that can arise when vulnerabilities in nonbanks go unaddressed.

The need for regulation arises precisely because nonbanks are so integral to the financial system. Their size, interconnectedness, and critical role in providing credit, liquidity, and investment opportunities mean that their activities can have far-reaching implications for financial stability. Disruption in nonbanks and the associated impairment of the financial and credit intermediation provided by nonbanks will hit the real economy. Appropriate oversight is not about stifling innovation or imposing unnecessary burdens; it is about ensuring that nonbanks can operate safely and effectively within a resilient financial system.

Another misconception is that regulators believe all nonbanks present significant risks to financial stability. This is not the case. The nonbank sector is incredibly diverse, encompassing entities with vastly different business models, risk profiles, and regulatory needs. While some entities or activities, such as highly leveraged hedge funds that operate in critical markets, like sovereign bond markets, may pose significant risks to financial stability, others, such as well-managed pension funds or insurance companies, may present only limited risks to financial stability. Effective regulation should adopt a risk-based approach that focuses on areas where vulnerabilities are most pronounced and on the specific risks of different nonbank entities and activities.

During our consultation on nonbank leverage, respondents emphasised this diversity. They noted that different nonbanks employ leverage in varying ways, resulting in different levels of risk. Some stakeholders emphasised that leverage in certain segments, such as real estate investment trusts, is often well-managed and supported by robust risk management practices. The FSB recommendations give jurisdictions the ability to cater the recommendations to the specificities of the nonbank sector in their jurisdiction. Despite clear language about this flexibility to account for the diversity, we frequently heard the lament that all nonbank activities would be treated the same. Doing so, however, would hurt the financial system.

The final misconception that I want to mention is that the lack of depositors for nonbanks (or conversely, the presence of sophisticated investors) means that bank-like regulation should not apply. This argument suggests banks are subject to strict oversight only because they take deposits that are redeemable on demand and at par value. This unique characteristic of bank liabilities creates an inherent fragility, necessitating robust regulatory frameworks to ensure banks maintain sufficient liquidity and capital to meet their obligations. Additionally, banks’ access to central bank liquidity as lenders of last resort underscores the need for regulation to mitigate moral hazard and safeguard financial stability.

On the other hand, MMFs are close substitutes for deposits because they offer investors daily liquidity and stable value. When MMFs experience runs, financial market effects can be felt far beyond the investors in the MMF itself. As such, they require regulatory measures to address liquidity risks and prevent runs. OEFs are further removed from the characteristics of deposits, and investments in private credit, equity, and hedge funds are even further away. It is not about depositors versus investors. When you take the financial stability perspective, it’s about the resilience of the financial system as a whole. This does not mean that these entities should not be regulated; rather, it means that their regulation should reflect the specific risks they pose to the financial system.

The path forward: enhancing resilience in NBFI

As I start to wrap up, let me turn to Sense and Sensibility again. While considering the situation that she and her daughters find themselves in and wanting to improve it, Marianne and Elinor’s mother says, “I shall see how much I am before-hand with the world in the spring, and we will plan our improvements accordingly.” As regulators, we see the financial landscape and the important role that nonbanks play, and we have to plan our improvements accordingly to ensure that the nonbank sector has the resilience it needs. The FSB has focused on several areas of work: 

  1. Enhancing liquidity resilience
    Following the market turmoil of March 2020, the FSB emphasised the need to address liquidity mismatches in nonbanks. This has underpinned our work on MMFs and OEFs, and we are currently exploring measures to improve resilience in these areas. 
  1. Addressing leverage risks
    The use of leverage in the nonbank sector can amplify market shocks and create systemic risks. We made recommendations in this area last year, and we are pursuing data gaps and further work on some of those recommendations.
  1. Improving risk management practices
    Events like the collapse of Archegos highlighted gaps in risk management practices among nonbank entities and their counterparties. Strengthening these practices is essential to reducing vulnerabilities. 
  1. Promoting transparency and data sharing
    A lack of transparency can exacerbate uncertainty during periods of stress. The FSB is working to improve data collection and data and information sharing to enhance the understanding of risks within the nonbank sector. 
  1. Fostering International Cooperation
    Given the global nature of financial markets, international cooperation is essential. The FSB is committed to working with its members and other stakeholders to develop harmonised regulatory approaches that address cross-border risks. 

Conclusion

Before I conclude, as I am at one of the world’s premier research institutions, let me send a message to the researchers in the room. There are several misconceptions within the discourse surrounding the regulation of nonbank financial intermediation. We welcome all comments and insights from the public, and there are numerous claims being made that warrant further exploration. If you are seeking research topics, there is a significant opportunity for rigorous analytical work that could substantiate or challenge these claims. For the grad students out there, the breadth of these topics could provide ample material for years’ worth of future doctoral dissertations.

To conclude, the nonbank sector is a critical part of the global financial system. Its size, complexity, and interconnectedness make it both a source of strength and a potential point of vulnerability. As we continue to navigate the challenges and opportunities presented by NBFI, it is important that we remember that effective regulation is not about stifling innovation or imposing unnecessary burdens. It is about ensuring that the financial system remains resilient, stable, and capable of supporting the real economy. When the resilience of the nonbank sector is called into question, regulators must be quick to act, or to turn to Jane Austen one last time (this time from Emma), “What is right to be done cannot be done too soon.”

Thank you.

  1. FSB (2020), Holistic Review of the March Market Turmoil, November. ↩︎
  2. FSB (2024), Leverage in Nonbank Financial Intermediation: Consultation Report, December. ↩︎
  3. FSB (2021), Policy proposals to enhance money market fund resilience: Final report, October. ↩︎