The Bank for International Settlements (BIS) published a Financial Stability Institute report in April 2026, warning that the largest crypto platforms now operate as financial intermediaries without the capital buffers, deposit insurance or central bank access that apply to traditional banks.
Key Takeaways:
- The BIS Financial Stability Institute warned in April 2026 that major crypto platforms like Binance and Coinbase now operate more like banks than trading venues.
- Celsius Network collapsed in 2022 after a USD 1.4 billion depositor run exposed maturity mismatches with no deposit insurance backstop.
- Only 11 of 28 jurisdictions reviewed by the FSB in 2025 had a finalized regulatory framework addressing financial stability risks from crypto intermediaries.
Crypto Earn Accounts Exposed as Uninsured Deposits, BIS Research Warns
The report, authored by Denise Garcia Ocampo of the BIS and Peter Goodrich and Gian-Piero Lovicu of the Financial Stability Board, focused on what researchers call multifunction crypto asset intermediaries, or MCIs. The term covers firms like Binance, Bybit, Coinbase, Crypto.com, Kraken, MEXC and OKX.
These platforms have expanded well beyond spot trading and custody. They now offer yield-bearing earn accounts, margin lending, derivatives, and token issuance, functions typically separated across different licensed entities in traditional finance.
The total crypto asset market stood at approximately $3 trillion at the end of 2025. Centralized exchanges processed roughly $6 to $8 trillion in spot and futures volume each quarter. Binance alone held about 39% of global centralized spot trading volume. The top five MCIs collectively served an estimated 200 to 230 million users.
The paper’s central concern is the earn product. When customers deposit crypto into Binance Simple Earn or Bybit Easy Earn, terms and conditions transfer ownership of those assets to the platform. The MCI pools the funds, deploys them across lending, market-making and DeFi, and pays users a variable yield. Customers become unsecured creditors, not depositors with legal protections.
That structure creates short-term redeemable liabilities backed by longer-duration or less liquid assets. Researchers call this maturity and liquidity transformation, the same risk that bank regulators manage through capital and liquidity requirements. MCIs face it without those guardrails.
The collapse of Celsius Network in 2022 illustrated the exposure. Celsius experienced net withdrawals of more than $1.4 billion between May and June of that year. By June 12 the platform froze withdrawals. When it filed for bankruptcy on July 12, its balance sheet showed a billion-dollar deficit. The bankruptcy court confirmed Celsius earn users were general unsecured creditors.
A flash crash on Oct. 10, 2025, reinforced the concern. Crypto asset prices fell sharply over 30 minutes, triggering cascading automated liquidations across derivatives platforms. Reported direct losses reached $19 billion the following day. Binance suffered an operational outage during the event, and three tokens used as margin collateral, including an algorithmic stablecoin, temporarily lost their pegs. Binance announced $283 million in customer compensation following the incident.
The report reviewed terms and conditions from eight major MCIs between November 2025 and March 2026 and found that most earn products grant the platform full discretion over deposited assets, commingle them with other customer funds, and reserve the right to suspend redemptions without notice.
Leverage adds further risk. Some platforms allow retail customers up to 150-to-1 margin on derivatives contracts. The paper draws a direct line from that leverage to the October 2025 liquidation cascade.
The FSB’s 2025 thematic review found that only 11 of 28 participating jurisdictions, roughly 39%, had a finalized regulatory framework addressing financial stability. Just two of those covered borrowing and lending by MCIs. Three covered earn products.
The authors call for prudential capital and liquidity requirements, governance standards, stress testing and consolidated supervision applied at the group level. They recommend a combination of entity-based and activity-based regulation, noting that activity-based rules alone cannot address the funding and liquidity risks MCIs carry.
Cross-border cooperation remains a core gap. Many large MCIs allocate functions across dozens of jurisdictions through separate legal entities, and formal supervisory information-sharing agreements between regulators remain uncommon.
