Who regulates stock markets around the world: how the Commission is similar to foreign regulatory bodies

Financial market referees: how global regulators operate and what place the NSSMC has in this

Imagine a soccer game without a referee. The teams decide for themselves whether there was an offside, whether a handball is allowed, and when to end the game. A financial market without an independent regulator would look something like that. That is why such bodies emerged virtually everywhere where there are stock exchanges, IPOs, and private investors. They license market participants, ensure that companies disclose information honestly, look for market manipulation and insider trading, warn the public about fraudulent platforms, and educate people on how to avoid losing money.

In the US, the stock market is overseen by the SEC; in the UK, by the FCA; and in Germany, by BaFin. In Ukraine, this role is fulfilled by the National Securities and Stock Market Commission. The names and approaches may differ, but the goal is the same — to make the market fair and transparent for investors. Next, we will examine several countries that demonstrate different models of financial oversight: from a separate capital markets regulator to a mega-regulator that oversees multiple economic sectors simultaneously.
United States — SEC
The world’s most well-known regulator is the US Securities and Exchange Commission. It was set up in 1934, immediately following the 1929 stock market crash and the Great Depression: it became clear then that stock exchanges could not regulate themselves. Today, the SEC oversees the New York Stock Exchange and Nasdaq, registers initial public offerings, and investigates insider trading and price manipulation. And on the Investor.gov website, anyone can find a simple explanation of how to check a broker and recognize a Ponzi scheme.

United Kingdom – FCA
The British regulator was established in 2013 as a result of reforms to the financial supervision system following a global financial crisis. The Financial Conduct Authority oversees not only the market itself but also how financial firms treat their clients: it reviews advertisements for investment products, maintains a public registry of licensed firms, and regularly publishes a list of fraudulent platforms that should be avoided.

France — AMF
The French AMF was established in 2003 through the merger of several financial market supervisory bodies. The AMF focuses on prevention: it has a dedicated service (the financial ombudsman) to handle complaints from individual investors, maintains a blacklist of illegal platforms, and strives to explain complex financial topics in simple terms — before people even have a chance to run into a problem.

Germany — BaFin
In Germany, there is no separate regulator specifically for the stock market — there is BaFin, which is responsible for banks, insurance companies, and the securities market all at once. It was set up in 2002 by creating a single entity by merging three federal supervisory agencies. This is an example of a “mega-regulator,” where instead of several agencies, each overseeing its own sector, there is a single agency that sees the financial system as a whole and supervises it.

Poland — KNF
Poland’s KNF is also a mega-regulator. It was established in 2006 and, in addition to the capital market, oversees banks, insurance companies, and pension funds. Poland’s experience is particularly interesting for Ukraine: the country has followed a similar path in the development of its financial market and, over the past two decades, has consistently aligned its regulation with EU standards.

Spain — CNMV
The Spanish CNMV has been in operation since 1988 and, unlike in Germany or Poland, is specifically responsible for the securities market — it registers share issues, supervises investment firms, and ensures that market prices are formed fairly, without manipulation.

Australia — ASIC
Australia’s ASIC, in its current form, has been operating since 1998 and is known primarily for its fight against fraud: in just one year, it took down nearly 7,000 fake investment websites. Its educational platform, Moneysmart, offers simple explanations about investments, loans, and retirement savings. Scammers even create counterfeit versions of the platform to gain the trust of potential victims.

Japan — FSA
Japan’s FSA has been in operation since 2000 and, like Germany’s BaFin, oversees banks, insurance companies, and the stock market. It pays particular attention to transparency in corporate governance — that is, the extent to which companies report honestly to their own shareholders.

Singapore — MAS
In Singapore, there is no separate stock market regulator at all — this function, along with all others, is performed by its central bank, the Monetary Authority of Singapore (MAS). The MAS has existed since 1971 and combines monetary policy, banking supervision, and capital market regulation within a single structure. This is perhaps the most unusual model among developed countries.

Nine countries — nine different models. Some have established a separate agency dedicated solely to the securities market, while others have consolidated supervision of banks, insurance companies, and the stock market into a single entity; Singapore, meanwhile, has entrusted this responsibility to its central bank. But despite the differences in approach, the basic functions are surprisingly similar across the board.

So, what does Ukraine have to do with this?

All of these regulatory bodies, including the NSSMC, are members of the International Organization of Securities Commissions (IOSCO). It is the world’s largest forum of securities regulators, headquartered in Madrid: more than 130 jurisdictions that together oversee approximately 95% of the global securities market.

Ukraine has been a regular member of IOSCO since 1996 — ever since the Commission itself was established. But membership in the organization and full compliance with its standards are not one and the same. On 14 July 2026 in Madrid, at IOSCO headquarters, the NSSMC signed the Multilateral Memorandum of Understanding (IOSCO MMoU) — the key instrument that allows regulators to exchange information directly with one another and jointly investigate violations. To reach this signing, Ukraine had to amend its legislation and expand the Commission’s own powers.

And this is not just a formality. As early as August, the Commission put the new tool into practice — for the first time, it launched international investigations in response to requests from foreign regulators. The details of the cases have not been disclosed: under the terms of the Memorandum, information obtained through the IOSCO MMoU is confidential and is used solely for the specific investigation. Commission Chairman Oleksii Semeniuk called this the first practical case since Ukraine joined the IOSCO MMoU. And this demonstrates that the Ukrainian regulator now operates under the same rules as the SEC, FCA, or BaFin.

Regardless of whether a country has a separate securities commission, a mega-regulator such as BaFin, or has entrusted this role to its central bank, as in Singapore, the same principles underlie them all: fair rules of the game, transparent information, and investor protection. It is precisely these principles that guide the NSSMC’s work, and it is becoming increasingly integrated into the global system that upholds them.