Overview
This document synthesizes CBDC research from 20 jurisdictions into structured comparison tables. Each cell is sourced from the corresponding country research file and the canonical fact matrix. Where data is unavailable or not covered in the source material, the cell is marked "No data" or "NOT VERIFIED" as the underlying source records it.
Jurisdictions covered: Australia, Bahamas, Brazil, Canada, China, Eastern Caribbean, European Union, Ghana, India, Jamaica, Japan, Nigeria, Russia, Singapore, South Africa, South Korea, Sweden, Thailand, United Kingdom, United States.
Status at a Glance (June 2026)
| Status | Jurisdictions | Count |
|---|---|---|
| Launched / live (retail) | Bahamas, Jamaica, Nigeria | 3 |
| Launched / live pilot at scale (retail) | China, India | 2 |
| Pilot concluded / suspended | Eastern Caribbean | 1 |
| Active retail pilot (not launched) | Brazil, South Korea | 2 |
| Pilot with mandated future launch | Russia | 1 |
| Wholesale live or pilot | Australia, Singapore, South Africa | 3 |
| Pilot completed, no full-scale launch | Ghana, Thailand | 2 |
| Research / design / preparation phase | Canada, European Union, Japan, Sweden, United Kingdom | 5 |
| Anti-CBDC (no issuance; prohibited) | United States | 1 |
Of the 20 jurisdictions, 6 have launched or operated a CBDC with real money (Bahamas Sand Dollar, Jamaica JAM-DEX, Nigeria eNaira — all launched and legal tender; China e-CNY and India e₹ — operational at pilot scale; Eastern Caribbean DCash — launched as a pilot, now concluded and its successor suspended). Russia's digital ruble is in a pilot with a legally-mandated large-scale launch on 1 Sep 2026 and narrow live government/budget use since 1 Jan 2026, but is not yet a full live retail launch and so is not counted among the launched set. The United States is the only jurisdiction with an explicit anti-CBDC stance.
The tables that follow cover seven dimensions: Legal Status and Institutional Design (Table 1), Technology and Architecture (Table 2), Privacy and Data Protection (Table 3), Monetary Policy Design (Table 4), Financial Inclusion (Table 5), Cross-Border Participation (Table 6), and Adoption Outcomes for launched CBDCs (Table 7). Tables 1-6 cover all 20 jurisdictions. Table 7 covers only the six jurisdictions that have launched or operated a CBDC with real money.
Table 1: Legal Status & Institutional Design
| Country | CBDC Name | Status | Legal Basis | Legal Tender? | Lead Institution | Distribution Model |
|---|---|---|---|---|---|---|
| Australia | eAUD (retail pilot) / wholesale CBDC | Wholesale experimentation completed Feb 2026 (Project Acacia, final report 18 May 2026); retail assessed and shelved | Reserve Bank Act 1959; Currency Act 1965; no CBDC-specific legislation | No | Reserve Bank of Australia (RBA) | Two-tier (intermediated, via ESA holders) |
| Bahamas | Sand Dollar | Launched (October 20, 2020); active but adoption low (<0.4% of cash) | Central Bank of The Bahamas Act, 2020 | Yes | Central Bank of The Bahamas (CBOB) | Two-tier (licensed AFIs: banks, credit unions, MTBs, PSPs) |
| Brazil | Drex (Digital Real) | Active pilot, restarted — Hyperledger Besu decommissioned Nov 10, 2025; rebuilding from scratch, no firm launch date | Law 14,478/2022; Decree 11,563/2023; BCB Resolution 315/2023; no standalone CBDC Act | No (pilot phase) | Banco Central do Brasil (BCB) | Two-tier (tokenized bank deposits via banks) |
| Canada | None (retail scaled down; wholesale research) | Not launched; retail CBDC scaled down Sep 2024 ("no compelling case"); contingency/readiness posture; wholesale work continues | Bank of Canada Act (s.25) and Currency Act would both require amendment; Stablecoin Act (Bill C-15, Royal Assent Mar 26, 2026) excludes CBDCs, not yet in force | No (no CBDC authority) | Bank of Canada (BoC) | Two-tier (research-stage; OpenCBDC 2PC studied) |
| China | e-CNY (digital yuan) | Active large-scale pilot transitioning toward deployment; 22 authorized operators (after +12 banks Apr 2, 2026); reclassified toward deposit-money Jan 1, 2026 | PBOC administrative authority; draft amended PBOC Law (Art. 19, 22, 65) not yet enacted | No explicit codified legal tender (de facto via PBOC authority) | People's Bank of China (PBOC) | Two-tier (PBOC to 22 authorized operators to public) |
| Eastern Caribbean | DCash | Pilot concluded Jan 2024; DCash 2.0 development suspended Feb 13, 2026 (FPS + CAPS prioritized) | 2020 amendments to Arts. 2 & 18 of the ECCB Agreement (1983) + 8 domestic implementing laws; Payment System and Services Act (model law) underpins FPS pivot | Yes (during pilot, by ECCB Agreement amendment) | Eastern Caribbean Central Bank (ECCB) | Two-tier (ECCB to licensed financial institutions) |
| European Union | Digital Euro | Advanced preparation / pre-issuance pilot; preparation phase concluded Oct 2025, GC moved to next phase 30 Oct 2025; ECON vote 23 Jun 2026 | Proposed Digital Euro Regulation COM(2023) 369 (procedure 2023/0212(COD)); not yet enacted | Proposed legal tender under draft regulation | European Central Bank (ECB) / Eurosystem | Two-tier (Eurosystem to supervised PSPs) |
| Ghana | eCedi | Pilot declared "completed" 22 May 2026; design/development phase (wholesale + cross-border); not a live launch | No dedicated CBDC law; Bank of Ghana Act, 2002 (Act 612); enabling eCedi Act not passed | No | Bank of Ghana (BoG) | Two-tier (intermediated) |
| India | e₹ (Digital Rupee) | Active retail (e₹-R) and wholesale (e₹-W) pilots; e₹-R circulation fell ~24% YoY in FY2025-26 (first decline) | RBI Act 1934 as amended by Finance Act 2022 (Sec 139; new Sec 22A); legal tender under Sec 26 | Yes (legal tender by statute) | Reserve Bank of India (RBI) | Two-tier (RBI to banks/non-bank operators to public) |
| Jamaica | JAM-DEX | Launched (June 14, 2022); legal tender but adoption-challenged (~0.1% of currency) | Bank of Jamaica (Amendment) Act, 2022 (Act 5 of 2022) | Yes (legal tender by statute) | Bank of Jamaica (BOJ) | Two-tier (BOJ to authorized DTI wallet providers) |
| Japan | Digital Yen | Research/pilot phase; "no plan to issue a CBDC" (June 2026); issuance decision expected 2026; Feb 2026 expansion to wholesale + tokenization | No legal tender status; Bank of Japan Act (Act No. 89 of 1997); amendments required; no Diet bill | No | Bank of Japan (BOJ) | Two-tier (account-type CBDC) |
| Nigeria | eNaira | Launched (October 25, 2021); legal tender, operational but largely dormant; Nov 2025 pivot to wholesale | Section 19 of CBN Act 2007 + BOFIA 2020 + Regulatory Guidelines on the eNaira; no standalone eNaira Act | Yes (legal tender) | Central Bank of Nigeria (CBN) | Two-tier (CBN to licensed financial institutions) |
| Russia | Digital Ruble | Pilot with legally-mandated large-scale launch 1 Sep 2026; narrow live government/budget use since 1 Jan 2026 | Federal Law No. 340-FZ (signed Aug 1, 2023); Civil Code amendments (Arts. 128, 140, 1128, 1174) | Yes (third form of the ruble) | Central Bank of Russia (CBR) | Two-tier (CBR sole platform operator; banks as intermediaries) |
| Singapore | SGD wholesale CBDC (SGD Testnet) | Wholesale live issuance (first live wholesale CBDC transaction Nov 2025); retail (Project Orchid) research only | No specific CBDC legislation; MAS Act and Currency Act 1967; PSA 2019, FSMA 2022 for intermediaries | No (wholesale only) | Monetary Authority of Singapore (MAS) | Wholesale (MAS to institutional participants); retail PBM via banks |
| South Africa | None (wholesale research) | Not launched; research/PoC (Project Khokha 1, 2/PK2, PK2x); Position Paper (27 Nov 2025): retail CBDC technically feasible but "no compelling immediate need" | No CBDC-authorizing law; SARB Act 1989; Constitution 1996 s.225; NPS Act 1998; amendment required | No | South African Reserve Bank (SARB) | Wholesale (research only; non-bank NPS access roadmap) |
| South Korea | Digital Won (Project Hangang) | Active hybrid pilot; Phase 1 paused June 2025, Phase 2 restarted March 2026; "intermediate stage between a CBDC and stablecoins" | Not legal tender; Virtual Asset Users Protection Act (Act No. 19563) excludes BOK digital currency; BOK Act amendment likely required | No (pilot phase) | Bank of Korea (BOK) | Two-tier (deposit-token hybrid via banks) |
| Sweden | e-Krona | Research/analysis programme; technical pilot (R3 Corda, four phases) concluded 2024; no issuance decision; no enabling legislation | No legislation authorising issuance; Sveriges Riksbank Act 2022 (SFS 2022:1568) did not authorise; SOU 2023:16 found insufficient need | No | Sveriges Riksbank | Two-tier (anticipated; DLT-based pilot) |
| Thailand | Digital Baht | Retail pilot completed 2024 (Bang Khun Phrom), no full-scale launch; pivoted to Programmable Payment Sandbox; wholesale (mBridge, Inthanon) active | Retail CBDC would be legal tender under Currency Act B.E. 2501 (1958) if invoked; no specific CBDC legislation | No (not invoked) | Bank of Thailand (BOT) | Two-tier (intermediated via financial service providers) |
| United Kingdom | Digital Pound | Design phase; no decision to launch; decision expected later in 2026 | No draft digital-pound legislation; primary legislation required; FSMA 2023 provides broader foundation | No | Bank of England (BoE) + HM Treasury | Two-tier (public-private platform; PIPs/ESIPs) |
| United States | None | Anti-CBDC; no issuance. Binding prohibition = EO 14178 (in force); statutory bans passed both chambers in differing forms but NOT enacted | Executive Order 14178 (Jan 23, 2025); H.R. 1919 passed House 219-210 (not enacted); ROAD to Housing CBDC moratorium passed both chambers in differing forms, unreconciled | N/A (no CBDC; barred by EO) | N/A (Federal Reserve research only; Chair Kevin Warsh) | N/A |
Analytical notes:
The legal landscape divides into three clusters.
Cluster 1 — Enacted CBDC-specific legislation: Russia (Federal Law 340-FZ), India (Finance Act 2022 amending RBI Act), Jamaica (BOJ Amendment Act 2022), and Bahamas (CBOB Act 2020). These four jurisdictions have the strongest legal foundations, with statutory authority that goes beyond general central bank powers. The Eastern Caribbean also amended its founding treaty (ECCB Agreement Arts. 2 & 18) to confer legal-tender status during the DCash pilot, but the pilot has concluded.
Cluster 2 — Operating under existing central bank authority: China, Singapore, Australia, South Korea, Thailand, Japan, Sweden, South Africa, Ghana, Nigeria, and Canada (where any CBDC would in fact require amendment of the Bank of Canada Act and Currency Act). This is the largest group, reflecting a preference for iterative experimentation before committing to bespoke legislation. The risk is that without dedicated law, CBDC programs lack the permanence and legal certainty needed for production deployment.
Cluster 3 — Explicit prohibition: The United States is the only jurisdiction to formally bar CBDC development. The binding prohibition is Executive Order 14178 (January 23, 2025), which is in force. Statutory bans have advanced — H.R. 1919 passed the House 219-210, and a CBDC moratorium passed both the Senate (in the 21st Century ROAD to Housing Act, 89-10) and the House (396-13, amended) — but in differing, unreconciled forms, so no statutory ban is yet enacted. This makes the U.S. the only major economy to formally reject CBDC, doing so via executive action. New Fed Chair Kevin Warsh (sworn in May 22, 2026) reaffirmed opposition to a retail CBDC.
The European Union occupies a unique position with a detailed proposed regulation (COM(2023) 369) that has not yet been enacted — it is further along the legislative path than Cluster 2 jurisdictions but has not yet crossed the threshold into Cluster 1. Its preparation phase concluded in October 2025, the Governing Council moved the project to the next phase on 30 October 2025, and the ECON Committee vote on the draft report is scheduled for 23 June 2026.
Five jurisdictions have granted their CBDC explicit legal tender status: Bahamas, Jamaica, India, Nigeria, and Russia (the digital ruble being a "third form of the ruble"). China's e-CNY notably lacks codified legal tender status despite being the world's most advanced pilot.
Distribution model convergence: Every jurisdiction that has progressed beyond conceptual research has adopted or proposed a two-tier distribution model. No jurisdiction has pursued direct central bank-to-consumer distribution, reflecting a consensus that disintermediation of commercial banks is an unacceptable risk.
Table 2: Technology & Architecture
| Country | DLT / Ledger Type | Platform / Provider | Token-Based or Account-Based | Offline Capability | Programmability |
|---|---|---|---|---|---|
| Australia | Multi-DLT (Canvas Connect, Ethereum, Hedera, Redbelly, XRP Ledger); ERC-20 on EVM | AP+ HashSphere (private Hedera), Canvas Connect, Redbelly Network | Token-based (ERC-20 wCBDC) | NOT VERIFIED for wholesale; identified as a potential retail resilience use case | Yes (atomic settlement, embedded compliance; eAUD smart contracts/escrow) |
| Bahamas | Private permissioned DLT (Cortex DLT) | NZIA Limited / Movmint; IBM; Zynesis; Norton Rose Fulbright | No data (wallet-based) | Yes (offline/pre-authorized transactions, under development) | Yes (issuer can set expiry / usage rules) |
| Brazil | Was Hyperledger Besu (Phase 1, decommissioned Nov 10, 2025); pivoting to centralized infrastructure, technology TBD | BCB; rebuilding from scratch (privacy tech tested: Zether, Starlight, Rayls, ZKP Nova, Hamsa — none production-mature) | Tokenized deposits (wDrex/rDrex) | NOT VERIFIED | Yes — originally key differentiator; scope narrowed post-pivot to collateral/lien reconciliation |
| Canada | No deployed system; research evaluated OpenCBDC 2PC (retail), Hyperledger Fabric (Project Samara wholesale) | OpenCBDC (MIT DCI); Project Samara on Hyperledger Fabric; Project Jasper (2017-2019) | Research-stage (two-tier OpenCBDC 2PC) | Research only (SAN 2023-2: intermittent vs extended offline); not deployed | Not applicable (no CBDC) |
| China | Hybrid centralized/distributed; centralized PBOC ledger (not public blockchain); 300,000+ TPS (NOT VERIFIED) | PBOC core infrastructure; 22 authorized operators (Apr 2026); Alipay/WeChat Pay front-ends | Token strings + accounts + smart contracts (from Jan 1, 2026) | Yes (NFC, Bluetooth, SIM card wallets, hardware wallets, dual offline) | Yes but limited; conditional payments, vouchers, purpose-binding; PBOC-controlled; no DeFi |
| Eastern Caribbean | Private permissioned DLT (Hyperledger Fabric); hosted on Google Cloud | Bitt Inc. (2022 outage from expired Fabric identity certificates, ~56 days) | No data | DCash 1.0 had none; DCash 2.0 RFVI required it — but DCash 2.0 suspended | NOT VERIFIED |
| European Union | Centralized settlement (NOT DLT); in-house N-XT engine (UTXO data model) | Centralised Eurosystem platform built on TIPS; Giesecke+Devrient (offline) | UTXO-based settlement | Yes — core design feature (device-to-device via secure element eSE/eSIM/NFC) | Programmable money explicitly excluded; conditional payments as PSP value-added only |
| Ghana | Token-based offline component (stored-value, cash-like) | Giesecke+Devrient (G+D) prototype | Token-based (offline stored-value) | Yes — offline-first design (offline NFC POS, consecutive offline payments, dual-mode) | NOT VERIFIED |
| India | Hybrid — wholesale (e₹-W) on Hyperledger Fabric DLT; retail (e₹-R) API-based, NOT on DLT (UPI-inspired) | RBI in-house; NPCI backend; UPI QR interoperability | Token-based (retail); account-based (wholesale) | Yes — offline launched at Global Fintech Fest Oct 2025 (NFC, feature-phone, stored-value) | Yes — purpose-bound money (fuel, groceries, education, healthcare); welfare schemes |
| Jamaica | Centralized (NOT blockchain / NOT DLT); BOJ-controlled ledger | eCurrency Mint (Ireland), DSC3 cryptography; ~0.3s settlement, quantum-resilient | Token-based ("digital bearer instrument") | NOT VERIFIED | NOT VERIFIED |
| Japan | Account-type CBDC ledger shared between central and intermediary systems; NoSQL; researching UTXO; public blockchain deemed not viable | Experimental pilot system; API sandbox (18 companies); 50,000 TPS vs 100,000 target | Account-based (also tested token-based) | Under development — for disaster resilience and poor connectivity | Under research (WG2/DG on New Technologies); wholesale sandbox programmable interbank payments |
| Nigeria | Permissioned DLT (Hyperledger Fabric); CBN sole validator | Bitt Inc. (Barbados); stress-tested >2,000 TPS; ISO 20022 via Bitt Numa; NIBSS-integrated | Account-based (centralized CBN ledger); NOT token-based | No — required internet connectivity | Smart contract functionality in architecture but remained unenabled after launch |
| Russia | Centralized hybrid platform; built/maintained in-house by CBR; specific DLT not publicly disclosed | Centralised in-house CBR platform; built in-house to mitigate sanctions risk | No data (one wallet per person) | NOT VERIFIED | Yes — smart contracts ("coloured funds"); 17,000+ in pilot; targeted budget funds |
| Singapore | DLT — SGD Testnet shared ledger; Orchid Blueprint building blocks; GL1 public permissioned blockchain | SGD Testnet (DBS, OCBC, Standard Chartered, UOB); GL1 core group; Purpose-Bound Money protocol | Purpose-Bound Money (PBM) protocol (form-factor agnostic) | NOT VERIFIED / not a stated feature | Yes — PBM is the key innovation (programmable conditions; wraps CBDC, deposits, stablecoins) |
| South Africa | PoC/sandbox only — Khokha 1: Quorum (Ethereum-based permissioned); PK2: R3 Corda + Cosmos-based Khokha Hub | Quorum (PK1); R3 Corda (Accenture) + Cosmos-based (Block Markets Africa) in PK2 | No data (no production ledger) | NOT VERIFIED / not applicable (wholesale-focused) | Wholesale/sandbox only — tokenized settlement, wholesale CBDC as collateral; no production programmability |
| South Korea | Two-layer hybrid: wholesale CBDC layer + deposit-token layer (won-pegged, 1:1); DLT in cloud testing, centralized node management | Bank mobile apps with QR; LG CNS core infrastructure; Samsung (earlier phases) | Deposit tokens (over wholesale CBDC) | Offline payments tested in 2022 simulation; not a core deployed feature | Yes — Purpose Bound Money model (children's allowances, EV charging, vouchers) |
| Sweden | DLT-based pilot on R3 Corda (digital tokens), with Accenture (concluded 2024) | R3 Corda pilot platform; EMV-compatible card for offline | DLT-based tokens | Yes — offline card ("shadow wallet"), Phase 4; cap SEK 3,000, max 5 consecutive offline | Phase 3 confirmed feasibility of programmable payments and smart contracts |
| Thailand | DLT-based — Project Inthanon (wholesale); retail pilot DLT-based; Programmable Payment Sandbox (DLT + smart contracts, 1:1 peg) | Dedicated mobile app for retail pilot; PromptPay (QR) tested; Programmable Payment Sandbox | No data | Not publicly specified for retail pilot; PromptPay considered most suitable channel | Yes — Programmable Payment Sandbox (condition-based payments; SCB 10X PBM, KBANK, True Money/Bitkub) |
| United Kingdom | Undecided — BoE "core ledger" concept; explicitly NO decision on DLT vs centralised database | BoE core ledger + API layer; tested via Project Rosalind (33 API functions), Digital Pound Lab (sandbox) | No data (core-ledger funds, not bank balance sheets) | Deferred offline payments prioritised for launch; device offline deferred | No government/central-bank programmability; private-sector programmability with user consent only |
| United States | N/A (no CBDC); Project Hamilton found DLT not needed (central-actor model) | Project Hamilton (Boston Fed/MIT, OpenCBDC): 1.7M TPS; RLN and Project Cedar (NY Fed) wholesale | N/A | N/A (research designs did not specify offline) | N/A (Project Hamilton explored programmability as research only) |
Analytical notes:
Technology choices reveal a spectrum from fully centralized to multi-DLT approaches.
DLT vs. centralized divide: The early assumption that CBDCs require blockchain/DLT is being challenged. Brazil's pivot away from Hyperledger Besu — the Besu platform was decommissioned on 10 November 2025 and the project is rebuilding "from scratch" with technology TBD — is the most dramatic example. The BCB concluded that no privacy solution it tested (Zether, Starlight, Rayls, ZKP Nova, Hamsa) was production-mature against its "privacy trilemma" (confidentiality, programmability, and regulatory compliance cannot all be achieved simultaneously on a shared ledger). Jamaica chose a centralized platform (eCurrency Mint DSC3) from the outset, avoiding blockchain entirely. The European Union's choice of a centralized UTXO engine (N-XT) on TIPS rather than DLT is a deliberate departure from the blockchain-centric designs common in Asia-Pacific. Project Hamilton in the United States similarly found a distributed ledger was not needed.
DLT adopters: China uses a hybrid centralized/distributed architecture that gives the PBOC central control while allowing 22 authorized operators (after a doubling on 2 April 2026) to manage distribution. Nigeria and Eastern Caribbean both used Hyperledger Fabric (via Bitt Inc.), with mixed results — the Eastern Caribbean suffered a roughly two-month outage from expired node certificates. India uses Hyperledger Fabric for wholesale and an API-based, non-DLT approach for retail. Sweden piloted on R3 Corda across four phases, and Canada used Hyperledger Fabric for its wholesale Project Samara.
Multi-DLT strategies: Australia (Project Acacia across Canvas Connect, Ethereum, Hedera, Redbelly, and the XRP Ledger) and Singapore (SGD Testnet plus GL1) have adopted multi-DLT strategies for wholesale CBDC, testing across multiple platforms simultaneously. This avoids technology lock-in and generates comparative performance data.
Offline capability: This remains a critical differentiator with real-world consequences. Ghana's offline-first design directly addresses the reality that an estimated ~47% of its population lacks internet access (a self-reported figure). Bahamas designed offline capability specifically for hurricane resilience (still under development). China offers NFC, SIM-based, and hardware-wallet solutions for offline use. India officially launched offline Digital Rupee at the Global Fintech Fest in October 2025. Sweden tested an offline card solution in Phase 4. The European Union makes cash-like offline functionality a core feature.
Programmability: India's purpose-bound welfare distribution (G-SAFAL, DEEPAM 2.0, PMGKAY), Singapore's Purpose-Bound Money protocol, and South Korea's government subsidy integration represent the most advanced programmability implementations. By contrast, the European Union and United Kingdom explicitly exclude central-bank programmability from their core designs.
Table 3: Privacy & Data Protection
| Country | Privacy Model | Data Protection Law | Anonymity Approach | Central Bank Access to Individual Data |
|---|---|---|---|---|
| Australia | Institutional (wholesale); intermediated (eAUD pilot) | Privacy Act 1988 (under reform); Australian Privacy Principles | No fully anonymous design; ~A$5/person/yr WTP for full anonymity (RDP 2024-02); ad hoc AUSTRAC sharing | RBA saw transaction values/balances but not holder identity (eAUD pilot) |
| Bahamas | Not anonymous — fully auditable trail; three-tier KYC | General confidentiality protections (no single named DP law) | No anonymity at any tier (Tier 1 simplified to Tier 3 enhanced KYC) | CBOB maintains centralised KYC register and AML/CFT engine; law enforcement via legal channels |
| Brazil | Privacy is the single most consequential obstacle (drove the pivot); no solution deemed mature | LGPD (Law 13,709/2018); banking secrecy (Complementary Law 105/2001) | Not anonymous; participant-level privacy intended (banks can't see other banks' clients) | BCB has full transaction visibility; banks limited to own clients |
| Canada | Research: "soft privacy" (authorized access, controls, audits) more promising than "hard"/cryptographic | PIPEDA + provincial privacy law (would apply) | Not applicable (no CBDC); research notes cash-like anonymity technically immature | Would depend on design; OPC research favored a "direct CBDC" record-keeping model |
| China | "Controllable anonymity" — small amounts anonymous, big amounts traceable | No overarching DP law cited; PIPL interaction underspecified | Tiered wallets: Category 4 (phone only, anonymous) up to Category 1 (full ID, traceable) | PBOC sees verified-wallet identities and aggregated amounts; anonymous-wallet identity via legal process |
| Eastern Caribbean | Not anonymous, with confidentiality via a two-tier data-access model | Varies by territory (8 jurisdictions) | Not anonymous; Value-Based (simplified KYC) and Registered (full KYC) wallets | ECCB saw only anonymized/aggregate data; wallet-hosting FI retained identity data |
| European Union | Tiered: offline = cash-like; online = pseudonymised (Eurosystem cannot identify users) | GDPR | Cash-like for offline; pseudonymised online (EDPB/EDPS urged low-value online privacy threshold) | ECB/Eurosystem cannot access offline data or identify online users (by design) |
| Ghana | No detailed privacy specs published; offline payments give some inherent privacy | Data Protection Act, 2012 (Act 843) | NOT VERIFIED — no public data on retention/government access | Bank of Ghana (Data Protection Commission enforces Act 843) |
| India | Tiered anonymity — "reasonable anonymity" for small-value; full traceability for large-value (PMLA) | Digital Personal Data Protection Act, 2023 (Rules Nov 2025) | Wallet tiers: Basic (minimal KYC, higher anonymity) vs Full KYC (Aadhaar/PAN) | RBI sees aggregate issuance/redemption; banks see individual identity (centralized ledger could technically access all) |
| Jamaica | Identity not recorded in transactions (only value); user data stored with wallet provider | Data Protection Act (2020); Office of the Information Commissioner | Tiered KYC (Low KYC: one ID; Standard KYC); not fully anonymous (wallet provider sees transactions) | BOJ has no direct access to individual transaction data; wallet provider holds user data |
| Japan | Privacy a paramount design concern given cash culture; data minimization; role-sharing | APPI (amended 2022); PETs research report (Jan 2023) | Tiered privacy via intermediated model; specific tiers not detailed | BOJ does not directly hold individual user data; intermediaries can pseudonymize |
| Nigeria | Comprehensive transaction monitoring by CBN (account-based) — eliminates cash anonymity | Nigeria Data Protection Act, 2023 (eNaira guidelines predate it) | Tiered KYC, no anonymity (Tier 0 phone-only up to Tier 3 BVN+enhanced) | CBN (and intermediaries) have full transaction visibility |
| Russia | No anonymity by design — CBR states settlements "do not provide for the anonymity of payments"; rated "Very Weak" | Russian data protection laws; Rosfinmonitoring oversight | None — complete de-anonymisation; full traceability; state surveillance capability | CBR maintains records of all transactions; Gosuslugi/ESIA in-person registration required |
| Singapore | Wholesale inherently limits privacy concerns; retail PBM via bank wallets with standard KYC | PDPA 2012; MAS Data Governance Guidance (May 2024) | No CBDC-specific framework; Project Mandala used ZKPs/MPC for privacy-preserving compliance | Intermediated — commercial banks (not MAS) hold user-level data |
| South Africa | Wholesale focus inherently reduces privacy concerns; Khokha 1 used Pedersen commitments + range proofs | POPIA | Not applicable (no retail CBDC); wholesale = institutional participants only | SARB (PoC operator); Information Regulator enforces POPIA for any future retail CBDC |
| South Korea | BOK "chose to improve compliance at the sacrifice of privacy"; full anonymity rejected | PIPA (amended Feb 2026, fines up to 10% of revenue) | Low anonymity — KYC through banks creates a full transaction trail; ZKP explored | Deposit-token users provide info to their bank, NOT to BOK; banks manage KYC |
| Sweden | Subject to GDPR + Swedish DP Act; privacy-by-design; no final architecture (no issuance decision) | GDPR; Swedish Data Protection Act | Moderate-to-Strong (prospective); offline card offers "conditional anonymity" for small transactions | Intermediaries would be controllers; no formal IMY position paper as of Mar 2026 |
| Thailand | Retail pilot within existing DP framework, BOT as central validator; standard banking KYC | PDPA B.E. 2562 (2019, effective June 2022) | Not detailed for the pilot; standard KYC via financial service providers | BOT (central validator) and intermediaries handle data; HRF flags surveillance risks |
| United Kingdom | "At least as private as current digital money, potentially more private"; NOT anonymous | UK GDPR; Data Protection Act 2018 (ICO supervises) | Not anonymous; PETs (pseudonymisation, ZKPs, MPC); Lords warned no cash-like anonymity | Neither BoE nor Government would access users' personal data (by design) |
| United States | Privacy/surveillance is the central political driver of opposition; cash-like privacy framing | RFPA 1978, BSA 1970, GLBA 1999 + 4th Amendment (would apply to any intermediary) | Not applicable (no CBDC); opponents reject any digital dollar as a surveillance tool | Fed would not maintain individual accounts; intermediaries would hold data |
Analytical notes:
Privacy design is the most contentious dimension of CBDC policy. The approaches can be grouped into four tiers.
Tier 1 — Maximum surveillance: Russia (explicitly no anonymity, Gosuslugi/ESIA registration required, CBR and Rosfinmonitoring have full transaction visibility — rated "Very Weak") and Nigeria (comprehensive monitoring, NIN/BVN-linked wallets, CBN has full transaction visibility). In both cases, the CBDC functions as a state surveillance instrument alongside its monetary function. South Korea sits near this tier by its own admission — Governor Rhee said the design "chose to improve compliance at the sacrifice of privacy."
Tier 2 — Controllable anonymity: China's "small anonymity, big traceability" model allows anonymous small transactions while the PBOC retains the ability to trace any transaction. This is a pragmatic middle ground that enables everyday privacy while preserving state investigatory capacity.
Tier 3 — Intermediated privacy: India (tiered anonymity with reduced identity requirements for small-value), Bahamas (tiered KYC across three levels), Jamaica (BOJ does not see individual transaction identities; data held by the wallet provider), and the United Kingdom (stated goal of "at least as private as current digital money"). These jurisdictions use the two-tier model to create a privacy buffer — the central bank is separated from individual data by commercial bank intermediaries.
Tier 4 — Privacy by design: The European Union offers the strongest privacy protections: cash-like anonymity for offline transactions, pseudonymised online transactions, and an explicit design commitment that the ECB/Eurosystem would never identify users. This reflects the EU's broader GDPR-influenced approach. Canada's research similarly favours strong privacy but concluded that purely cryptographic "hard privacy" is immature, preferring "soft privacy" (authorized access, controls, audits).
Brazil's experience is instructive as a cross-cutting lesson: privacy became the single most consequential obstacle, driving a complete pivot away from blockchain because no tested architecture reconciled banking secrecy, BCB supervisory visibility, and LGPD data-protection requirements. This suggests that privacy law may ultimately determine technology choice, not the reverse. The United States case is the political endpoint of this concern — surveillance fears are the central justification for its anti-CBDC stance.
Data protection law coverage: Nearly every jurisdiction has an identifiable data protection framework (GDPR, LGPD, PDPA, POPIA, APPI, PIPA, DPDP, NDPA, etc.); the Bahamas relies on general confidentiality protections rather than a single named CBDC-relevant DP statute. Only the EU's proposed Digital Euro Regulation explicitly addresses CBDC privacy requirements within the regulatory text itself.
Table 4: Monetary Policy Design
| Country | Holding Limits | Interest-Bearing? | Disintermediation Mitigation | Remuneration |
|---|---|---|---|---|
| Australia | N/A (wholesale); individual wCBDC transactions up to A$250,000; A$4.4m total issued | No (pilot wCBDC paid no interest) | Wholesale focus avoids retail disintermediation | Existing ESA remuneration only |
| Bahamas | Tier 1 B$500 / B$1,500/mo; Tier 2 B$5,000 / B$10,000/mo; Tier 3 B$8,000 / B$20,000/mo | No (non-interest bearing) | Tiered holding limits constrain deposit flight | None |
| Brazil | NOT VERIFIED (rDrex are tokenized bank deposits under FGC guarantee) | NOT VERIFIED (rDrex = tokenized commercial bank deposits, not a direct CBDC liability) | Tokenized-deposit model preserves bank intermediation; no change to BCB balance sheet | NOT VERIFIED |
| Canada | Not applicable (no CBDC); research (SWP 2024-4): holding limits effectively prevent deposit crowding-out | Not applicable (research modeled non-interest-bearing) | Research-stage; holding limits identified as the key safeguard | Not applicable |
| China | Tiered caps: Category 4 CNY 10,000 up to Category 1 CNY 500,000 (Cat 1 single CNY 50,000, daily CNY 100,000) | Yes — from Jan 1, 2026, verified wallets (Cat 1-3) earn 0.05% annual; first payout Mar 20, 2026 | Reclassified as bank deposit liabilities (Jan 1, 2026); reserve requirement integration | Interest at 0.05% (verified wallets) from 2026 |
| Eastern Caribbean | Registered Wallet EC$3,000–EC$20,000 (FI-set); Value-Based EC$1,000–EC$2,700/mo; merchant limits NOT VERIFIED | NOT VERIFIED | Minimal (pilot scale; now suspended) | NOT VERIFIED |
| European Union | Commission modelled EUR 3,000/person; Council (Dec 2025): ECB-set limit within a Council ceiling reviewed ≥ every 2 yrs; businesses zero limit | No — zero interest / non-remuneration by design | Holding limit + waterfall to bank account | None (by design) |
| Ghana | NOT VERIFIED — no public data (no published holding limits or wallet tiers) | NOT VERIFIED — no public data | NOT VERIFIED | NOT VERIFIED |
| India | ₹1,00,000 max wallet; ₹10,000 per-transaction; ₹50,000 daily cumulative; 250 token denominations | No — explicitly non-interest-bearing (mirrors cash) | Holding limit caps exposure | None |
| Jamaica | BOJ imposes no min/max — providers set their own (e.g. JN Pay basic J$50,000; up to J$100,000/day with KYC) | No — not interest-bearing | Non-interest design reduces incentive to shift bank deposits | None |
| Japan | Not publicly disclosed; testing holding/transaction restrictions; corporate vs P2P caps proposed; limits deemed essential | No — Expert Panel recommended no interest (treated as digital equivalent of cash) | Holding/transaction limits (under study) | None recommended |
| Nigeria | Tiered: Tier 0 N120,000 ( | No — paid no interest on holdings | Tiered limits; pivoting to wholesale | None |
| Russia | RUB 300,000 monthly top-up limit (replenishment only; wallet-to-wallet uncapped); business wallets uncapped | No — wallets do not accrue interest | Monthly top-up cap framed as bank-disintermediation safeguard; mandatory adoption raises risk | Free transactions for individuals (no interest) |
| Singapore | N/A (wholesale settlement); retail PBM restrictions are purpose-based, not amount-based | No (wholesale settlement instrument); retail PBM runs on bank deposits | Wholesale design avoids retail disintermediation | N/A |
| South Africa | NOT VERIFIED / N/A (no retail CBDC issued) | NOT VERIFIED / N/A (no retail CBDC issued) | Wholesale focus; "no compelling immediate need" for retail | N/A |
| South Korea | Pilot: 1M won (~$689) at any time; 5M won cumulative (production caps not disclosed) | No indication digital won would bear interest | Deposit-token model preserves bank role; pilot holding caps | Interest policy remains with banks on underlying deposits |
| Sweden | Potential caps to limit deposit migration (not decided); ~1-3% of GDP demand deemed manageable | Not decided (non-remunerated more likely) | Holding caps under consideration; "do no harm" design | Not decided |
| Thailand | Not publicly disclosed for retail pilot (NOT VERIFIED); Deposit Protection Act covers up to 1M baht | No indication digital baht would bear interest; sandbox reserves cannot be deployed (no yield) | Pilot-scale; no production decision | None |
| United Kingdom | Proposed GBP 10,000-20,000 (2023 consultation, unchanged); Treasury Committee urged lower, closer to EU EUR 3,000 | No — non-interest bearing (zero remuneration) by design | Holding limit is primary safeguard; FS Paper No. 53 (Nov 2025) modelled deposit flight | None proposed |
| United States | Not applicable (no CBDC issued) | Not applicable (no CBDC issued) | Not applicable | N/A |
Analytical notes:
Holding limits are the primary tool jurisdictions use to mitigate bank disintermediation risk.
Holding limit comparison (where a per-person retail figure exists):
| Jurisdiction | Limit (approximate USD equivalent) |
|---|---|
| European Union | EUR 3,000 (~$3,200) modelled — most conservative |
| Bahamas | B$8,000 (~$8,000) — Tier 3 maximum |
| United Kingdom | GBP 10,000-20,000 (~$12,600-25,200) — proposed range |
| China | CNY 10,000-500,000 (~$1,400-69,000) — tiered by wallet class |
| India | ₹1,00,000 (~$1,200) |
| Nigeria | N120,000-N5,000,000 (~$75-3,125) — tiered by wallet class |
| Russia | RUB 300,000/month top-up (~$3,300) — replenishment only |
| South Korea | 1,000,000 won (~$689) at a time — pilot only |
The European Union's modeled EUR 3,000 limit is the most conservative among major economies, reflecting strong bank lobbying and disintermediation concerns; under the Council's December 2025 position the ECB would set the actual limit within a Council-agreed ceiling reviewed at least every two years. The United Kingdom's proposed GBP 10,000-20,000 range is substantially more generous, though the Treasury Committee has urged a lower figure closer to the EU's. India's ₹1,00,000 limit is low in absolute terms but adequate for the target population.
The deposit-token convergence: China's January 2026 reclassification is the most radical monetary policy shift in the CBDC landscape. By converting e-CNY holdings in commercial bank wallets into deposit liabilities (rather than central bank liabilities) and beginning to pay interest (0.05% from Jan 1, 2026, first payout Mar 20, 2026), China effectively moved away from the pure CBDC model toward a tokenized-deposit approach — a move that the Peterson Institute argues means the e-CNY may no longer qualify as a CBDC under standard definitions. Brazil (Drex wDrex/rDrex tokenized deposits) and South Korea (deposit-token hybrid via LG CNS) have taken similar approaches from the outset, preserving bank intermediation by design. This convergence suggests the distinction between "CBDC" and "tokenized bank deposits" may be dissolving in practice.
Interest-bearing CBDCs: Only China has introduced interest on CBDC holdings (0.05% from January 2026), and this followed the reclassification to a deposit model. The European Union, United Kingdom, India, and Japan have all explicitly proposed or recommended non-interest-bearing designs to avoid competing with bank deposits. Russia offers free transfers for individuals but no interest — the incentive is convenience and mandatory adoption rather than yield.
Disintermediation risk: Russia's combination of a top-up-only monthly cap, uncapped wallet-to-wallet transfers, and mandatory adoption (from 1 September 2026) creates a high disintermediation risk profile. Banks in Russia will be required to offer digital ruble services, potentially accelerating deposit migration where other jurisdictions rely on stricter holding-limit safeguards.
Table 5: Financial Inclusion
| Country | Unbanked / Underbanked Population | Inclusion-Specific Design Features | Key Inclusion Programs |
|---|---|---|---|
| Australia | <1% unbanked (99%+ bank penetration) | Low priority; retail CBDC would not materially improve access | Wholesale market-efficiency focus; offline a potential resilience use case |
| Bahamas | ~18-20% unbanked (2018 IMF) | Tiered KYC (Tier 1 minimal ID); mobile-first; offline (under development) | Sand Dollar Ambassadors; Mastercard-linked prepaid card; Family Island targeting (measured impact limited) |
| Brazil | ~16% unbanked/underbanked; 23.8M lack internet | Builds on Pix (150M+ users); tokenization to democratize asset ownership | Pix-integration design; offline access NOT VERIFIED; digital divide flagged as a barrier |
| Canada | Studied but case weakened by strong existing digital payments (Interac, forthcoming RTR) | Research only; even $1.50/month friction drastically cuts uptake (~$440M/yr subsidy needed) | None deployed; extended-offline model studied for remote/northern communities |
| China | ~234M unbanked (figure NOT VERIFIED/possibly outdated) | Hardware wallets, SIM-based wallets (no smartphone), Category 4 (phone-only), zero fees | Government benefit distribution; red-envelope campaigns; transit integration |
| Eastern Caribbean | ~56% of Caribbean population unbanked | Low-barrier Value-Based wallet (no bank account, simplified KYC); mobile-first | Cross-island payment unification (8 territories); concrete outcomes limited by low adoption; now suspended |
| European Union | No specific figure | Offline functionality and physical cards (no smartphone); European Accessibility Act compliance | Free basic use for individuals; public-sector distribution for unbanked; ONCE Foundation agreement |
| Ghana | ~47% lack internet access (self-reported) | Offline-first design ("live off-grid and use it as cash") | Coexists with mobile money; pilot via CalBank, Vodafone Cash |
| India | ~190M unbanked (Findex 2021); ~65% rural | Token-based offline (NFC, Oct 2025); UPI integration; programmable welfare | G-SAFAL (agriculture); DEEPAM 2.0 (cooking gas); PMGKAY (food, targets 800M); state DBT pilots |
| Jamaica | 22.8% of adults unbanked (NFIS 2023); ~80% of transactions still cash | Low-KYC accounts (one ID); bank wallet apps | J$2,500 to first 60,000 users; J$25,000 to first 10,000 micro-merchants; growth driven by existing users |
| Japan | No specific figure | Universal access, disaster resilience; biometric auth prioritized for elderly | Existing Zengin System (1973) reduces urgency |
| Nigeria | ~38M unbanked | Speed Wallet (Tier 0/1) — phone number only; no bank account | eNaira promoted for inclusion; largely FAILED (98.5% wallets inactive after 1 yr); NIN a barrier |
| Russia | No specific figure | Free transactions for individuals; integration with bank apps; universal QR codes | Mandatory adoption from Sep 2026; high-friction Gosuslugi/ESIA registration a barrier |
| Singapore | High inclusion (>96% bank account penetration) | Low priority; FAST/PayNow diminish urgency | Purpose-Bound Money for targeted government transfers |
| South Africa | ~15% unbanked (~85% banked; Findex 2021) | N/A (wholesale research only); retail CBDC ruled out near-term | PayShap real-time payments and NPS expansion preferred over retail CBDC |
| South Korea | High bank access (inclusion "not a key factor", Gov. Rhee) | Government subsidy distribution via deposit tokens; offline tested 2022 | EV charging subsidies (treasury pilot); childcare/culture vouchers |
| Sweden | Uniquely cashless (~5% in-store cash use, 2025) | Offline card solution (Phase 4); "do no harm" design | Bring digitally-excluded into payments market; recommends households keep SEK 1,000 cash/adult |
| Thailand | Bank account penetration ~82% of adults | Rural/underbanked access tested; PromptPay benchmark | ~10,000 test participants; BOT argues PromptPay already serves inclusion |
| United Kingdom | ~1.2M unbanked; ~48% would find loss of cash access "extremely problematic" | Inclusion a key design priority; deferred offline; staged access | Complementary to cash (not a replacement) |
| United States | Previously ~4.5% / 5.9M unbanked households (FDIC 2021; no longer cited by current administration) | N/A (no CBDC) | FedNow, Zelle/Venmo/CashApp, and GENIUS-Act stablecoins cited as alternatives |
Analytical notes:
Financial inclusion motivations divide sharply between developing and developed economies.
Developing economy approaches: India has the most sophisticated inclusion-focused CBDC design, with programmable welfare distribution (G-SAFAL for agriculture, DEEPAM 2.0 for cooking gas, PMGKAY for food security, the last targeting 800 million beneficiaries) aimed at ~190M unbanked citizens — even as e₹-R circulation contracted ~24% YoY in FY2025-26. Ghana's offline-first design directly addresses the reality that an estimated ~47% of its population lacks internet access — arguably the purest inclusion-driven CBDC program among all 20 jurisdictions, though the pilot was only declared "completed" in May 2026 and the retail eCedi remains unlaunched. Nigeria targeted ~38M unbanked with simplified wallets (Speed Wallet requiring only a phone number), but 98.5% of eNaira wallets were inactive after one year — demonstrating that low barriers to wallet creation do not guarantee usage. Bahamas designed its Sand Dollar specifically for archipelagic geography and hurricane resilience, yet measured inclusion impact remains limited after five years.
Developed economy approaches: Australia (99%+ bank penetration), United Kingdom (~1.2M unbanked), Japan, Singapore, and Canada generally find that existing payment infrastructure already serves inclusion needs. Australia explicitly concluded there was "no clear public interest case" for retail CBDC; Canada's research found even modest friction ($1.50/month) drastically cuts uptake. The U.S. cites FedNow, established payment apps, and GENIUS-Act stablecoins as alternatives. These jurisdictions tend to pursue wholesale CBDC (for market efficiency) rather than retail CBDC (for inclusion).
China's bridging approach: China's design bridges the developing/developed divide. With a large unbanked population (figure NOT VERIFIED/possibly outdated) in the world's second-largest economy, China developed hardware wallets for the elderly, SIM-based wallets that do not require smartphones, and a phone-number-only Category 4 wallet — the most comprehensive effort to bridge digital divides among any jurisdiction surveyed. Red-envelope campaigns and transit integration provided compelling use cases that drove adoption beyond inclusion into everyday convenience.
The inclusion paradox: Across jurisdictions, CBDC adoption has been lowest precisely where the inclusion need is greatest. The populations most likely to benefit (unbanked, rural, elderly) are also the most difficult to reach and the least likely to adopt new digital financial instruments. Nigeria's experience is the starkest illustration: coercive measures (cash withdrawal limits during the naira redesign crisis) temporarily drove eNaira adoption but generated public backlash rather than sustainable usage. Jamaica's 2025 growth (transaction values +550%, volumes +267% YoY) came from existing users transacting more, not new unbanked sign-ups.
Table 6: Cross-Border & Interoperability Participation
| Country | Cross-Border CBDC Projects | Bilateral Partnerships | BIS Project Participation |
|---|---|---|---|
| Australia | Project Dunbar (with BIS, Singapore, Malaysia, South Africa); no Dunbar successor announced | Australia-Saudi Arabia collaboration | Project Dunbar; BIS committees |
| Bahamas | None (domestic only); CARICOM regional-integration discussions | No data | Included in BIS/IMF interoperability studies |
| Brazil | HKMA-BCB partnership (Oct 2024, Ensemble Sandbox x Drex); Phase 2 trade-finance/FX themes | HKMA (Hong Kong); MERCOSUR integration NOT VERIFIED | Project Mariana relevant (Brazil not a direct participant); mBridge NOT VERIFIED |
| Canada | Project Jasper Phase 4 (Jasper-Ubin, with MAS, Bank of England); Project Samara (tokenized bond, Mar 2026) | MAS, Bank of England (legacy Jasper) | BIS Toronto Innovation Centre (opened Jun 2024; FMI/suptech/open-finance focus) |
| China | mBridge (with HKMA, Bank of Thailand, UAE, Saudi Arabia; BIS withdrew Oct 2024); 2026 pilots with Singapore, Thailand, Hong Kong, UAE, Saudi Arabia | Multiple bilateral digital-currency agreements; Belt and Road / ASEAN corridors | mBridge (BIS Innovation Hub, BIS now withdrawn) |
| Eastern Caribbean | Inherently cross-border (8 territories); now pivoting to CARICOM Payments and Settlement System (CAPS) and PAPSS pilots | CARICOM integration discussions | BIS/IMF case-study interest |
| European Union | Euro-area-wide scope (20 states); TIPS interlinking (starting with India); Project Mariana (concluded) | Non-euro EU states via NCB-ECB agreement (COM(2023) 368) | Project Stella (ECB-BOJ); NOT a participant in BIS mBridge |
| Ghana | Stated next design phase (May 2026): cross-border + wholesale within ECOWAS (no live corridor) | No data | NOT in BIS Innovation Hub cross-border projects |
| India | Joined BIS Project Rialto and Project Mandala Phase 2 (first confirmed BIS multilateral participation); Apr 2026 proposal to link BRICS CBDCs | MoU with MAS; bilateral talks with MAS and Central Bank of UAE; interest in mBridge | Project Rialto; Project Mandala Phase 2 |
| Jamaica | None (JAM-DEX domestic only); CARICOM/CAPSS discussions and PAPSS pilot (regional, not JAM-DEX) | No data | No BIS CBDC participation |
| Japan | Project Stella (ECB-BOJ, 2016-2020); Project Agora (BIS, launched Apr 2024, 7 central banks) | No data; NOT a participant in mBridge | Project Stella; Project Agora (first-phase report 27 May 2026, atomic multi-currency settlement feasible) |
| Nigeria | Initially domestic-only; CBN approved eNaira for inbound remittances (minimal uptake); no ECOWAS integration | No data | NOT in major BIS cross-border pilots |
| Russia | BRICS Bridge initiative (Russia-proposed, 2024 BRICS chair) — largely conceptual; bilateral with "friendly states" | BRICS member-state coordination (limited enthusiasm from partners) | NOT joining BIS mBridge (sanctions context) |
| Singapore | Among the most active globally — Jasper-Ubin, Ubin+, Dunbar, Cedar x Ubin+, Mandala (Phase 2 Nov 2025), Mariana, Agora, Swift CBDC sandbox | MAS-Bundesbank MoU (Nov 2025); multiple bilateral arrangements | Dunbar; Mariana; Agora; Mandala; GL1 initiative; NOT a mBridge participant |
| South Africa | Project Dunbar (with Australia, Malaysia, Singapore); PK2x explores regional African settlement (SA↔Kenya) | SADC payment-integration context | Project Dunbar; BIS Innovation Hub Johannesburg Centre |
| South Korea | Project Agora (BIS, Apr 2024, 7 central banks incl. BOK); mBridge observer status | Won-backed stablecoin as alternative cross-border pathway | Project Agora; mBridge (observer only) |
| Sweden | BIS Project Icebreaker (with Bank of Israel, Norges Bank; concluded Mar 2023) | No data | Project Icebreaker; path now tied to EU digital euro |
| Thailand | Founding member of mBridge (with BIS, China, Hong Kong, UAE; Saudi Arabia joined 2024); Inthanon-LionRock | Hong Kong HKMA partnership | mBridge (BIS Innovation Hub; handed to partners Oct 2024) |
| United Kingdom | Project Rosalind (BIS Innovation Hub London + BoE, domestic API focus); cross-border explicitly EXCLUDED from Oct 2025 design notes | No formal digital-pound/digital-euro arrangement (would need bilateral negotiation) | Project Rosalind; BIS/G7/G20 work |
| United States | Research only: Project Cedar (NY Fed, wholesale FX); BIS Project Icebreaker / mBridge (US withdrew from active mBridge participation) | None (strategy relies on stablecoins, FedNow, correspondent banking) | Project Hamilton (completed; MIT/Boston Fed) |
Analytical notes:
Cross-border CBDC participation is concentrated among a small number of highly active jurisdictions.
Cross-border leaders: Singapore leads with participation in Dunbar, Mariana, Agora, Mandala (Phase 2 launched November 2025), the GL1 initiative, Cedar x Ubin+, and Project Ubin+ — the broadest cross-border portfolio of any jurisdiction surveyed, plus a November 2025 MoU with the Deutsche Bundesbank. Singapore treats cross-border interoperability as a core competitive advantage. China and Thailand are co-founders of mBridge (BIS Innovation Hub), the most advanced multi-CBDC cross-border platform, which also includes Hong Kong, UAE, and Saudi Arabia — though the BIS withdrew from mBridge in October 2024. India confirmed its first BIS multilateral participation in 2025-26 (Projects Rialto and Mandala Phase 2) and proposed linking BRICS-member CBDCs.
BIS-coordinated projects: The BIS Innovation Hub serves as the primary coordinator for multilateral CBDC projects. Key projects and their participants among the 20 jurisdictions:
- Project Dunbar (multi-CBDC platform): Australia, Singapore, South Africa, Malaysia
- Project Stella (DvP and cross-border): Japan, European Union
- Project Agora (tokenized cross-border, 7 central banks): Japan, South Korea; first-phase report 27 May 2026
- Project Mandala (privacy-preserving compliance): Singapore, India (Phase 2)
- Project Rialto (instant cross-border settlement): India
- mBridge (multi-CBDC bridge): China, Thailand, Hong Kong, UAE, Saudi Arabia (BIS withdrew Oct 2024)
- Project Mariana (DeFi-inspired FX): Singapore, BIS, Swiss National Bank, Banque de France
- Project Icebreaker (cross-border retail): Sweden, Bank of Israel, Norges Bank
- Project Samara / Jasper (wholesale): Canada
Alternative networks: Russia's BRICS Bridge initiative represents a parallel cross-border CBDC ambition outside BIS coordination, reflecting sanctions-driven exclusion from Western financial infrastructure — though it remains largely conceptual as of mid-2026, with key partners showing limited enthusiasm. The bifurcation of the global CBDC interoperability landscape into BIS-aligned and BRICS-aligned networks is a significant geopolitical development; India's April 2026 proposal to link BRICS-member CBDCs is a proposal, not an agreed arrangement.
Unique cross-border design: The Eastern Caribbean's DCash was the only CBDC worldwide designed from inception to operate across multiple sovereign territories (8 ECCU member states). This remains an unreplicated achievement, though the program is now concluded and its successor suspended in favor of a Fast Payment System and CAPS.
Domestic-only / no-meaningful-cross-border jurisdictions: Bahamas, Jamaica, Nigeria, and Ghana have no meaningful cross-border CBDC activity yet (Ghana has only announced a design-phase intent toward ECOWAS settlement). For small economies with high remittance dependence, this is a significant missed opportunity.
Table 7: Adoption Outcomes (Launched / Operated CBDCs Only)
This table covers only the six jurisdictions that have launched or operated a CBDC with real money: Bahamas, Jamaica, and Nigeria (launched, legal tender); China and India (operational at pilot scale); and Eastern Caribbean (launched as a pilot, now concluded and its successor suspended). Russia is excluded because its digital ruble is a pilot with a legally-mandated future launch (1 Sep 2026), not yet a full live retail launch. All figures below are self-reported by the issuing central bank or tracker unless otherwise noted, and should be treated as indicative.
| Country | Launch Date | Wallets / Users | Circulation Volume | Circulation as % of Cash | Transaction Data | Merchant Acceptance | Key Adoption Challenge |
|---|---|---|---|---|---|---|---|
| Bahamas | Oct 20, 2020 | ~138,000 personal wallets (Dec 2024, +16% YoY); ~144,000 consumer; ~2,100 business (Nov 2024) | B$2,482,045 (early 2025) | ~0.39% of physical cash | ~80% of domestic mobile payments (Apr 2023); B$4.5M/mo P2B+B2B (Nov 2023) | ~455 active merchants reported; agency-banking integration in progress | Low adoption; physical cash rose ~20%; bank-integration mandate pending (~mid-2026) |
| Jamaica | Jun 14, 2022 (legal tender) | ~282,274 registered wallets (end-2024, +7% YoY) | J$258.5M (end-2024) / ~J$260.05M (end-2025) | ~0.1% of currency | Transaction value +550% YoY, volume +267% YoY (2025) — driven by existing users | ~2,379 merchants (Sep 2024); only two public wallets (Lynk, JN Pay) | Slow adoption ("a disappointment" — Gov. Byles); slow POS integration |
| Nigeria | Oct 25, 2021 | ~98.5% of wallets inactive after 1 yr (IMF); ~13M wallets figure circulates (not re-verified) | N18.31bn (~$11.4M) as of Feb 2025; CBN minted only N3bn (0.09% of cash supply) | ~0.37% of currency in circulation | ~2.2M transactions by Jul 2024 (negligible for 220M population) | ~10% of POS merchants downloaded wallets (yr 1) | 98.5% wallet inactivity; public distrust; NIN barrier; pivoting to wholesale |
| China | Phased pilot from Apr 2020 | ~2.25 billion wallets (Sept 2025, multiple per user) | CNY 16.7 trillion (~$2.37T) cumulative as of Nov 2025 | ~0.16% of M0 (June 2023) | ~3.48 billion cumulative transactions; avg ~CNY 428 (down from CNY 1,895 in 2023) | ~5.6M merchants (mid-2023); 26-29+ cities, 17 provinces | Reclassification toward deposit-money (Jan 2026); legal vacuum; declining avg ticket |
| India | e₹-R: Dec 1, 2022; e₹-W: Nov 1, 2022 (pilots) | ~7-8M retail users (Dec 2025); ~19 participating banks | e₹-R ₹771.7 crore (~$90M) as of Mar 31, 2026, down ~24% YoY from ₹1,016.5 crore | No data (negligible) | e₹-W collapsed from ₹10 crore (Mar 2023) to ₹0.08 crore (Mar 2024) | ~300,000 merchants, 26 cities (end 2024) | First reported circulation contraction (FY2025-26); no full-launch decision |
| Eastern Caribbean | Mar 2021 – Jan 2024 (pilot) | 4,000+ accounts (end 2021); 21 FIs + 10 govt agencies (Jan 2024) | EC$2.45M (~US$906,551) in circulation (Mar 2023) | ~0.16% of currency (Mar 2023) | NOT VERIFIED (no granular volumes released) | 400+ merchants (Mar 2023) | ~56-day outage (2022, expired certificates); pilot concluded; DCash 2.0 suspended |
Analytical notes:
Adoption data reveals a stark gap between launch and usage across all jurisdictions that have moved beyond pilot. All figures are self-reported and should be read as indicative.
Circulation as share of cash supply: Where data is available, CBDC circulation remains negligible. Bahamas' Sand Dollar (B$2.5M, ~0.39% of physical cash) and Nigeria's eNaira (N18.31bn, ~0.37% of currency in circulation) both represent less than 0.4% after years of operation. In the Bahamas, physical cash in circulation actually increased (~20%) despite the Sand Dollar's availability — a paradox that undermines the narrative that CBDC will reduce cash dependency. China's e-CNY was only ~0.16% of M0 (June 2023) despite its scale.
Wallet creation vs. active usage: The gap between wallet creation and active usage is enormous. Nigeria's 98.5% wallet inactivity rate after one year (IMF WP/23/104) is the most dramatic failure metric in the global CBDC landscape. Bahamas created ~144,000 consumer wallets but only a few hundred merchants actively process transactions. Creating a wallet is frictionless; creating a reason to use it is not.
China and India as outliers, and the decline signal: China's e-CNY dwarfs all others in absolute terms (~2.25B wallets, ~3.48B transactions, CNY 16.7T cumulative value), reflecting the world's largest population, aggressive merchant/transit integration, and government-coordinated promotion. Yet its average transaction value fell from CNY 1,895 (2023) to ~CNY 428, and its January 2026 reclassification toward a deposit model suggests the pure CBDC approach was not achieving the scale the PBOC sought. India's e₹-R, the second-largest pilot, registered its first-ever circulation contraction in FY2025-26, falling ~24% YoY to ₹771.7 crore, while e₹-W had already collapsed from ₹10 crore to ₹0.08 crore — a caution that pilot momentum can reverse.
Growth trajectories: Jamaica shows the most promising relative growth (transaction value +550% YoY in 2025) but from a very low base and concentrated among existing users — outgoing Governor Byles called the slow adoption "a disappointment."
Failure and suspension: The Eastern Caribbean's DCash is the clearest failure case. A roughly two-month outage (2022) caused by expired Hyperledger Fabric node certificates destroyed user confidence and became a globally cited case study in CBDC technical risk. The ECCB ultimately concluded the pilot in January 2024 and suspended DCash 2.0 development on 13 February 2026, pivoting to a Fast Payment System and CARICOM (CAPS) integration instead.
Cross-cutting lesson: Across all jurisdictions, the pattern is consistent: technical launch is far easier than driving adoption. Bank cooperation, merchant acceptance, and compelling use cases matter more than the underlying technology. The jurisdiction with the highest adoption (China) invested heavily in ecosystem integration — transit, merchant subsidies, government transfers — rather than relying on the CBDC's inherent features to drive demand.
Cross-Cutting Themes
1. The Wholesale Pivot
A significant trend across the 20 jurisdictions is the pivot from retail to wholesale CBDC. Australia explicitly concluded that retail CBDC offers insufficient benefits given existing payment infrastructure, completing its wholesale Project Acacia in February 2026 (final report 18 May 2026). Singapore has focused on wholesale from the start, achieving its first live wholesale CBDC transaction in November 2025. South Africa's November 2025 Position Paper found "no compelling immediate need" for retail CBDC. Nigeria is pivoting from retail to wholesale after the eNaira's adoption failure. Ghana reframed the eCedi toward wholesale and cross-border use in May 2026. Thailand completed its retail pilot but pivoted to a Programmable Payment Sandbox. Canada scaled down retail work in 2024 while continuing wholesale experiments (Project Samara, March 2026). Eastern Caribbean suspended its retail successor in favor of fast payment systems. This pattern suggests that wholesale CBDC may be the more viable near-term application.
2. Fast Payments and Stablecoins as CBDC Alternatives
Several jurisdictions have concluded that fast payment systems — or privately-issued stablecoins — deliver most of the benefits of retail CBDC with lower risk. Australia cites its New Payments Platform. The United States relies on FedNow and GENIUS-Act (PL 119-27) stablecoins as explicit alternatives to a CBDC. South Africa points to PayShap. The Eastern Caribbean suspended DCash 2.0 to prioritize a Fast Payment System. Thailand pivoted to a programmable-payments/stablecoin sandbox. Canada enacted a Stablecoin Act (Royal Assent 26 Mar 2026, not yet in force) and saw its first regulated CAD stablecoin launch (CADD, May 2026). This convergence raises a fundamental question: if fast payments and regulated stablecoins satisfy the same use cases, is retail CBDC necessary?
3. The Deposit-Token Convergence
China (January 2026 reclassification toward deposit liabilities, with 0.05% interest), Brazil (Drex wDrex/rDrex model), and South Korea (deposit-token hybrid, explicitly "an intermediate stage between a CBDC and stablecoins") are converging on a model where digital money is a bank deposit liability rather than a central bank liability. This blurs the traditional CBDC definition and may represent the future of programmable money — tokenized bank deposits supervised by central banks, rather than direct central bank issuance.
4. Geopolitical Dimensions
The CBDC landscape is bifurcating along geopolitical lines. BIS-coordinated projects (Dunbar, Stella, Agora, mBridge, Mariana, Mandala, Rialto) connect Western-aligned and neutral jurisdictions. Russia's BRICS Bridge initiative creates an alternative network outside Western financial infrastructure, though it remains largely conceptual. China participates in both BIS projects and BRICS coordination, positioning itself as a bridge; India's April 2026 proposal to interconnect BRICS-member CBDCs (a proposal, not an agreement) adds to this dynamic. The United States' ban on domestic CBDC (EO 14178, in force) combined with its promotion of stablecoins (GENIUS Act, PL 119-27) represents a distinct third approach — leveraging private-sector dollar-denominated digital assets rather than central bank issuance to maintain dollar dominance.
5. Technology Is Not the Binding Constraint
Across all 20 jurisdictions, technology has not been the primary barrier to CBDC success. United States research (Project Hamilton) demonstrated 1.7M transactions per second. Japan achieved 50K TPS with a 100K target. China has processed ~3.48B transactions. Multiple DLT platforms (Hyperledger Fabric, R3 Corda, Hyperledger Besu, Hedera, Quorum) and centralized architectures have all proven technically viable. The binding constraints are adoption, regulatory design, privacy-law compliance, and political will.
The Eastern Caribbean's outage (expired certificates, not a fundamental technology failure) and Brazil's pivot (privacy-law incompatibility, not performance) both illustrate that operational and legal challenges, not computational limits, determine CBDC outcomes.
6. The Privacy-Surveillance Spectrum
Perhaps the most consequential design choice for any CBDC is where it sits on the privacy-surveillance spectrum, reflecting national governance values more than technical constraints. Russia and Nigeria treat CBDC as a tool for comprehensive financial surveillance. China seeks a middle ground ("controllable anonymity"). The European Union and Canada design privacy protections into the architecture itself (offline anonymity, central-bank exclusion from individual data). The United States cited surveillance concerns as a primary justification for opposing CBDC entirely. These positions are fundamentally political, not technical — every architecture surveyed can be configured for more or less privacy.
Methodology
All data in these tables is sourced exclusively from the 20 jurisdiction research files in the CBDC Frameworks domain and the canonical fact matrix. Where a country file does not contain information for a given cell, "No data" or "NOT VERIFIED" is entered as the source records it. No external claims or inferences have been added. Country names are rendered consistently across all tables. Adoption and transaction figures in Table 7 are self-reported by the issuing authority and flagged accordingly.
Source Files
Asia-Pacific:
- Australia —
regulations/asia-pacific/australia.md - China —
regulations/asia-pacific/china.md - India —
regulations/asia-pacific/india.md - Japan —
regulations/asia-pacific/japan.md - Singapore —
regulations/asia-pacific/singapore.md - South Korea —
regulations/asia-pacific/south-korea.md - Thailand —
regulations/asia-pacific/thailand.md
Americas:
- Bahamas —
regulations/americas/bahamas.md - Brazil —
regulations/americas/brazil.md - Canada —
regulations/americas/canada.md - Eastern Caribbean —
regulations/americas/eastern-caribbean.md - Jamaica —
regulations/americas/jamaica.md - United States —
regulations/americas/united-states.md
Europe:
- European Union —
regulations/europe/european-union.md - Russia —
regulations/europe/russia.md - Sweden —
regulations/europe/sweden.md - United Kingdom —
regulations/europe/united-kingdom.md
Middle East & Africa:
- Ghana —
regulations/middle-east-africa/ghana.md - Nigeria —
regulations/middle-east-africa/nigeria.md - South Africa —
regulations/middle-east-africa/south-africa.md
Data Currency
All data reflects information available in source files and the canonical fact matrix as of June 4, 2026. CBDC programs are rapidly evolving; figures and status descriptions may change.
Coverage Notes
- "No data" / "NOT VERIFIED" entries are concentrated in jurisdictions at early research stages (Ghana, Sweden, Thailand, Japan, Canada) and on dimensions where the source files contain limited quantitative data.
- Wholesale-only jurisdictions (Australia, Singapore, South Africa) have "N/A" entries for retail-specific dimensions such as retail holding limits, retail financial-inclusion design, and retail privacy models.
- The United States is marked "N/A" or "anti-CBDC" across most dimensions: the binding prohibition is EO 14178 (in force), while statutory bans passed both chambers in differing, unreconciled forms and are not yet enacted.
- Table 7 (Adoption Outcomes) includes China and India despite their "pilot" classification because both have issued real money at scale. Russia is excluded because its digital ruble has a legally-mandated but not-yet-effected large-scale launch (1 Sep 2026).
- Eastern Caribbean is included in Table 7 as a concluded/suspended CBDC to capture lessons from its operational period (March 2021 - January 2024).
- All adoption and transaction figures in Table 7 are self-reported by the issuing authority or trackers and should be treated as indicative, not independently audited.
- Holding-limit USD equivalents in Table 4 analytical notes are approximate conversions for comparative purposes only.