The Regulatory Spectrum

1. The CBDC Spectrum

Every jurisdiction studied in this research can be placed on a regulatory spectrum ranging from outright legislative prohibition to full nationwide launch. This spectrum is not a ladder of progress — the evidence strongly suggests that position on the spectrum does not predict success. Instead, it reveals a paradox: the jurisdictions that moved fastest to launch show the worst adoption outcomes, while those still in preparation have invested the most in design quality.

This analysis draws exclusively from verified data in the 20 jurisdiction profiles (Phase 1 and Phase 2 research) and the economic outcomes guidance document. No external claims are introduced. Where data is uncertain or contested (such as China's post-reclassification CBDC status), this is noted explicitly. Adoption and transaction figures are self-reported by issuing central banks and trackers unless otherwise stated, and are flagged accordingly.

The seven positions on the spectrum, from most restrictive to most deployed, are defined below. Across all 20 jurisdictions, six have a launched or live CBDC (

Bahamas Sand Dollar,

Nigeria eNaira,

Jamaica JAM-DEX, the Eastern Caribbean DCash [pilot concluded and successor suspended],

China e-CNY [pilot-scale], and

India e₹), one is in launched-limited deployment with a legally mandated full-launch date (

Russia), and one is the only major economy actively opposed to CBDC issuance (

United States).

Position 1: Legislative Prohibition

Country:

United States

The US is the only major economy formally opposed to CBDC development. The binding prohibition is Executive Order 14178 (January 23, 2025), which bans all federal agencies from establishing, issuing, or promoting CBDCs and revoked the prior EO 14067. Statutory bans have advanced but are not enacted: the House passed the Anti-CBDC Surveillance State Act (H.R. 1919) 219-210 in July 2025; the Senate passed the 21st Century ROAD to Housing Act 89-10 in March 2026 with a CBDC moratorium through December 31, 2030; and the House passed an amended version of that Act 396-13 on May 20, 2026 with the moratorium retained — but the two chambers' versions remain unreconciled, so no statutory ban is in force. The GENIUS Act (S. 1582), signed July 18, 2025 as Public Law 119-27, positions regulated stablecoins as the US alternative to a CBDC. Kevin Warsh was sworn in as Federal Reserve Chair on May 22, 2026 (Senate confirmed 54-45) and has reaffirmed his opposition to a retail CBDC.

Mechanism: Executive order (in force), advancing-but-unenacted legislation, stablecoin-first strategy.

Outcome data: No CBDC to assess. Project Hamilton (Federal Reserve Bank of Boston + MIT) demonstrated 1.7 million TPS before being archived. FedNow (instant payment service, launched July 2023) is positioned as addressing the use cases that CBDC proponents cite. The US remains a global outlier; the IMF has noted this is the only major nation to formally bar CBDC development while 130+ countries explore them.

Position 2: Research Only / No Commitment

Countries:

Japan,

Australia,

South Africa,

Canada

These jurisdictions have conducted extensive research and proof-of-concept experiments but have explicitly concluded there is no compelling case to proceed to retail issuance.

Japan: The Bank of Japan has run a methodical PoC Phase 1 → Phase 2 → Pilot sequence (2020-2024) and operated an API sandbox with 18 companies (as of October 2024). Stress tests achieved 50,000 TPS against a 100,000 TPS target. In February 2026, the 10th Liaison and Coordination Committee meeting marked the end of the exploratory phase and formed three Discussion Groups, expanding research to wholesale CBDC and tokenization. A decision on whether to issue a retail Digital Yen is expected in 2026. The BOJ has maintained "no plan to issue a CBDC" (June 2025/June 2026). Legislative amendments to the BOJ Act, Criminal Code, and Civil Code would be required; no Diet bill had been introduced as of March 2026.

Australia: The RBA and Australian Treasury concluded in September 2024 that "a clear public interest case to issue a retail CBDC has yet to emerge." The RBA has pivoted to wholesale CBDC under Project Acacia. Experimentation concluded in February 2026 with 20 use cases (12 pilot + 8 PoC), and the RBA and DFCRC published the Project Acacia final report on May 18, 2026: A$4.4m in pilot wholesale CBDC was issued across 8 use cases, with DFCRC estimating A$24bn/yr in potential gains (a self-reported research estimate). The pilot wCBDC was a research issuance, not a live launch. Australia's well-functioning New Payments Platform (NPP) and >99% account penetration reduce the perceived need for a retail CBDC.

South Africa: The SARB published a definitive Position Paper on November 27, 2025 concluding that a retail CBDC is technically feasible but there is "no compelling immediate need." Project Khokha (PK1, PK2, and the sandbox-stage PK2x) explored wholesale CBDC for interbank settlement; the National Payment System Vision 2030+ Consultation Paper (February 24, 2026) reinforces the "no immediate need for retail CBDC" stance and does not introduce a CBDC. South Africa maintains wholesale CBDC interest (Project Khokha 2x: tokenized settlement, bank-issued stablecoins for regional African settlement such as SA↔Kenya, trade-finance) while explicitly deprioritizing retail.

Canada: The Bank of Canada formally scaled down retail CBDC work in September 2024 (Governor Macklem: "not currently a compelling case"), shifting to a contingency-planning / readiness posture. No CBDC authority exists — both the Bank of Canada Act and the Currency Act would require legislative amendment to issue one. Wholesale experimentation continues: Project Samara completed on March 5, 2026, settling a CAD $100M tokenized bond with wholesale W-CAD on Hyperledger Fabric (BoC, EDC, RBC, TD). The Stablecoin Act (Bill C-15) received Royal Assent on March 26, 2026 but is not yet in force and expressly excludes CBDCs; the first regulated CAD-backed stablecoin (CADD) launched May 4, 2026 — a private stablecoin, not a CBDC. Canada's trajectory has converged with the US skeptical stance.

Outcome data: No retail CBDCs launched; no retail adoption data. The primary output is technical knowledge, wholesale settlement experiments, and policy clarity. Japan's cautious stance is notable given its advanced digital payment ecosystem and aging population. Australia's wholesale pivot under Project Acacia — A$4.4m issued across multiple DLT platforms (private Hedera/HashSphere, Canvas Connect, Redbelly Network) — suggests wholesale tokenized-asset settlement may be the most productive near-term application of central bank digital money. South Africa's SARB, despite one of Africa's strongest data-protection regimes (POPIA), concluded the risks of retail CBDC currently outweigh the benefits. Canada demonstrates that a world-class central bank research body can deliberately decline to deploy while continuing wholesale work.

Position 3: Cautious Design Phase

Countries:

United Kingdom,

Sweden,

Ghana

These jurisdictions have designed or piloted CBDCs but have not committed to issuance. They are characterized by extensive consultation or design work and explicit acknowledgment that a "no" decision (or further deferral) is a legitimate outcome.

United Kingdom: The digital pound remains in the design phase as of mid-2026, with no decision to launch taken. Deputy Governor Dave Ramsden confirmed in March 2026 that a decision is expected "this year." The BoE and HM Treasury published a joint consultation in February 2023 and a joint response in January 2024 (50,000+ responses). Both the House of Lords ("a solution in search of a problem") and the Treasury Committee have expressed skepticism. The Government has committed to enshrining privacy protections in primary legislation and guaranteeing no government/central-bank programmability. Financial Stability Paper No. 53 (November 10, 2025) modelled deposit-flight scenarios. The proposed individual holding-limit range is GBP 10,000-20,000. The Digital Pound Lab (launched August 2025) provides an industry sandbox, building on Project Rosalind's 33 API functions. If approved, launch would come only in the late 2020s.

Sweden: The Riksbank's e-Krona project, launched in 2017, is the longest-running CBDC research programme globally. Four pilot phases (2020-2024) on R3 Corda concluded with Phase 4's offline payment-card solution (SEK 3,000 offline-wallet cap, max 5 consecutive offline payments). The Payments Investigation (SOU 2023:16) found "insufficient societal need" for an e-Krona, and no enabling legislation exists. The Riksbank's Payments Report 2026 (March 12, 2026) recommends that the Riksdag/Government set up a formal inquiry into e-krona legislation — but explicitly conditioned on the EU's digital euro Regulation being finalised and the ECB deciding to issue. Sweden's path is now closely tied to the digital euro timeline; its unique context (cash use ~5% of in-store payments in 2025) makes it the strongest structural case for retail CBDC among advanced economies, yet the political decision has not been taken.

Ghana: The BoG partnered with Giesecke+Devrient (G+D) for an offline-first eCedi design. A 2022 sandbox pilot tested real transactions in urban, mining-town, and rural settings, and the BoG won the "Innovation in Digital Currency Design for Financial Inclusion" award (October 2024). On May 22, 2026, Governor Asiama announced that the eCedi had "completed its pilot phase" and that the BoG is "now actively designing its use for cross-border settlements and wholesale payments" — a design-phase shift, not a live launch. The retail eCedi remains unlaunched: it has no legal-tender status, and enabling legislation has not been passed (the project has slipped repeatedly: 2022→2023→2025→still pending). Separately, Parliament passed the Virtual Asset Service Providers Bill, 2025 in December 2025 (crypto/VASP licensing, distinct from the eCedi; virtual assets are not legal tender). Given that ~47% of Ghanaians lack internet access (self-reported), the offline-first approach directly addresses the jurisdiction's core constraint.

Outcome data: No live systems; design documentation, consultation responses, and a completed-but-unlaunched pilot are the primary outputs. The UK's 50,000 consultation responses and Financial Stability Paper No. 53 represent the most rigorous public assessment of CBDC trade-offs among all jurisdictions studied, and the UK's explicit commitment that legislation will not allow the Government or Bank of England to use digital-pound data beyond purposes already permitted for law enforcement sets the global standard for legislated CBDC privacy. Sweden's Phase 4 offline findings (EMV-compatible payment card with SEK 3,000 shadow wallet) inform global CBDC design for resilience scenarios, but its trajectory is now externally driven by the EU. Ghana's pilot demonstrated offline CBDC feasibility in a developing-country context — a finding directly relevant across Sub-Saharan Africa and South Asia — yet the absence of enabling legislation has kept it from launch.

Position 4: Active Pilot / Preparation

Countries:

European Union,

India,

Brazil,

South Korea,

Thailand,

Singapore,

China

These jurisdictions are running live or recently concluded pilots with real participants, and in several cases are building toward deployment decisions. The range of ambition within this group is wide — from the EU's methodical preparation to China's massive-scale rollout that blurs the line between pilot and launch. Two of these — China and India — have CBDCs operational at scale and are treated here as active pilots rather than full nationwide launches because of unresolved status (China's reclassification) and the absence of a full-launch decision (India).

European Union: The digital euro is the most institutionally advanced CBDC project globally. The ECB moved through investigation (2021-2023) and preparation (2023-2025); the preparation phase closed in October 2025, and the Governing Council moved the project to the next phase on October 29-30, 2025. The N-XT settlement engine uses a centralised UTXO data model with privacy by design (the Eurosystem cannot identify online users; offline transactions are cash-like). Framework agreements with EU-controlled service providers were announced October 2, 2025 (estimated EUR 432.1 million, maximum EUR 1.164 billion). The Commission impact assessment modelled a EUR 3,000 per-person holding limit; the Council's December 19, 2025 negotiating position provides for an ECB-set limit within a Council-agreed ceiling. The digital euro is non-interest bearing and explicitly not programmable money. On the legislative track, the European Parliament adopted amendments endorsing both online and offline functionality on February 10, 2026, and the ECON Committee vote on the draft report is scheduled for June 23, 2026. The Eurosystem opened a PSP pilot call on March 5, 2026 (12-month pilot in H2 2027); potential first issuance during 2029 is contingent on the EU adopting the Regulation in 2026. ECB surveys show 58% of Europeans consider themselves unlikely to use the digital euro.

India: The Digital Rupee (e₹) is the second-largest CBDC pilot globally. Legal authority derives from the Finance Act 2022, which amended the RBI Act to include "bank note" in digital form; e₹ is legal tender and a direct RBI liability. The retail pilot (e₹-R, launched December 2022) reached ~7-8 million users and ~19 banks by late 2025 (self-reported). UPI interoperability extends e₹ to 300+ million merchant touchpoints. Programmable CBDC welfare delivery has been deployed in Gujarat (G-SAFAL), Andhra Pradesh (DEEPAM 2.0), Odisha (Subhadra), and Puducherry (PMGKAY food distribution under Canara Bank, February 2026). Offline NFC capability launched at the Global Fintech Fest in October 2025. Critically, the RBI Annual Report 2025-26 (released May 29, 2026) reported that e₹-R in circulation fell ~24% to ₹771.7 crore (~US$90M) as of March 31, 2026 — the first reported year-over-year decline (down from ₹1,016.5 crore). The wholesale pilot (e₹-W) has collapsed, from ₹10 crore (March 2023) to ₹0.08 crore (March 2024). The "UPI problem" is acute, making the marginal value of a retail CBDC unclear.

Brazil: Drex (Digital Real) was the most technically ambitious CBDC project in terms of programmability. Phase 1 (concluded February 2025) tested a Hyperledger Besu-based wholesale CBDC, tokenized deposits, and smart contracts; Phase 2 tested 13 themes across 16 consortia with 50+ companies. In August 2025, BCB president Galipolo announced a pivot away from blockchain, stating the technology tested "did not prove viable" for privacy compliance. The project then restarted from scratch: on November 4, 2025 the BCB told consortia it would shut down the Besu platform, and the Hyperledger Besu Drex platform was decommissioned on November 10, 2025, with Phase 3 (collateral management / lien reconciliation) to begin in 2026 on technology yet to be selected. Separately, the crypto-tax provisional measure MP 1,303/2025 (flat 17.5%) lapsed (caducou) on October 8, 2025; the progressive 15-22.5% regime with a R$35k exemption remains in force for 2026. Brazil's privacy trilemma — privacy, decentralization, and programmability cannot all be maximized with current technology — is a definitive finding for the global CBDC community. No firm launch date exists; Galipolo gave no launch timeline ("not necessarily" for 2026). Pix (150+ million users, 76% of adults) provides the adoption base.

South Korea: Project Hangang tests a hybrid deposit-token model (wholesale CBDC underpinning commercial-bank deposit tokens, not a full retail CBDC). Phase 1 (April-June 2025): 80,000 of 100,000 invited users opened wallets; 114,000+ transactions; total volume only 692.46 million won ($515,000), while each of seven banks spent ~5 billion won ($3.7M) on infrastructure. The BOK paused the project at the end of June 2025 over cost and regulatory uncertainty, then restarted Phase 2 in March 2026 with 9 banks and a live government-subsidy focus — including a world-first plan to pay EV-charging subsidies in deposit tokens (national-treasury operation). LG CNS is the core technology partner. A regulatory tension between BOK and FSC over stablecoin governance complicates the framework.

Thailand: The BOT completed a retail CBDC pilot (~10,000 participants, Bang Khun Phrom, 2024) but concluded there are "no plans for full-scale retail CBDC issuance," noting that PromptPay offers comparable functionality. Thailand's domestic focus has shifted to a Programmable Payment Sandbox for stablecoin and programmable-payment experimentation (a second round runs from April 2026 with True Money, Bitkub, and OM Platform). Wholesale work continues through Project Inthanon and mBridge, where Thailand is a founding member.

Singapore: MAS has assessed there is "no urgent need" for a retail CBDC. The approach is wholesale-first: the SGD Testnet achieved the first live issuance of Singapore-dollar wholesale CBDC (2024-2025), including the first live wholesale CBDC transaction (overnight interbank lending, November 2025). Project Orchid developed the Purpose-Bound Money (PBM) protocol, and the Global Layer 1 initiative positions Singapore as an infrastructure provider for cross-border tokenized-asset settlement. A 2026 pilot for tokenized MAS Bills settled in wholesale CBDC is planned. Retail CBDC remains theoretical with no timeline.

China: The e-CNY is by far the world's largest CBDC experiment, operating at scale but still classified as an active pilot. Cumulative transactions reached 3.48 billion worth CNY 16.7 trillion (~USD 2.37 trillion) as of November 2025 (self-reported), with 2.25 billion wallets (indicating multiple wallets per user). The January 1, 2026 reclassification is fundamental: e-CNY held in verified commercial-bank wallets (Categories 1-3) now earns interest (initial 0.05% annual rate, first quarterly payout March 20, 2026) and is treated as bank deposit liabilities rather than pure M0/central-bank liabilities, leading PIIE to argue it "may no longer qualify as a CBDC under standard definitions." On April 2, 2026, the PBOC doubled its authorized-operator roster to 22 (adding 12 banks), read as a transition from pilot toward full-scale deployment. Average transaction value has declined from CNY 1,895 (2023) to ~CNY 428 (2025). The e-CNY is placed here rather than in "launched" because its reclassification and ongoing pilot status make its final form uncertain.

Outcome data: The EU has the most detailed cost projections and the most advanced legislative process (ECON vote June 23, 2026). India demonstrates programmable welfare delivery as the strongest developing-economy use case — yet FY2025-26 marked its first reported circulation contraction (24%), a significant negative signal. Brazil's privacy failure and full platform decommissioning is the most consequential technical finding. South Korea's low transaction volume ($515,000 in Phase 1) confirms the wallet-usage gap. Thailand and Singapore's explicit decisions not to pursue retail CBDC despite technical capability are significant policy signals. China's volume is unmatched but its reclassification and operator doubling raise definitional questions about whether it is still a pilot, a launch, or no longer a CBDC at all.

Position 5: Launched (Limited)

Country:

Russia

Russia has enacted comprehensive CBDC legislation and begun narrow live use, with a legally mandated large-scale launch ahead, but has not yet achieved full nationwide retail deployment.

Russia: The digital ruble is legally established as a third form of the ruble under Federal Law No. 340-FZ (signed August 1, 2023) and Civil Code amendments. Narrow government/budget use (social security, salaries, budget operations) commenced January 1, 2026, and the full large-scale launch is legally mandated for September 1, 2026 — systemically important banks and retailers with revenue >RUB 120M must comply then, with all banks by 2028. Pilot statistics (June 2025, CBR self-reported): ~2,500 wallets, operations through 15 banks in 150+ localities, 63,000+ P2P transfers, 13,000+ B2C payments, 17,000+ smart contracts executed. The digital ruble is explicitly non-anonymous: the CBR states "unique identifiers make it possible to track the circulation of digital rubles." Onboarding requires Gosuslugi registration and in-person ESIA verification (access rules tightened February 6, 2026). Over 50% of Russians are reportedly unwilling to use the digital ruble for daily transactions (media-sourced, indicative). The BRICS Bridge cross-border initiative remains largely conceptual; the April 2026 RBI proposal to interconnect BRICS members' CBDCs is a proposal, not an agreement, and does not specifically name the digital ruble.

Outcome data: ~2,500 pilot wallets in a nation of 144 million. The digital ruble's primary driver is geopolitical (sanctions context) rather than financial inclusion, and public skepticism is high. The mandatory September 2026 adoption timeline represents the most coercive CBDC deployment approach among all jurisdictions studied, and one of the most legally-formalised CBDC programmes globally.

Position 6: Launched (Nationwide)

Countries:

Bahamas,

Jamaica,

Nigeria

These jurisdictions have fully launched retail CBDCs available to their general populations. All three share a common outcome: extremely low adoption relative to expectations.

Bahamas (Sand Dollar): Launched October 20, 2020 — the world's first nationwide CBDC. Personal wallets reached ~138,000 (December 2024, +16% YoY) and consumer wallets ~144,000 (November 2024) out of a ~400,000 population (self-reported, CBOB/tracker). Circulation reached B$2,482,045 (early 2025) — ~0.39% of physical cash. Cash in circulation reportedly increased ~20% despite the Sand Dollar push. The CBOB announced a two-year plan (mid-2024) to mandate commercial-bank Sand Dollar integration by ~mid-2026, acknowledging that voluntary adoption strategies underperformed. Tiered KYC (Tier 1 requires only minimal ID, B$500 balance cap) targets unbanked populations; offline capability is designed for hurricane resilience but remains under development.

Jamaica (JAM-DEX): Launched June 2022 with full legal-tender status by statute (Bank of Jamaica (Amendment) Act, 2022, enacted June 14, 2022) — the first country to legislate CBDC legal tender. Registered wallets reached ~282,274 (end-2024, +7% YoY) and merchants ~2,379 (September 2024); JAM-DEX in circulation was ~J$260.05m (end-2025), ~0.1% of currency (self-reported, BOJ/tracker). Transaction value rose +550% and volume +267% year-over-year in 2025 — but driven primarily by existing users transacting more, not new sign-ups. Only two public wallets (NCB's Lynk and JN Bank's JN Pay) are active. The non-blockchain centralized eCurrency/DSC3 design avoided the technical outages DCash suffered. Outgoing Governor Byles called slow JAM-DEX adoption "a disappointment" (May 27, 2026).

Nigeria (eNaira): Launched October 25, 2021 — Africa's first live CBDC (second globally after the Bahamas). The IMF (WP/23/104) found 98.5% of wallets inactive after one year; 2.2 million cumulative transactions by July 2024; circulation N18.31 billion ($11.4 million, February 2025) — 0.37% of currency in circulation (all self-reported, flag accordingly; the ~13m wallet figure circulates but is not independently re-verified). The eNaira launched alongside controversial cash-withdrawal-limit policies (2022-2023) that the CBN later reversed under public pressure. Smart-contract functionality in the Hyperledger Fabric architecture remains unenabled. In November 2025, CBN officials acknowledged a pivot toward wholesale CBDC (eNaira v2.0), and an October 2025 task force began studying an official Nigerian stablecoin (cNGN, designed to complement rather than replace the eNaira) — a strategic re-direction, not discontinuation. Cambridge analysis found the CBN "misapprehends the meaning and scope of informed consent to data processing," and the Human Rights Foundation flags surveillance concerns.

Outcome data: No launched CBDC has exceeded 0.5% of currency in circulation — the Bahamas at ~0.39%, Nigeria at ~0.37%, and Jamaica at ~0.1% all demonstrate that launching a CBDC does not translate to adoption. Cash has increased, not decreased, in CBDC jurisdictions. The wallet-to-active-user gap is universal and extreme (Nigeria's 98.5% inactivity rate is the most documented). Merchant acceptance remains the binding constraint.

Position 7: Abandoned / Suspended

Country: Eastern Caribbean (DCash)

Eastern Caribbean: DCash was the world's first multi-national CBDC pilot, launched March 2021 across 8 ECCU member states, and the only CBDC to operate natively across multiple sovereign territories. The Hyperledger Fabric-based system suffered a ~two-month outage (early 2022) caused by expired identity certificates — a certificate-management failure that became a globally cited cautionary example. The pilot officially concluded January 12, 2024. The ECCB Monetary Council suspended DCash 2.0 development on February 13, 2026, in favor of prioritizing a regional Fast Payment System and participation in the CARICOM Payments and Settlement System (CAPS) pilot (formally confirmed in the Council's May 4, 2026 communiqué). The suspension reflects both private-sector digital-payment expansion across the ECCU and a pragmatic reassessment that fast payment systems may achieve similar goals at lower cost and complexity.

Outcome data: The DCash trajectory — from pioneering pilot to suspension in favor of conventional infrastructure — is the most significant policy signal from the launched/pilot CBDC group. The ECCB's conclusion that a fast payment system is preferable to CBDC may represent a broader trend among smaller economies. The expired-certificate outage has become the most widely cited CBDC operational failure globally, demonstrating that blockchain-based CBDCs carry infrastructure risks that centralized systems (such as

Jamaica's eCurrency platform) avoid. The growth of private-sector mobile banking across the ECCU during the pilot period illustrates a dynamic that applies well beyond the Caribbean: private-sector innovation may outpace central bank digital currency development, narrowing the window of CBDC relevance.

Spectrum Summary by Region

Americas: The Americas span the full spectrum. The

US stands alone in legislative prohibition (EO 14178 in force; statutory bans passed both chambers in differing, unreconciled forms).

Canada has scaled down retail work and converged with the US skeptical stance while continuing wholesale experimentation.

Brazil is in an active pilot but has decommissioned its Besu platform and is rebuilding from scratch.

Bahamas and

Jamaica are launched but struggling. DCash is suspended. The common thread: no jurisdiction in the Americas has achieved meaningful CBDC adoption, regardless of approach.

Europe: The

EU leads with the most institutionally advanced preparation and an active legislative track (ECON vote June 23, 2026). The

UK is in a cautious design phase with strong parliamentary scrutiny.

Sweden has the longest-running program but no commitment, and its path is now tied to the digital euro.

Russia is in launched-limited deployment with a legally mandated full-launch date (September 1, 2026) and explicit surveillance. The European approach is generally characterized by greater institutional deliberation and stronger privacy frameworks than other regions.

Asia-Pacific: The most diverse region on the spectrum.

China has the largest deployment by volume (22 operators after the April 2026 doubling).

India has the most innovative programmable welfare use cases but recorded its first circulation decline (~24%) in FY2025-26.

Japan and

Australia are in research/wholesale-only mode.

South Korea is piloting a hybrid deposit-token model (paused mid-2025, resumed March 2026).

Thailand concluded a retail CBDC is unnecessary.

Singapore leads in wholesale innovation without retail commitment. The region collectively demonstrates that advanced instant-payment ecosystems (UPI, PromptPay, PayNow) can coexist with CBDC research without creating adoption demand.

Middle East and Africa:

Nigeria's eNaira is the clearest cautionary tale and is now pivoting to wholesale.

Ghana's offline-first eCedi is the most promising design for inclusion in the region; its pilot is "completed" (May 2026) but it remains unlaunched pending unpassed enabling legislation.

South Africa published a definitive Position Paper (November 27, 2025) concluding there is no compelling retail case and pivoting firmly to wholesale (Project Khokha 2x). The region faces the most acute inclusion challenges and the highest stakes for getting CBDC design right — yet the only launched African CBDC (Nigeria) has failed by every measurable metric.

Cross-Cutting Observations Across the Spectrum

Several patterns emerge when the seven positions are examined together:

The technology-readiness trap. Jurisdictions at every position have demonstrated that CBDC technology works. Project Hamilton (US) achieved 1.7 million TPS. The BOJ reached 50,000 TPS. The Bahamas' Cortex DLT processes transactions reliably. Nigeria's Hyperledger Fabric handles the load. Technical feasibility is a solved problem. The unsolved problems are demand generation, merchant infrastructure, commercial-bank cooperation, and political legitimacy — none of which are technology problems. Brazil's full decommissioning of its Besu platform, after four years and 50+ partner companies, underscores that even a working technical platform can be abandoned when it cannot reconcile privacy, decentralization, and programmability.

The cash persistence paradox. In every jurisdiction where data is available, the introduction of a CBDC has not reduced cash usage. The Bahamas reports a ~20% increase in physical cash. Jamaica remains heavily cash-dependent (and saw cash rise further after Hurricane Melissa in late 2025). Nigeria's cash policies backfired spectacularly. China's e-CNY competes not with cash but with Alipay and WeChat Pay — and loses. This contradicts the foundational assumption of many CBDC projects.

The privacy-surveillance divide. Jurisdictions divide sharply on privacy. The UK and EU have committed to legislated privacy protections, offline cash-like anonymity, and restrictions on government data access. Russia has built explicitly non-anonymous infrastructure ("unique identifiers make it possible to track the circulation of digital rubles"). China's "controllable anonymity" sits between these poles. Nigeria's design enables comprehensive CBN monitoring. The evidence from Russia (50%+ unwilling) and Nigeria (98.5% inactive) suggests that weak privacy correlates directly with poor adoption.

The wholesale convergence. Multiple jurisdictions that began with retail ambitions have converged toward wholesale-only or wholesale-first strategies. Australia explicitly pivoted (Project Acacia, A$4.4m wCBDC issued). Singapore assessed no urgent retail need. South Africa concluded there is no compelling retail case (Project Khokha 2x). Canada scaled down retail and completed wholesale Project Samara. Nigeria is pivoting to wholesale (eNaira v2.0). Ghana reframed the eCedi toward wholesale/cross-border. Thailand completed its retail pilot with no launch plans. This convergence suggests a growing consensus that wholesale CBDC for institutional settlement offers a clearer value proposition than retail CBDC for consumer payments.

The developing-country programmability opportunity.

India's deployment of programmable CBDC for welfare delivery (G-SAFAL agricultural inputs, DEEPAM 2.0 LPG subsidies, PMGKAY food distribution) represents the strongest evidence-based use case for CBDC in any jurisdiction. Purpose-bound money that restricts spending to approved categories addresses genuine problems — subsidy leakage, corruption — that conventional payment systems cannot solve as elegantly. South Korea is now testing the same idea in a high-income setting (EV-charging subsidies paid in deposit tokens). This is largely a directed-disbursement opportunity rather than a voluntary-adoption one.

2. The Spectrum Table

Distribution (N=20): Prohibition 1 · Research/No Commitment 4 · Cautious Design 3 · Active Pilot/Preparation 7 · Launched (Limited) 1 · Launched (Nationwide) 3 · Abandoned/Suspended 1. Of the 20, 6 jurisdictions have a launched or live CBDC (Bahamas, Nigeria, Jamaica, Eastern Caribbean [suspended], China [pilot-scale], India [pilot-scale]); 1 is in launched-limited deployment (Russia); and 1 is actively opposed (United States).

How to Read the Table

The table's most striking feature is the contrast between Position 4 (Active Pilot) and Position 6 (Launched Nationwide). The pilot jurisdictions have invested more capital, engaged more stakeholders, produced more technical innovations, and published more rigorous analysis. The launched jurisdictions have produced real adoption data — and that data uniformly shows negligible uptake. The table does not support the assumption that progression from left to right represents progress. Instead, it suggests that the spectrum is not a ladder but a landscape, where each position reflects a distinct policy judgment about whether CBDC is the right tool for a jurisdiction's circumstances.

The technology column reveals another pattern: no single technology has proven superior. The EU uses a centralized UTXO engine. Jamaica uses centralized DSC3. The Bahamas uses Cortex DLT. Nigeria and the Eastern Caribbean used Hyperledger Fabric. Brazil tested Hyperledger Besu and decommissioned it. China uses a hybrid architecture. Singapore and Australia have tested multiple DLT platforms simultaneously. The technology choice matters less than the institutional, commercial, and political context in which it is deployed.

3. The Optimal Zone

The spectrum data reveals a paradox that challenges conventional assumptions about CBDC development.

The Launch-Adoption Paradox

The evidence from all jurisdictions studied shows an inverse correlation between speed of launch and quality of outcomes. The three nationwide launches (Bahamas, Jamaica, Nigeria) all demonstrate negligible adoption. Nigeria's 98.5% wallet inactivity rate is the starkest data point, but the Bahamas' ~0.39% share of cash and Jamaica's reliance on just two public wallet providers tell the same story. In all three cases, cash in circulation has not declined — and in the Bahamas it has increased ~20%.

Meanwhile, the jurisdictions that have invested the most time in design and consultation (the EU, UK, Singapore) have not launched — and their approach may be the more prudent one. The ECCB's explicit decision to abandon CBDC in favor of fast payment systems reinforces this: sometimes the optimal outcome is not launching at all.

The EU's Deliberate Approach

The

European Union's digital euro project stands out as a potential gold standard for process, if not yet for results. Key distinguishing features:

• Phased institutional methodology: Investigation (2021-2023), preparation (closed October 2025), then a PSP pilot (call opened March 2026, 12-month pilot in H2 2027), with potential first issuance during 2029 — contingent on the EU adopting the Regulation in 2026 (ECON Committee vote scheduled June 23, 2026).
• Privacy architecture: The N-XT settlement engine uses a centralised UTXO model where the Eurosystem cannot identify online users; offline transactions replicate cash-like privacy.
• Financial stability rigor: A EUR 3,000 per-person holding limit was modelled; the Council (December 2025) provides for an ECB-set limit within a Council-agreed ceiling, reviewed at least every two years.
• Democratic legitimacy: Full co-decision procedure; the Council agreed its negotiating position in December 2025, and Parliament adopted amendments (February 2026) endorsing both online and offline use.
• European digital sovereignty: All selected service providers are EU-controlled entities.

The fundamental question for the EU remains the one its own survey data highlights: 58% of European citizens consider themselves unlikely to use the digital euro. No amount of architectural sophistication addresses the absence of organic consumer demand.

The UK's Privacy-First Design Phase

The

United Kingdom's approach — characterized by parliamentary skepticism, legislated privacy guarantees, and an explicit acknowledgment that "no decision" is legitimate — represents the strongest democratic-accountability framework among all CBDC projects studied. The MIT DCI privacy collaboration and Financial Stability Paper No. 53 (the most detailed deposit-flight analysis from any central bank) demonstrate rigorous evidence-based assessment. The risk is timeline slippage: as of mid-2026 the decision remains pending, with Deputy Governor Ramsden confirming it is expected "this year."

Singapore's Infrastructure-Without-Commitment Model

Singapore represents a distinct approach within the optimal zone: building the infrastructure to issue a retail CBDC without committing to issuance. The Purpose-Bound Money protocol, the SGD Testnet (live wholesale CBDC, with the first live wholesale transaction in November 2025), and the Global Layer 1 initiative create capabilities that can be activated if conditions warrant, while avoiding the adoption risk of premature launch. MAS's consolidated authority (central bank, regulator, and monetary authority in one body) enables this coordinated pragmatism.

India's Programmable Welfare as a Third Path

India's approach is a pragmatic middle path: launch a pilot quickly (December 2022), accept low voluntary consumer adoption (~7-8 million users), but find genuine value in government-directed use cases where the adoption problem does not apply. The Puducherry PMGKAY food-distribution pilot (February 2026) is a step toward what could become the world's largest CBDC-based welfare delivery system. The caution: even India's directed model has not insulated overall circulation, which fell ~24% in FY2025-26 — the first reported decline. If India's programmable CBDC nonetheless proves effective at reducing subsidy leakage at scale, it would be the first clear evidence that CBDC delivers economic outcomes that alternative technologies cannot replicate.

The Evidence Does Not Clearly Favor Any Position

An honest assessment of the global evidence base in mid-2026 must conclude:

• No launched retail CBDC has achieved meaningful adoption. The best data comes from the worst outcomes.
• No unlaunched CBDC has proven it will succeed. The EU and UK may produce superior designs, but they face the same demand problem.
• Wholesale CBDC may deliver more value than retail. Singapore, Australia, South Africa, and Canada have all converged on wholesale-first or wholesale-only strategies; India's retail pilot contracts while its wholesale tokenization (UMI) initiative continues.
• Fast payment systems may be sufficient. The ECCB's pivot, Thailand's PromptPay assessment, and India's "UPI problem" all point to the same conclusion: where modern instant-payment infrastructure exists, the marginal utility of retail CBDC is unclear.
• Programmable money for welfare delivery is the clearest use case. India's e₹ deployment for government schemes (G-SAFAL, DEEPAM 2.0, PMGKAY) — and now South Korea's EV-subsidy deposit-token pilot — is the most compelling evidence that CBDC solves a problem conventional payments cannot.

4. Comparative Outcomes Matrix

Reading the Matrix: Dimension-by-Dimension Analysis

Adoption: The matrix confirms that no jurisdiction has achieved meaningful voluntary consumer adoption. China's absolute transaction volume (CNY 16.7 trillion cumulative, self-reported) is impressive but represents a fraction of the Alipay/WeChat Pay duopoly. India's ~7-8 million users represent a small share of the population, and circulation actually fell ~24% in FY2025-26. South Korea's Phase 1 generated only $515,000 in total volume. The Bahamas, Jamaica, and Nigeria are all below 0.5% of cash in circulation. Russia has ~2,500 pilot wallets in a country of 144 million. The only jurisdiction with high-volume usage — China — achieved it through government promotion and platform integration, not organic demand.

Financial Inclusion: The dimension where CBDC theory most exceeds CBDC reality. Every project cites inclusion as a primary motivation, yet the Bahamas' Family-Island unbanked remain largely unreached after five years, Nigeria's coercive cash policies alienated the very populations they aimed to include, and Jamaica's growth comes from existing banked users. India's programmable welfare delivery is the exception because the government controls both ends of the transaction. Ghana's offline-first design is promising in principle but remains untested at scale and unlaunched. The lesson: inclusion through CBDC requires merchant infrastructure, offline capability, and use cases where CBDC offers genuine advantage over existing alternatives.

Innovation: The strongest innovations have come from jurisdictions that have not launched — the EU's UTXO-based N-XT settlement engine, Singapore's Purpose-Bound Money protocol, India's programmable welfare delivery, Brazil's 13-theme pilot (though its blockchain ultimately proved unviable and was decommissioned), Project Hamilton's 1.7 million TPS, and the UK's 33 Project Rosalind API functions. Launched CBDCs (Bahamas, Jamaica, Nigeria) have produced comparatively little technical innovation — their contribution is empirical adoption data, valuable precisely because it demonstrates the limits of CBDC.

Privacy: The sharpest divergence across the spectrum. The UK's legislated guarantee of no government programmability and the EU's offline transactions where the Eurosystem cannot access details sit at one pole; Russia's explicit statement that digital-ruble settlements "do not provide for the anonymity of payments" and China's "controllable anonymity" (big amounts traceable) sit at the other, with Nigeria's comprehensive CBN monitoring nearby. The evidence suggests privacy architecture is not merely a design preference but a determinant of adoption: the most privacy-hostile designs (Russia, Nigeria) show the lowest adoption.

Monetary Stability: The one dimension where CBDC has performed as intended — by not disrupting. Every jurisdiction with holding limits, non-remuneration, and two-tier distribution has prevented bank disintermediation, because CBDC circulation is negligible everywhere. China's January 2026 reclassification to commercial-bank deposits eliminates disintermediation risk entirely (PIIE notes it removes any chance digital-yuan adoption siphons off bank deposits). The EU's waterfall/reverse-waterfall mechanism remains untested at scale, and the UK's holding-limit proposal substantially contains modelled deposit flight. The real test of monetary stability will come only if a CBDC achieves meaningful adoption, which none has.

5. Key Insight

The Inverse Relationship

The regulatory spectrum reveals a striking inverse relationship: the faster countries launched, the worse their outcomes. This pattern holds across all jurisdictions studied.

The Bahamas (launched October 2020) has ~0.39% of cash in circulation as CBDC after five years. Nigeria (launched October 2021) has 98.5% inactive wallets. Jamaica (launched June 2022) sees growth only among existing users, not the unbanked it targets. The Eastern Caribbean (pilot from March 2021) suspended its program entirely.

In contrast, the jurisdictions investing the most time in design — the

EU,

UK, and

Singapore — have produced the most sophisticated architectures, the strongest privacy frameworks, and the most rigorous financial-stability analysis. The EU has also spent the most (framework agreements with EU-controlled providers estimated at EUR 432.1 million, maximum EUR 1.164 billion).

Why Haste Fails

The data suggests three structural reasons for this inverse relationship:

First, launched CBDCs solved a technical problem before solving a demand problem. Every early mover could demonstrate that the technology works. None could demonstrate that consumers want it. The Bahamas, Jamaica, and Nigeria all launched technically functional systems into markets where consumers had no compelling reason to switch from cash or existing digital payments.

Second, early launchers lacked the institutional density of the preparation-phase jurisdictions. The EU's scheme rulebook (v0.9, with thousands of stakeholder comments), the UK's design notes, and Singapore's five-phase Project Ubin created institutional knowledge that no early launcher possessed. The ECCB's ~two-month outage from expired certificates is the most vivid illustration of what happens when operational maturity does not match launch ambition.

Third, the absence of commercial-bank buy-in dooms adoption. In the Bahamas, banks resisted integration until the CBOB moved to mandate it. In Jamaica, only two public wallets exist. In Nigeria, the CBN's coercive cash-withdrawal policies triggered public backlash. By contrast, Brazil's Phase 2 involved 50+ companies across 16 consortia, and the EU's preparation phase engaged dozens of market participants.

The Geopolitical Dimension

The spectrum also reveals a geopolitical divide. The US's opposition to CBDC development, combined with its stablecoin-first strategy under the GENIUS Act (PL 119-27), positions the dollar's digital future in private-sector hands.

China's e-CNY, despite its reclassification, represents the most extensive state-directed digital-currency infrastructure globally, with the Shanghai International Operation Center and mBridge participation creating cross-border capabilities.

Russia's digital ruble is explicitly motivated by the sanctions context — the BRICS Bridge proposal aims to enable settlement outside Western-controlled infrastructure, though it remains largely conceptual. The EU digital euro is framed partly as a European-sovereignty measure, with all service providers required to be EU-controlled entities.

This geopolitical context means CBDC development is driven not only by domestic objectives but by international monetary competition, as 130+ countries explore CBDCs while the US declines to.

The Cost Question

The spectrum reveals a dramatic asymmetry in disclosed costs. The EU has published the most detailed projections (framework agreements estimated at EUR 432.1 million, maximum EUR 1.164 billion). No launched CBDC (Bahamas, Jamaica, Nigeria) has disclosed development costs — a significant transparency gap. For small island developing states, CBDC development represents a disproportionate share of central-bank budgets, and the ECCB's decision to suspend DCash 2.0 may partly reflect this cost calculus. South Korea offers a rare data point on cost-to-activity imbalance: each of seven banks spent ~5 billion won ($3.7M) on infrastructure to generate ~$515,000 in Phase 1 volume. At 0.39% of cash (Bahamas) or 98.5% wallet inactivity (Nigeria), the return on investment for launched CBDCs is clearly negative.

The Most Promising Approaches Have Not Launched Yet

The

EU's privacy-by-design settlement engine, the

UK's legislated privacy guarantees, and

Singapore's Purpose-Bound Money protocol represent the frontier of CBDC design innovation. None has been tested at scale with real consumers. They may succeed where early launchers failed — or face the same demand problem in different packaging.

The evidence available in mid-2026 supports one clear conclusion: there is no evidence that any retail CBDC, launched or planned, has solved the fundamental adoption challenge. The most promising use case —

India's programmable welfare delivery — does not require consumers to voluntarily adopt CBDC. It works because the government is both sender and rule-setter. Whether voluntary consumer adoption can be achieved at scale remains the open question that no position on the spectrum has answered.

What the Spectrum Tells Policymakers

For jurisdictions still deciding where to position themselves on the spectrum, the evidence points to several actionable conclusions:

1. Do not rush to launch. The Bahamas, Jamaica, Nigeria, and the Eastern Caribbean all launched before solving the demand problem. Five years of data show that technical readiness does not generate adoption. The EU's multi-year arc toward potential 2029 issuance, while frequently criticized as slow, may prove the correct pace.

2. Solve the demand problem first. Every launched CBDC faces the same consumer question: "Why should I use this instead of what I already have?" The

Bahamas' answer (hurricane resilience) is compelling in theory but insufficient at 0.39% of cash.

India's answer (programmable welfare delivery) is effective but applies to government disbursements rather than voluntary payments. No jurisdiction has articulated a consumer value proposition that generates organic demand.

3. Privacy is a prerequisite, not a feature. The correlation between privacy-hostile design and poor adoption (Russia, Nigeria) is not coincidental. The

UK's decision to legislate privacy guarantees before launch is a model for other jurisdictions, as is the EDPB/EDPS recommendation for a low-value online privacy threshold in the digital euro.

4. Wholesale may deliver more value than retail.

Singapore,

Australia,

South Africa, and

Canada have all converged on wholesale CBDC for institutional settlement as the clearer value proposition.

Nigeria is pivoting from retail to wholesale, and

Ghana has reframed the eCedi toward wholesale/cross-border. The ECCB abandoned CBDC entirely in favor of fast payment systems.

5. Build on existing payment infrastructure.

India's UPI integration (300+ million merchant touchpoints),

Brazil's Pix foundation (150+ million users), and

Thailand's PromptPay assessment all demonstrate that CBDC should complement, not compete with, proven instant-payment systems. The ECCB's pivot to a fast payment system reflects this logic.

6. Engage the banking sector early and meaningfully.

Brazil's Phase 2 involved 50+ companies across 16 consortia, and the EU's preparation phase engaged dozens of market participants and competitively procured service providers. By contrast, the

Bahamas had to move toward mandating bank participation, and

Jamaica has only two public wallets. Commercial-bank buy-in is the distribution mechanism, not an optional extra.

7. Accept that "no CBDC" is a valid outcome. The US has chosen opposition. The ECCB has chosen suspension.

Australia,

South Africa, and

Canada have concluded there is no compelling retail case. The

UK has explicitly preserved a "no" decision as legitimate. The global evidence supports the view that a well-functioning instant-payment system, combined with regulated stablecoins and cash preservation, may achieve the same policy objectives as a CBDC at lower cost, complexity, and risk.

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The Spectrum in Mid-2026

The CBDC regulatory spectrum as it stands in mid-2026 is not static. Several jurisdictions are likely to shift positions within the next 12-18 months:

• Japan is expected to make its issuance decision in 2026, potentially moving from Position 2 to Position 3 or 4.
• The UK will conclude its design-phase assessment in 2026, either advancing to a build phase or remaining at Position 3.
• The EU is working toward Regulation adoption in 2026 (ECON Committee vote June 23, 2026), with the PSP pilot in H2 2027 and potential first issuance during 2029.
• Russia's mandatory September 1, 2026 launch for systemically important banks and large retailers will test whether state-mandated adoption can overcome public reluctance.
• The Bahamas' mandatory bank-integration deadline (~mid-2026) will determine whether regulatory compulsion can generate the adoption that market forces have not.
• Nigeria's pivot to wholesale CBDC (eNaira v2.0) and its parallel cNGN stablecoin task force may represent a permanent retreat from retail ambitions.

The spectrum will continue to evolve as evidence accumulates. But the central finding of this analysis — that speed of launch inversely correlates with quality of outcomes — is unlikely to be overturned by near-term developments.

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Verification Notes

• Source of truth: This refresh mirrors the canonical per-jurisdiction spectrum_position and tier facts in .claude/cbdc-frameworks-fact-matrix.json for all 20 jurisdictions. No facts were introduced beyond the matrix or the prior version of this file, and no web sources were consulted for this refresh.
• Self-reported figures: All adoption, wallet, circulation, and transaction-volume figures are self-reported by issuing central banks, the IMF, or trackers, and are flagged as such (e.g., China's CNY 16.7T cumulative, India's ₹771.7 crore, Russia's ~2,500 wallets, Nigeria's 98.5% inactivity). They are not independently audited.
• US status: EO 14178 is the only binding CBDC prohibition in force. The statutory moratoria (H.R. 1919; the ROAD to Housing Act's Sec. 1001 moratorium) passed both chambers in differing, unreconciled forms and are not enacted. The GENIUS Act is S. 1582 / Public Law 119-27. Kevin Warsh was sworn in as Fed Chair on May 22, 2026.
• Launched / live vs. pilot: Only the Bahamas (Sand Dollar), Nigeria (eNaira), Jamaica (JAM-DEX), the Eastern Caribbean (DCash, pilot concluded and DCash 2.0 suspended), China (e-CNY, pilot-scale), and India (e₹) are launched/live. Russia is launched-limited with a mandated September 1, 2026 full launch. The US is anti-CBDC. All others are research, design, or pilot/preparation stage.
• Status changes this cycle: Brazil (Besu platform decommissioned November 10, 2025; MP 1303 lapsed October 8, 2025); Canada (Stablecoin Act Royal Assent March 26, 2026, not yet in force); Australia (Project Acacia final report May 18, 2026 — 20 use cases, A$4.4m wCBDC); China (22 operators after the April 2, 2026 doubling); India (e₹-R circulation −24% YoY); Sweden/euro area (ECB preparation phase concluded October 2025, GC moved to next phase October 30, 2025); EU (ECON vote June 23, 2026); Ghana (eCedi pilot "completed" May 22, 2026; VASP Bill 2025 passed December 2025); South Africa (Position Paper November 27, 2025; Project Khokha 2x).
• Distribution recomputed for N=20: Prohibition 1 · Research/No Commitment 4 · Cautious Design 3 · Active Pilot/Preparation 7 · Launched (Limited) 1 · Launched (Nationwide) 3 · Abandoned/Suspended 1.
• Tags & links: Frontmatter uses only canonical tags (type/analysis). Wikilinks use correct file slugs with the deep-research/cbdc-frameworks/ path prefix (basenames such as bahamas/jamaica/canada are ambiguous across domains). No Wikipedia/Reddit/Quora/X/Twitter/Medium sources are cited.

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Analysis synthesized from 20 jurisdiction profiles and the economic outcomes guidance document. All data points are drawn from the verified source material (.claude/cbdc-frameworks-fact-matrix.json and the Phase 1 / Phase 2 research files). No new claims introduced beyond what the underlying research supports.