Financial Inclusion

1. The Inclusion Case for CBDC

1.1 The Global Unbanked Population: Where We Stand

The World Bank Global Findex Database provides the authoritative demand-side data on financial inclusion. The trajectory over the past decade is one of significant progress, but the remaining gap is enormous:

The 2025 edition of the Global Findex (based on 2024 survey data covering approximately 148,000 adults in 141 economies) confirms that 1.3 billion adults remain outside the formal financial system. Over 650 million of them are concentrated in just eight countries: Bangladesh, China, Egypt,

India, Indonesia, Mexico,

Nigeria, and Pakistan.

The demographics of exclusion are consistent across regions:

• 55% of the unbanked are women
• 52% come from the poorest 40% of households
• 62% have only primary education or less
• 54% are unemployed or out of the labour force

Critically, of those without accounts, approximately 900 million own a mobile phone, and more than half of them — about 530 million — have smartphones. This is the addressable population for mobile-first CBDC design.

Sources:

• World Bank, Global Findex Database 2025 (March 2026)
• BIIA — Financial inclusion at record high, but 1.3 billion still unbanked (2025)
• World Bank, Global Findex Database 2021 (2022)

1.2 Where CBDC Can Address Gaps That Other Instruments Cannot

Proponents of CBDC for financial inclusion identify several areas where CBDC could — in theory — address gaps that existing instruments (bank accounts, mobile money, fast payment systems) do not:

1. Settlement in central bank money. Unlike mobile money (which represents a claim on a private operator) or bank deposits (which represent a claim on a commercial bank), CBDC is a direct liability of the central bank. For populations in countries with weak or recently failed banking systems — such as

Nigeria during its 2022-2023 naira crisis or Ghana during its 2022 sovereign debt restructuring — central bank money offers a higher safety guarantee. The counterargument is that this distinction matters only in systemic crises, and during such crises, trust in all government-issued instruments may be compromised.

2. Offline payment capability. Mobile money and bank transfers require network connectivity. CBDC can be designed for offline use via NFC, Bluetooth, or hardware wallets. For the estimated 47% of Ghanaians (self-reported figure) or ~65% rural Indians without reliable internet, offline CBDC could enable digital payments where no digital instrument currently works. This is the strongest differentiated inclusion case for CBDC.

3. Programmable welfare delivery. CBDC can embed spending conditions into government transfers — ensuring food subsidies are spent on food, agricultural inputs on approved supplies, or education grants on tuition.

India's PMGKAY digital food currency pilot (launched February 2026 in Puducherry) and Gujarat's G-SAFAL livelihood programme demonstrate this capability, as does

South Korea's deposit-token subsidy disbursement (EV-charging subsidies, a world-first national treasury operation in digital currency) and

Russia's "coloured funds" for targeted budget spending. No existing payment rail offers programmability at this level without significant middleware.

4. Interoperability by design. In fragmented payment ecosystems where mobile money operators, banks, and fintech wallets do not interoperate, a CBDC can serve as the universal settlement layer. The Eastern Caribbean DCash was designed as a cross-border payment instrument across eight sovereign territories from inception — a capability that no mobile money or banking system provided.

5. Reduced cost of government-to-person (G2P) payments. The World Bank notes that 165 million unbanked adults receive private-sector wages in cash only. CBDC could reduce the cost and leakage of government transfers, wages, and subsidies — provided the recipients have the means to receive and spend them.

1.3 Counter-Arguments: Is CBDC Necessary for Inclusion if Mobile Money Works?

The counter-case is substantial and must be honestly confronted by policymakers:

Mobile money has already achieved what CBDC promises. M-Pesa in Kenya (launched 2007) reached 51 million customers across 7 countries without any central bank digital currency. In Sub-Saharan Africa, 40% of adults had a mobile money account in 2024, up from 27% in 2021 (Global Findex 2025). Mobile money works on basic feature phones via USSD, requires no internet connectivity for basic transactions, and has established agent networks in rural areas.

Fast payment systems have achieved mass inclusion at speed.

Brazil's Pix brought 71 million previously unbanked or underbanked Brazilians into the formal digital economy within four years of its November 2020 launch, reaching 150 million users (76% of the adult population) by 2025.

India's UPI now processes over 20 billion transactions per month with 500+ million unique users. Thailand's PromptPay, Singapore's PayNow/FAST, and South Africa's PayShap each provide near-instant retail payments without a CBDC. Neither Pix nor UPI required CBDC.

The World Bank itself asks the question directly. The World Bank published "Is Central Bank Digital Currency the Right Tool to Expand Financial Inclusion?" — concluding that countries should assess whether existing instruments can achieve inclusion goals before committing to CBDC. The IMF's Fintech Note 2024/006 provides a decision framework for when CBDC adds value beyond what fast payment systems already provide.

Two central banks answered "no." The Eastern Caribbean Central Bank, after pioneering the world's first multi-national CBDC pilot, suspended DCash 2.0 development (ECCB Monetary Council, 13 February 2026) in favour of a regional Fast Payment System plus the CARICOM Payments and Settlement System (CAPS), concluding that conventional payment infrastructure modernization could deliver the needed benefits more reliably. The South African Reserve Bank's 27 November 2025 Position Paper reached the parallel conclusion that a retail CBDC is technically feasible but has "no compelling immediate need," because PayShap, non-bank e-money issuance, and National Payment System expansion address inclusion more effectively near-term.

Sources:

• World Bank Blog — Is CBDC the Right Tool to Expand Financial Inclusion?
• IMF Fintech Note 2024/006 — Positioning CBDC in the Payments Landscape
• ECCB Suspends DCash 2.0 — Antigua News Room (February 2026)
• SARB — Position Paper on the Necessity of a Retail CBDC (27 November 2025)

2. Global Landscape — Inclusion Models

Based on the evidence from launched and piloted CBDCs worldwide, four distinct models have emerged for how CBDC relates to financial inclusion strategy. Each reflects different national circumstances, infrastructure maturity, and policy priorities. Of the 20 jurisdictions surveyed, only 6 have launched or live retail CBDCs (

Bahamas,

Nigeria,

Jamaica, China e-CNY [pilot-scale], India e₹ [pilot], and the now-discontinued Eastern Caribbean DCash); the remaining 14 are at research, pilot, design, or anti-CBDC stages.

2.1 Model A: CBDC as Primary Inclusion Vehicle

Countries:

Nigeria (eNaira),

Bahamas (Sand Dollar),

Jamaica (JAM-DEX), Eastern Caribbean (DCash, discontinued)

In this model, the central bank explicitly positions the CBDC as the primary tool for reaching unbanked populations. The CBDC is designed with simplified KYC tiers, low-barrier wallets, and the expectation that it will serve populations excluded from the banking system. Every launched/live retail CBDC outside of China and India falls into this category.

Nigeria launched the eNaira in October 2021 with financial inclusion as a primary justification (38 million unbanked adults). The Speed Wallet (Tier 0) required only a phone number and supported daily transactions up to N20,000 ($12). The reality was that 98.5% of wallets were inactive after one year (IMF, self-reported), and the CBN's attempt to force adoption through cash restrictions triggered protests and deepened public distrust. By November 2025 the CBN publicly acknowledged a pivot to a wholesale CBDC focus, effectively abandoning the retail inclusion objective.

The Bahamas launched the Sand Dollar in October 2020 targeting the ~18% of Bahamians without bank accounts (2018 IMF), particularly on remote Family Islands where banks were closing branches. Five years later, Sand Dollar circulation stands at B$2,482,045 — 0.39% of physical cash — and cash in circulation has actually increased by 20%. Measured inclusion impact remains limited/unproven.

Jamaica launched JAM-DEX (June 2022) with financial inclusion as the primary stated objective, targeting 22.8% of adults who were unbanked (NFIS 2023). With ~80% of transactions still in cash, growth has come from existing users transacting more, not from new unbanked sign-ups — the inclusion gap persists.

The Eastern Caribbean piloted DCash (March 2021–January 2024) with inclusion as a core goal alongside payments efficiency and resilience (~56% of the Caribbean population unbanked; aim to cut cash usage 50% over 5 years). Concrete inclusion outcomes were limited due to low adoption; the successor DCash 2.0 was suspended in February 2026.

Assessment: Model A has not succeeded in any jurisdiction to date. Where CBDC is positioned as the primary inclusion tool, it has consistently underperformed relative to expectations, because it requires the CBDC to simultaneously solve infrastructure, trust, and adoption challenges that existing instruments have already addressed for part of the population.

2.2 Model B: CBDC Alongside Existing Inclusion Infrastructure

Countries:

India (e₹ + Jan Dhan + UPI),

China (e-CNY),

Brazil (Drex + Pix)

In this model, the CBDC is deployed alongside well-established financial inclusion infrastructure. The CBDC is not expected to be the primary inclusion tool but to complement existing systems and address specific gaps they cannot fill.

India has the most developed version of this model. The JAM Trinity (Jan Dhan accounts + Aadhaar biometric ID + Mobile phone) and UPI together have transformed financial access for hundreds of millions. The e-Rupee (Digital Rupee) adds programmable welfare delivery (G-SAFAL, DEEPAM 2.0, Odisha Subhadra, PMGKAY food distribution) and offline capability (NFC-based, officially launched October 2025 at Global Fintech Fest) to address specific gaps — particularly in rural areas without internet connectivity (~65% rural population) and for targeted government subsidy distribution. The e-Rupee has ~7-8 million retail users as of December 2025, but this is negligible compared to UPI's 500+ million. e₹-R circulation fell ~24% year-over-year to ₹771.7 crore (~US$90M) as of 31 March 2026 — the first reported YoY decline (RBI Annual Report 2025-26, self-reported). Its inclusion contribution is not in mass adoption but in programmable money for welfare delivery and offline payments for connectivity-challenged populations.

China designed the e-CNY with a Category 4 wallet requiring only a phone number (no bank account), zero fees, offline NFC/Bluetooth payments, and hardware wallets (IC cards, wearables) for users without smartphones. The PBOC cites a target of ~234 million unbanked adults (figure NOT VERIFIED / possibly outdated) concentrated among rural households, migrant workers, and the elderly. However, Alipay and WeChat Pay (which handle over 90% of mobile payments) already provide extensive financial access, and the e-CNY has struggled to offer additional value to users already embedded in those ecosystems. As of April 2026 the e-CNY is distributed through 22 authorized operators (12 new banks added 2 April 2026), and from 1 January 2026 verified wallets earn interest at an initial 0.05% rate — a reclassification toward a deposit-money model that some analysts argue may no longer qualify as a "pure" CBDC.

Brazil's Drex (Digital Real) aimed to include the ~16% of adults who remain unbanked/underbanked (23.8 million lack internet), building on Pix's success (150M+ users, 76% of adults; 71M brought into the formal economy 2020-2024) and democratizing asset ownership via tokenization. However, the Hyperledger Besu platform was decommissioned 4 November 2025 and the project is rebuilding "from scratch" toward a narrower credit/collateral (lien-reconciliation) scope — a retreat from the programmable-welfare ambition. Inclusion via offline/unconnected access remains NOT VERIFIED as a Drex design feature; the digital divide is flagged as a barrier.

Assessment: Model B is more realistic than Model A because it does not overburden the CBDC with solving the entire inclusion problem. The CBDC addresses targeted gaps (offline payments, programmable welfare, settlement in central bank money) while existing infrastructure handles mass adoption. India's programmable welfare pilots represent the most promising inclusion-specific use case globally — though the FY2025-26 circulation contraction is a caution that even targeted CBDCs do not automatically grow.

2.3 Model C: CBDC as Backup/Complement to Commercial Banking

Countries:

United Kingdom (digital pound, design phase),

EU (digital euro, advanced preparation),

Japan (digital yen, research),

Sweden (e-Krona, research)

In this model, financial inclusion is acknowledged as a consideration but is not the primary driver of CBDC development. The CBDC is designed primarily for payment system resilience, monetary sovereignty, and ensuring public access to central bank money in an increasingly cashless economy.

The United Kingdom has roughly 1.2 million unbanked adults. The BoE positions the digital pound as an open, "fully interoperable" platform complementary to cash (not a replacement). The inclusion focus is on ensuring the ~48% of the UK population who would find loss of cash access "extremely problematic" have a digital alternative. But the digital pound is fundamentally a payments modernization initiative, not an inclusion programme — and a decision on whether to proceed is only expected later in 2026.

The EU lists resilience and inclusion as two of the digital euro's key purposes: free basic use for individuals, public-sector distribution for the unbanked, offline functionality and physical cards (no smartphone required) as an explicit inclusion tool, European Accessibility Act compliance, and an ONCE Foundation agreement for visually-impaired users. The ECB concluded its preparation phase in October 2025 and the Governing Council moved the project to the next phase on 30 October 2025; an ECON Committee vote on the draft report is scheduled for 23 June 2026.

Japan frames inclusion goals around universal access, settlement finality, disaster resilience, and lower cost versus cash, with biometric authentication prioritized for the elderly. The existing Zengin System (1973) reduces urgency, and a decision on whether to issue a Digital Yen is expected in 2026.

Sweden has the strongest inclusion rationale among the advanced economies precisely because it is uniquely cashless (only ~5% in-store cash use in 2025): the e-Krona could bring the digitally-excluded back into the payments market under a "do no harm" design. But there is no issuance decision and no enabling legislation; the Riksbank's 2026 Payments Report recommends a parliamentary inquiry only once the EU digital euro Regulation is finalised.

Assessment: Model C is appropriate for advanced economies with high existing account ownership (97%+ in the UK and EU). The inclusion case for CBDC in these contexts centres on maintaining access to public money and addressing digital exclusion for specific vulnerable populations (elderly, disabled, unbanked minorities), not on mass financial inclusion. Sweden is the edge case where a near-cashless economy makes "access to public money" itself an inclusion question.

2.4 Model D: Inclusion Already Solved — CBDC Redundant or Deprioritized for Inclusion

Countries: Ghana (e-Cedi, pilot completed) and Kenya (no CBDC) for mobile-money dominance;

Australia,

Singapore,

South Korea,

Thailand,

Canada,

South Africa, and the

United States for high existing access

In this model, an existing instrument — mobile money, a fast payment system, or near-universal bank access — has already achieved significant financial inclusion, and the CBDC risks being redundant or competing with a proven system.

Ghana's financial inclusion landscape is dominated by MTN MoMo, Telecel (formerly Vodafone) Cash, and AirtelTigo Money, operating through an interoperable Mobile Money Interoperability System since 2018. The e-Cedi (designed by Giesecke+Devrient with offline-first capability) was positioned as complementary to mobile money — its core differentiator being offline access for the ~47% of Ghanaians lacking internet (self-reported figure). The Bank of Ghana Governor declared the pilot "completed" on 22 May 2026 and reframed the project toward wholesale/cross-border use; the retail e-Cedi remains unlaunched, with enabling legislation still not passed.

Australia (>99% account penetration), Singapore (>96%), South Korea (near-universal), and Thailand (~82%) each conclude that inclusion is a low priority or "not a key factor." Australia and South Korea explicitly say retail CBDC would not materially improve access; Thailand's BOT argues PromptPay already serves inclusion goals; Singapore's FAST/PayNow diminish urgency. All four pursue wholesale or programmable-payment tracks instead.

Canada studied inclusion as a consultation theme but found the case weakened by strong existing digital payments (Interac, the forthcoming Real-Time Rail); Bank of Canada research found even a $1.50/month friction drastically cuts uptake, implying a ~$440M/yr subsidy would be needed to overcome it. Retail CBDC work was formally scaled down in September 2024.

South Africa reached the same conclusion formally in its 27 November 2025 Position Paper: with ~85% of adults holding a bank account (Findex 2021) and PayShap real-time payments expanding, existing innovations address inclusion more effectively than a retail CBDC near-term.

The United States no longer cites inclusion as a CBDC rationale at all: EO 14178 bars federal CBDC activity, and opponents argue FedNow, Zelle/Venmo/CashApp, and GENIUS-Act (PL 119-27) stablecoins already address access gaps. (The Biden-era figure of ~4.5% / 5.9M unbanked households, FDIC 2021, is no longer the operative framing.)

Assessment: Where an existing instrument has achieved mass adoption, the incremental inclusion benefit of CBDC is genuinely unclear. Ghana's offline e-Cedi is a differentiated feature for the unconnected, but the rest of the population is already served. Policymakers in these contexts should focus on strengthening existing rails and interoperability rather than introducing a competing instrument — and "not launching a CBDC" can itself be the responsible inclusion decision, as South Africa explicitly argues.

Sources:

• IMF WP/23/104 — Nigeria's eNaira, One Year After (May 2023)
• CBOB — Public Update on Sand Dollar (November 2024)
• MyJoyOnline — eCedi will not disrupt Mobile Money transactions (2024)
• RBI Annual Report 2024-25
• SARB — Position Paper on the Necessity of a Retail CBDC (27 November 2025)

3. Evidence from Launched CBDCs

This section examines what the data actually shows about CBDC's impact on financial inclusion in countries that have launched or actively piloted retail CBDCs. The evidence is sobering. Only six jurisdictions have ever crossed into launched/live retail-CBDC territory (

Bahamas,

Nigeria,

Jamaica, Eastern Caribbean DCash [now discontinued],

China e-CNY [pilot-scale],

India e₹ [pilot]).

3.1 Nigeria: Coercion Backfired

The eNaira is the most extensively documented CBDC failure for financial inclusion.

The promise: 38 million unbanked adults would gain access to digital payments through Speed Wallets requiring only a phone number.

What happened:

• 98.5% of eNaira wallets were inactive in any given week, one year after launch (IMF Working Paper WP/23/104, May 2023, self-reported)
• Wallet downloads reached only 0.8% of bank accounts in the first year
• By July 2024, CBN Governor Cardoso reported 12% of the population had opened wallets, but only ~2.2 million cumulative transactions had been processed — negligible for a country of 220 million
• The NIN (National Identification Number) requirement for Tier 1 wallets created an immediate barrier, as many unbanked Nigerians lack this ID (Tier 0 nominally needs only a phone number)
• eNaira circulation reached only N18.31 billion (~$11.4 million) by February 2025 — 0.37% of currency in circulation
• The eNaira required internet connectivity (no offline capability), excluding precisely the connectivity-poor populations it claimed to serve
• Users reported the eNaira offered "no use beyond what the normal naira or bank apps would do"

The coercion disaster: In December 2022, the CBN imposed cash withdrawal limits (N100,000/week for individuals) and mandated a naira redesign, partly to force digital adoption including eNaira. The result was a severe liquidity crisis that devastated the informal sector (65% of GDP), triggered protests and attacks on bank branches, and deepened public distrust of both the government and digital currency. The CBN had minted only N3 billion worth of eNaira — 0.09% of total cash supply — making it wholly inadequate as a cash replacement.

The pivot: At the Cedi @ 60 International Currency Conference (November 2025), CBN official Musa Itopa Jimoha publicly acknowledged that the eNaira is "not a rosy story" and that the CBN is shifting to a wholesale CBDC focus, effectively abandoning the retail inclusion objective. The CBN has separately turned toward a regulated private stablecoin (cNGN) over its own CBDC.

Sources:

• IMF WP/23/104 — Nigeria's eNaira, One Year After (May 2023)
• Carnegie Endowment — Why Nigeria's Controversial Naira Redesign Policy Hasn't Met Its Objectives (January 2024)
• Cornell University — Nigeria's eNaira CBDC: What Went Wrong? (April 2023)
• HRF CBDC Tracker — Nigeria (accessed March 2026)

3.2 Bahamas: Sand Dollar Not Reaching Family Islands

The Sand Dollar is the world's first nationwide CBDC and was explicitly designed for financial inclusion in an archipelagic nation.

The promise: Reach the ~18% of Bahamians without bank accounts, particularly on remote Family Islands where banks are closing branches. Provide disaster-resilient payments (Hurricane Dorian destroyed bank branches in 2019).

What happened:

• As of November/December 2024: ~144,000 consumer wallets, 2,100 business wallets, B$1.9 million in circulation; ~138,000 personal wallets (+16% YoY)
• By early 2025: circulation reached B$2,482,045 — 0.39% of physical cash
• Cash in circulation increased by 20% despite the Sand Dollar's availability
• The onboarding design is genuinely low-barrier (no bank account required; smartphone wallets, card-based wallets, and a Mastercard-linked prepaid card — a world-first, February 2021), and offline functionality is by design (for inter-island/disaster resilience) but remains under development
• In July 2024, the CBOB announced a two-year plan to mandate commercial-bank Sand Dollar integration (effective ~mid-2026) — an implicit acknowledgment that voluntary adoption had stalled

The Family Islands gap: While the government uses the Sand Dollar for collections and disbursements in Family Island cash districts, detailed data on actual Family Island adoption remains limited. The structural challenge persists: islands without reliable internet, electricity, or merchant infrastructure cannot support a digital payment instrument regardless of its design. The IMF's 2025 Article IV recognised progress but urged telecom/electricity investment.

Sources:

• CBOB — Public Update on Sand Dollar (March 2023)
• The Tribune — Bahamas 'going in reverse' through 20% cash increase (January 2025)
• FX Leaders — Bahamas Sets Two-Year Plan for Banks to Adopt Sand Dollar (July 2024)

3.3 Jamaica: ~282,000 Wallets but Only 2,379 Merchants

JAM-DEX (Jamaica Digital Exchange) received full legal tender status in June 2022 — the first country to designate its CBDC as legal tender by statute.

Adoption data:

• ~282,274 registered wallets by end-2024 (+7% YoY), ~9% of population
• Only 2,379 merchants registered as of September 2024
• Transaction value surged 550% and volumes grew ~267% year-over-year in 2025
• But growth was driven by existing users transacting more frequently, not new user acquisition
• JAM-DEX represents approximately 0.1% of currency in circulation (J$258.5M end-2024 / ~J$260.05M end-2025)
• Offline capability is NOT VERIFIED as a JAM-DEX feature, and onboarding requires joining a deposit-taking institution — partly contradicting the inclusion goal

The merchant infrastructure problem: BOJ Governor Richard Byles has expressed frustration that commercial banks have not invested in retrofitting POS terminals to accept JAM-DEX (he called slow adoption "a disappointment" on 27 May 2026; JN Bank is expected to be the first DTI to retrofit POS machines by July 2026). The BOJ has offered to cover half the cost of POS upgrades, but banks cite substantial investment requirements. Without merchant acceptance, consumers have no reason to hold JAM-DEX. Without consumer demand, merchants have no reason to invest. This circular dependency is the fundamental barrier to CBDC-driven inclusion.

The cultural barrier: As Silicon Caribe reported in March 2026, the core challenge is "cultural rather than purely technical." Jamaica remains heavily cash-dependent (Hurricane Melissa in October 2025 pushed currency in circulation up ~13% YoY) despite having a legally recognized, technically functional CBDC since 2022. For years JAM-DEX had only one public wallet (NCB's Lynk); JN Bank's JN Pay (July 2025) was only the second.

Sources:

• Bank of Jamaica Pushes Banks to Accelerate JAM-DEX Adoption — Silicon Caribe (March 2026)
• Jamaica Observer — Byles blasts banks over Jam-Dex delays (February 2026)
• HRF CBDC Tracker — Jamaica (accessed March 2026)

3.4 India: ~7-8 Million Users but Negligible vs UPI (500M+)

India's e-Rupee is the world's second-largest CBDC pilot after

China's e-CNY.

Adoption data (as of late 2025 / FY2025-26):

• ~7-8 million retail users across ~19 participating banks (December 2025)
• ~300,000 merchants accepting e-Rupee; 26 cities covered (end 2024)
• Circulation: ₹771.7 crore (~US$90 million) as of 31 March 2026 — down ~24% year-over-year from ₹1,016.5 crore, the first reported YoY decline (RBI Annual Report 2025-26, self-reported)
• e-Rupee represents ~0.003% of total currency in circulation

The UPI comparison: UPI processes over 20 billion transactions per month with 500+ million unique users. The e-Rupee's ~7-8 million users represent roughly 1.5% of UPI's user base. The RBI itself has maintained there is "no rush" to scale the e-Rupee, suggesting the pilot's purpose is learning rather than immediate mass adoption — and FY2025-26's circulation contraction underscores that even a targeted pilot does not automatically grow.

Where the e-Rupee's inclusion contribution is genuinely differentiated:

1. Offline payments (NFC-based, officially launched October 2025 at Global Fintech Fest; telecom-assisted/feature-phone payments) — primary strategy for the ~65% rural population where internet connectivity is unreliable
2. Programmable welfare delivery — Gujarat G-SAFAL, Andhra Pradesh DEEPAM 2.0, Odisha Subhadra Yojana, and the PMGKAY food-currency pilot launched in Puducherry on 26 February 2026 (Canara Bank), with national ambition to reach 80 crore (800 million) beneficiaries — would be the world's largest CBDC welfare delivery
3. Feature phone compatibility — telecom-assisted/2G payments under development
4. Agent network distribution — PayNearby and Bankit (authorized non-bank operators) extending e-Rupee access through rural agent networks

Assessment: India's e-Rupee demonstrates that in countries with strong existing digital payment infrastructure, the CBDC's inclusion value lies not in replacing the dominant system but in filling specific gaps that the existing system cannot address. Programmable welfare delivery is the strongest inclusion case — but the FY2025-26 decline shows that even this requires sustained pull-through to grow.

Sources:

• RBI Annual Report 2025-26 — e₹-R circulation ₹771.7 crore (29 May 2026)
• IBEF — RBI's offline digital rupee is here (October 2025)
• PIB — CBDC-based Digital Food Currency pilot for PMGKAY in Puducherry (February 2026)
• CoinLaw — UPI Statistics 2025

3.5 China: Largest Pilot, Low-Barrier Onboarding, Crowded Out by Wallets

China's e-CNY is the world's largest CBDC experiment, with strong inclusion-oriented onboarding design but limited differentiated value.

Inclusion-relevant design:

• Category 4 wallet requires only a phone number (no bank account), with a CNY 10,000 balance cap — the most generous simplified tier among launched CBDCs
• Zero fees, offline NFC/Bluetooth, SIM card wallets (work with the phone powered off), and hardware wallets (IC cards, wearables) for users without smartphones — the most complete offline/non-smartphone toolkit deployed anywhere
• Stated target: ~234 million unbanked adults (figure NOT VERIFIED / possibly outdated) plus integration into government benefit distribution

Adoption data (self-reported PBOC aggregate):

• 2.25 billion wallets (September 2025, multiple per user); 3.48 billion cumulative transactions; ~5.6 million merchants
• Cumulative CNY 16.7 trillion (~USD 2.37 trillion) as of November 2025; average transaction ~CNY 428 (down from CNY 1,895 in 2023)
• Only ~0.16% of M0 (June 2023)

Why inclusion value is limited: Alipay and WeChat Pay already handle over 90% of mobile payments, so the e-CNY offers little incremental access to users already embedded in those ecosystems. From 1 January 2026 the e-CNY was reclassified toward a deposit-money model (interest-bearing verified wallets), and the operator roster doubled to 22 (April 2026) — signals of a transition from pilot toward full-scale deployment, but driven by state-distribution metrics rather than organic inclusion demand.

Sources:

• PBOC e-CNY aggregate data (self-reported, November 2025)
• PIIE — Is China's e-CNY still a CBDC? (2026)

3.6 What the Data Actually Tells Us

Across all launched and piloted CBDCs, the inclusion evidence is consistent:

1. No CBDC has achieved meaningful financial inclusion at scale. The highest adoption relative to population is Jamaica (~9% account penetration), but active usage is far lower, merchant acceptance is minimal, and the unbanked population it was designed to reach is not being served.

2. Coercion destroys trust. Nigeria's attempt to force digital adoption through cash restrictions is the single most important cautionary tale in the CBDC landscape. Policymakers must internalize this lesson: forced adoption of any payment instrument — including CBDC — will backfire.

3. Launching is not adopting. The Bahamas launched the world's first CBDC in 2020. Five years later, it represents 0.39% of cash in circulation and cash has increased. India's e₹ pilot actually contracted ~24% in FY2025-26. Technical readiness is a necessary but insufficient condition for adoption.

4. Merchant infrastructure is the binding constraint. In Jamaica (2,379 merchants), the Bahamas (low active acceptance), and Nigeria (~10% of POS terminals year 1), the lack of merchant acceptance creates a circular dependency that no amount of consumer marketing can overcome.

5. Programmable welfare delivery is the strongest inclusion use case. India's government scheme integrations (G-SAFAL, DEEPAM 2.0, PMGKAY), South Korea's deposit-token EV-charging subsidies, and Russia's targeted "coloured funds" represent the most promising evidence that CBDC can address specific inclusion/leakage gaps that existing payment systems cannot.

4. Comparative Table — Inclusion Goal, Offline Access, Onboarding (All 20)

The table below mirrors the inclusion dimension (t5) across all 20 jurisdictions: the stated inclusion goal/priority, whether offline access is a design feature, and the onboarding model.

Sources: Compiled from the cbdc-frameworks fact matrix and per-jurisdiction profiles. All data points sourced individually in Sections 2, 3, and 5.

5. Design Features That Matter for Inclusion

The evidence from launched CBDCs reveals a consistent set of design features that determine whether a CBDC can plausibly serve financial inclusion goals. The presence or absence of these features is more predictive of inclusion outcomes than the decision to launch a CBDC in the first place.

5.1 Offline Capability

Who has it (deployed or core design):

China (e-CNY: SIM card wallets, NFC, Bluetooth, hardware wallets — tested at 2022 Winter Olympics),

India (e-Rupee: NFC tap-and-pay + telecom-assisted, launched October 2025),

Bahamas (Sand Dollar: pre-authorized offline transactions, under development), Ghana (e-Cedi: offline-first design, award-winning),

EU (digital euro: device-to-device via secure element + physical cards),

Sweden (e-Krona: offline card, Phase 4)

Who prioritises it for launch but defers full offline:

UK (deferred offline payments at launch; device offline deferred),

Japan (offline under development for disaster resilience)

Who does not / NOT VERIFIED:

Nigeria (eNaira required internet connectivity),

Jamaica (JAM-DEX offline NOT VERIFIED), Eastern Caribbean (DCash 1.0 had none — a key vulnerability for a storm-prone region),

Brazil and

Russia (NOT VERIFIED)

Why it matters: The World Bank and IMF both identify offline capability as a prerequisite for CBDC-driven inclusion. The populations most likely to be unbanked — rural, low-income, in areas with poor infrastructure — are also those least likely to have reliable internet. A CBDC without offline capability is, by definition, inaccessible to the populations it claims to serve. Nigeria's lack of offline support is widely contrasted with Ghana's offline-first e-Cedi.

The implementation challenge: Offline payments introduce double-spending risk. Solutions include pre-authorized transaction limits, hardware security elements, and reconciliation upon reconnection. The Bank of England's October 2025 design note distinguishes between "deferred offline payments" (viable for launch) and "device offline payments" (innovative but unproven at scale). Sweden's Phase 4 card capped offline wallets at SEK 3,000 with a maximum of 5 consecutive offline payments before reconnection. For inclusion purposes, even basic deferred offline capability is transformative.

Sources:

• BoE — Offline Payments Design Note (2025)
• IBEF — RBI's offline digital rupee is here (October 2025)

5.2 Simplified KYC for Low-Value Wallets

Tiered KYC is the mechanism that allows unbanked populations to access CBDC without the documentation requirements that exclude them from traditional banking. The evidence from launched and piloted CBDCs:

The NIN trap in Nigeria: Despite offering a Tier 0 wallet requiring "only a phone number," Nigeria's eNaira guidelines required a National Identification Number (NIN) from Tier 1. Many unbanked Nigerians lack a NIN, creating an immediate exclusion barrier. The IMF identified this as a factor in the eNaira's failure. Lesson: Simplified KYC must genuinely accept what unbanked populations actually possess — a phone number, possibly a SIM card — not what the government wishes they possessed.

The

China model: China's Category 4 wallet (phone number only, CNY 10,000 balance cap) represents the most generous simplified tier among launched CBDCs. The PBOC acknowledges that phone numbers are linked to government IDs (mandatory since 2010), but claims data-protection rules prevent carriers from sharing identifying information with the central bank absent legal process. This provides functional "controllable anonymity" for small transactions while maintaining a traceable link for law enforcement.

The Russia counter-example:

Russia frames the digital ruble as an inclusion tool (free transactions, integration with bank apps, universal QR codes) but requires Gosuslugi/ESIA in-person verification to obtain a unique signature key — a high-friction onboarding that creates significant barriers for the elderly, rural, and unbanked, the precise populations inclusion is meant to reach.

5.3 Mobile-First vs Smartphone-Required

The critical distinction: A CBDC that requires a smartphone excludes the hundreds of millions of unbanked adults who own only basic or feature phones. Of the 900 million unbanked adults with mobile phones, approximately 370 million have feature phones only (Global Findex 2025).

• Feature phone / non-smartphone support:
  China offers IC cards, NFC cards, and wearables that function without any phone — the most inclusive deployed approach.
  India's e-Rupee is developing telecom-assisted/feature-phone payments. The
  EU digital euro explicitly includes physical cards (no smartphone required), and
  Sweden's offline card works without internet or smartphone.
• Smartphone-required: Nigeria's eNaira, Jamaica's JAM-DEX, and the Bahamas' Sand Dollar all primarily require smartphone apps. This creates an immediate exclusion barrier for the poorest unbanked populations.
• No retail front-end at all:
  Australia,
  Singapore,
  South Africa, and
  Canada have no retail onboarding because they are wholesale-focused or have ruled out retail CBDC.

Recommendation: Any CBDC claiming to serve financial inclusion must support at minimum feature phone access (via USSD or similar protocol) and ideally hardware-wallet/card alternatives for non-phone users. The EU, China, and Sweden show this is achievable; smartphone-only CBDCs are not inclusion instruments. No launched CBDC yet supports a USSD interface comparable to M-Pesa's *99# — a critical gap.

5.4 Integration with Existing ID Systems

The ability to link CBDC wallets to national identity infrastructure determines onboarding friction:

• India (Aadhaar): 1.39 billion residents covered. Aadhaar-based e-KYC enables remote wallet activation without physical bank visits — the gold standard for identity-linked CBDC onboarding in large developing economies (JAM Trinity).
• Nigeria (NIN/BVN): The NIN covers fewer adults than Aadhaar relative to population, and the BVN requirement for higher tiers creates a circular dependency — you need a bank account to get a BVN, but the CBDC was supposed to serve those without bank accounts.
• Russia (Gosuslugi/ESIA): In-person ESIA verification to obtain a signature key is the most onerous identity-onboarding step among the surveyed jurisdictions.
• Bahamas / Eastern Caribbean: Value-based / Tier 1 wallets require only minimal ID and no bank account, which is the correct calibration — though small populations make verification more manageable.

Lesson: CBDC identity requirements must be calibrated to the actual identity documentation coverage of the target unbanked population. Requiring an ID that unbanked people do not possess defeats the purpose.

5.5 Free Basic Use

• China: Zero fees for individual users for wallet opening, e-CNY exchange, and basic payments; the PBOC does not charge operators, and operators do not charge users.
• India: No transaction fees during the pilot phase.
• Bahamas / Nigeria: No transaction fees for basic use.
• EU: Free basic use for individuals is a stated inclusion commitment in the digital euro design.
• Russia: Free transactions for individuals (though onboarding friction offsets this).

Assessment: Free basic use is a necessary but not sufficient condition for inclusion. Every launched CBDC offers zero transaction fees, yet none has achieved meaningful inclusion. Cost is not the binding constraint — utility, trust, and infrastructure are.

5.6 Agent Networks and Physical Access Points

Mobile money's success in Africa is built on agent networks — physical locations (shops, kiosks) where users can convert cash to digital money and vice versa. The absence of comparable agent infrastructure for CBDCs is a critical gap:

• Nigeria: The eNaira included "Super Agents and Agents" in its design, but the agent network was sparse compared to mobile money operators like OPay and PalmPay.
• India: PayNearby and Bankit (authorized non-bank operators) agent networks are being integrated with the e-Rupee, extending reach to rural areas without bank branches — the most promising CBDC agent-network approach currently.
• Ghana: The e-Cedi design leverages existing mobile money agents and licensed institutions (CalBank, Telecel Cash in the pilot) for distribution.
• EU: Public entities such as post offices are envisaged as distribution/onboarding points for the unbanked.
• Bahamas: Sand Dollar Ambassadors and giveaway programmes promote adoption — these are marketing efforts, not infrastructure.

Lesson: Without a dense physical access network for cash-in/cash-out, a CBDC cannot serve cash-dependent populations. Agent networks are infrastructure, not marketing.

6. What Works and What Doesn't

6.1 What Works

Simplified wallets with genuine low-barrier access. China's Category 4 wallet (phone number only, no bank account needed, zero fees) and India's Basic wallet demonstrate that reducing onboarding friction to the absolute minimum is essential. The key word is "genuine" — Nigeria's Tier 0 wallet was nominally simplified but the NIN requirement at Tier 1 negated this, and Russia's ESIA in-person step is the opposite of low-barrier.

Offline payments. Every CBDC that has achieved even modest traction with underserved populations has invested in offline capability. India's NFC launch (October 2025), China's SIM card wallets, the Bahamas' pre-authorized offline transactions, the EU's physical cards, and Sweden's offline card all address the connectivity gap that is the primary barrier to digital financial inclusion in developing countries.

Integration with existing payment rails. India's strategy of integrating the e-Rupee with UPI's 300+ million merchant touchpoints (via UPI QR interoperability on e-Rupee wallets at HDFC, Axis, Kotak, and SBI) means the e-Rupee does not need to build a separate merchant network. The EU's build on TIPS and Brazil's intended Pix integration follow the same logic. Building a merchant network from scratch has proven impossible for every launched CBDC.

Programmable welfare delivery. India's government scheme integrations represent the strongest evidence that CBDC can uniquely contribute to inclusion. Purpose-bound tokens that ensure food subsidies reach beneficiaries as food, agricultural inputs reach farmers as inputs, and LPG subsidies are redeemed only on actual gas delivery address genuine problems (subsidy leakage, corruption) that conventional payment systems cannot solve at this granularity. South Korea's deposit-token EV-charging subsidies (a world-first national treasury operation in digital currency) and Russia's targeted "coloured funds" extend the same model.

6.2 What Doesn't Work

Coercion. Nigeria's December 2022 cash restriction policy is the defining failure. Attempting to force adoption of a digital currency — whether CBDC, mobile money, or bank accounts — in a predominantly cash economy (65% informal sector) triggers immediate backlash, erodes trust, and disproportionately harms the most vulnerable. The CBN's subsequent pivot to wholesale CBDC is an implicit admission that forced retail adoption failed.

Assumption of smartphone access. Designing a CBDC that requires a smartphone app excludes the very populations the CBDC is supposed to include. Nigeria, Jamaica, and the Bahamas all leaned on this assumption. Until a CBDC supports feature phones (USSD), hardware wallets/cards, or agent-assisted transactions for non-smartphone users, it is not an inclusion tool.

High-friction onboarding that recreates banking barriers. If obtaining a CBDC wallet requires the same documentation as opening a bank account — or worse, in-person verification (Russia's ESIA) — the CBDC has not expanded access. Nigeria's NIN requirement and the general requirement for government-issued ID across most CBDCs perpetuate the exclusion of populations who lack formal identification.

Single-provider bottlenecks. Jamaica's JAM-DEX had only one public wallet provider (NCB's Lynk) for over two years after launch; JN Bank's JN Pay (July 2025) was only the second. This created an onboarding bottleneck, limited competition, and gave one institution excessive control over the user experience. CBDCs should launch with multiple providers from day one.

Assumption that supply creates demand. Every launched CBDC has demonstrated that making a CBDC available does not mean people will use it. The Bahamas offered giveaways. Jamaica's BOJ offered to subsidize POS terminals. Nigeria's CBN restricted cash. India's e₹ circulation fell ~24% in FY2025-26. None achieved meaningful adoption through supply-side measures. The fundamental error is assuming the problem is access to digital payment instruments; in most target countries the problem is a combination of trust, utility, infrastructure, and habit.

6.3 The Critical Lesson: CBDC Is NOT a Shortcut to Financial Inclusion

The evidence from every launched CBDC confirms what the World Bank has argued from the outset: CBDC is not a "silver bullet" for financial inclusion. Financial inclusion requires:

1. Trust in the issuing institution — which cannot be manufactured by issuing a digital currency
2. Physical infrastructure — agent networks, POS terminals, reliable electricity, mobile coverage
3. A functioning identity ecosystem — that covers the target unbanked population
4. A value proposition for users — the CBDC must do something no existing instrument does
5. A value proposition for merchants — without merchant acceptance, there is no payment network
6. Time and sustained investment — M-Pesa took over a decade to reach its current scale

A CBDC can complement these prerequisites. It cannot substitute for them. South Africa's explicit conclusion that "not launching a CBDC" is the responsible inclusion decision — given PayShap and NPS expansion — is the logical corollary for countries that already have functioning rails.

Sources:

• World Bank Blog — CBDC and Financial Inclusion: Changing the Paradigm (Part 1)
• IMF Fintech Note 2024/005 — CBDC Adoption: Inclusive Strategies for Intermediaries and Users

7. Recommended Framework

7.1 Prerequisites Before CBDC Can Serve Inclusion Goals

Policymakers must honestly assess whether the following prerequisites are in place before expecting a CBDC to advance financial inclusion. If they are not, resources are better directed at building them first:

7.2 Design Checklist for Inclusion-Focused CBDC

If the prerequisites are met and a policy decision is taken to proceed with CBDC for inclusion, the following design features should be treated as mandatory, not optional:

Tier 1 — Non-Negotiable for Inclusion:

• Offline payment capability (NFC, card, or equivalent) for areas without internet
• Lowest-tier wallet with genuine simplified KYC (phone number only, no government ID required at the base tier)
• Feature phone access (USSD or telecom-assisted) in addition to smartphone app
• Zero transaction fees for basic use
• Multiple wallet providers at launch (minimum 3 — avoid Jamaica's single-provider bottleneck)
• Agent network integration for cash-in/cash-out
• Interoperability with existing payment systems (mobile money, FPS, bank transfers)

Tier 2 — Strongly Recommended:

• Hardware wallet / physical card option (IC card, NFC card) for non-phone users (cf. China, EU, Sweden)
• Programmable capability for government welfare delivery (cf. India PMGKAY, South Korea subsidies)
• Integration with national digital ID for seamless onboarding (where ID coverage is high — cf. Aadhaar)
• UPI/FPS QR interoperability to leverage existing merchant networks
• Privacy protections for small-value transactions (cash-like anonymity for the lowest tier)

Tier 3 — Important for Sustainability:

• Government salary and transfer disbursement through CBDC wallets
• Merchant incentive programmes (subsidized POS, fee waivers)
• Financial literacy and user education programmes
• Regular publication of adoption data (wallets, transactions, merchant count) for accountability

7.3 Integration with National Financial Inclusion Strategy

A CBDC for inclusion must be embedded within the country's National Financial Inclusion Strategy (NFIS), not developed in isolation by the central bank's technology team. Integration requirements:

1. Align CBDC objectives with NFIS targets. If the NFIS targets 80% account ownership by 2030, specify what share CBDC is expected to contribute and how.
2. Coordinate with mobile money regulation. In countries with established mobile money (Ghana, Kenya, Tanzania), the CBDC must complement — not compete with — mobile money. The Bank of Ghana's explicit commitment that the e-Cedi "will not disrupt Mobile Money transactions" reflects this principle.
3. Embed in the social protection delivery chain. India's approach — routing government welfare (G-SAFAL, DEEPAM 2.0, PMGKAY) through programmable CBDC — and South Korea's deposit-token subsidy disbursement create pull-through adoption by linking the CBDC to benefits people already receive. This is vastly more effective than marketing campaigns or giveaways.
4. Establish measurable inclusion KPIs. Track not just wallet downloads (a vanity metric) but:
   • Active wallets as % of target unbanked population (monthly)
   • Merchant density per 10,000 population in target areas
   • Transaction volume per active wallet (usage intensity)
   • Cash-in/cash-out agent coverage per 10,000 population
   • Welfare disbursement volume through CBDC
5. Publish data regularly. Nigeria's eNaira and the Bahamas' Sand Dollar both suffered from opacity about actual adoption; India's most reliable figures come from the RBI Annual Report. The IMF's Working Paper on Nigeria was only possible because of independent analysis. Central banks must publish quarterly adoption data to maintain accountability.

8. Decision Matrix

The following decision matrix is designed for policymakers evaluating whether CBDC should be a component of their national financial inclusion strategy.

8.1 Should You Pursue CBDC for Financial Inclusion?

START
  |
  v
Does your country have >30% unbanked adult population?
  |
  YES --> Does an existing instrument (mobile money, FPS) already
  |       serve >50% of the adult population?
  |         |
  |         YES --> CBDC adds limited incremental inclusion value.
  |         |       Focus: programmable welfare, offline payments,
  |         |       settlement resilience. [Model B or Model D]
  |         |
  |         NO --> Are the prerequisites (Section 7.1) in place?
  |                 |
  |                 YES --> CBDC may be warranted as part of
  |                 |       inclusion strategy. [Model A or Model B]
  |                 |       Proceed with Design Checklist (7.2).
  |                 |
  |                 NO --> Build prerequisites first.
  |                        Mobile money or FPS is likely faster
  |                        and cheaper. CBDC can follow later.
  |
  NO --> Is the primary motivation inclusion, or payment system
         resilience / monetary sovereignty?
           |
           INCLUSION --> With <30% unbanked, the marginal inclusion
           |             benefit of CBDC is small. Focus on
           |             vulnerable populations, digital exclusion,
           |             cash access preservation. [Model C]
           |
           OTHER --> CBDC decision should be driven by
                     non-inclusion objectives.
                     See [technology](/app/regulations/research/deep-research/cbdc-frameworks/guidance-document/technology-design-choices)
                     and [privacy](/app/regulations/research/deep-research/cbdc-frameworks/guidance-document/privacy-data-protection) guidance.

8.2 Inclusion-Specific Risk Assessment

8.3 Success Criteria for Inclusion-Focused CBDC

A CBDC should be evaluated against the following inclusion-specific success criteria, measured at 3 years post-launch:

Note: No launched CBDC has met all of these thresholds. India's e₹ circulation actually contracted ~24% in FY2025-26, underscoring that adoption is not monotonic. This reflects the genuine difficulty of the inclusion challenge, not a flaw in the metrics. Policymakers should set realistic targets informed by this evidence.

Wikilinks

• Nigeria,
  Bahamas,
  India,
  Jamaica,
  China
• Eastern Caribbean,
  Brazil,
  Russia,
  Japan
• EU,
  United Kingdom,
  Sweden
• Ghana,
  South Africa
• South Korea,
  Thailand,
  Singapore,
  Australia
• Canada,
  United States
• World Bank, IMF
• technology, privacy, cross-border

Sources Summary

Primary Data Sources

• World Bank Global Findex Database 2025
• World Bank Global Findex Database 2021
• IMF WP/23/104 — Nigeria's eNaira, One Year After (May 2023)
• RBI Annual Report 2025-26 (May 2026)
• RBI Concept Note on CBDC (October 2022)

IMF Policy Frameworks

• IMF CBDC Virtual Handbook
• IMF Policy Paper 2025/041 — CBDC: Further Navigating Challenges and Risks (November 2025)
• IMF Fintech Note 2024/005 — CBDC Adoption: Inclusive Strategies
• IMF Fintech Note 2024/006 — Positioning CBDC in the Payments Landscape
• IMF WP/23/069 — Central Bank Digital Currency and Financial Inclusion

World Bank Research

• World Bank Blog — Is CBDC the Right Tool to Expand Financial Inclusion?
• World Bank Blog — CBDC and Financial Inclusion: Changing the Paradigm (Part 1)
• World Bank — Central Bank Digital Currency: A Payments Perspective

Country-Specific Sources

• Carnegie Endowment — Why Nigeria's Controversial Naira Redesign Policy Hasn't Met Its Objectives (January 2024)
• Cornell University — Nigeria's eNaira CBDC: What Went Wrong? (April 2023)
• CBOB — Public Update on Sand Dollar (March 2023)
• The Tribune — Bahamas 'going in reverse' through 20% cash increase (January 2025)
• Silicon Caribe — Bank of Jamaica Pushes Banks to Accelerate JAM-DEX Adoption (March 2026)
• Jamaica Observer — Byles blasts banks over Jam-Dex delays (February 2026)
• IBEF — RBI's offline digital rupee is here (October 2025)
• PIB — CBDC-based Digital Food Currency pilot for PMGKAY in Puducherry (February 2026)
• ECCB Suspends DCash 2.0 — Antigua News Room (February 2026)
• SARB — Position Paper on the Necessity of a Retail CBDC (27 November 2025)
• BoE — Offline Payments Design Note (2025)
• G+D — Bank of Ghana partners with G+D to pilot CBDC (2021)
• HRF CBDC Tracker — Nigeria (accessed March 2026)
• HRF CBDC Tracker — Jamaica (accessed March 2026)
• HRF CBDC Tracker — Ghana (accessed March 2026)
• HRF CBDC Tracker — Brazil (accessed March 2026)

Verification Notes

All adoption statistics were cross-referenced against the cbdc-frameworks fact matrix (canonical per-jurisdiction facts, refreshed June 2026) and the underlying jurisdiction profiles. Adoption and transaction figures are self-reported by issuing central banks unless otherwise noted and are flagged accordingly. The following items could not be independently verified to primary-source level:

1. Exact current number of active CBDC wallets (vs. downloaded/opened): No CBDC jurisdiction publishes regular active-wallet data. The 98.5% inactive figure for Nigeria comes from the IMF (WP/23/104) and applies to one-year-post-launch data (2022).
2. China's 234 million unbanked adults: Sourced from World Bank/CGAP data but the estimate date is unclear and may be outdated given China's rapid financial inclusion progress; flagged NOT VERIFIED in the matrix.
3. Ghana's ~47% lacking internet access: Self-reported / not independently verified; the e-Cedi pilot was declared "completed" (22 May 2026) with the project reframed toward wholesale/cross-border and enabling legislation still unpassed.
4. India's e₹-R circulation contraction: The ~24% YoY decline to ₹771.7 crore (31 Mar 2026) is self-reported by the RBI Annual Report 2025-26 and flagged accordingly; it is the first reported YoY decline.
5. India's Jan Dhan-to-e-Rupee integration status: No formal integration between Jan Dhan account infrastructure and e-Rupee wallet systems has been publicly announced — the two systems operate in parallel.
6. Offline capability for Brazil, Russia, Jamaica: NOT VERIFIED as a stated design feature in the matrix.
7. Success criteria thresholds in Section 8.3: These are the author's proposed benchmarks based on the evidence reviewed. No international body has published comparable CBDC-specific inclusion KPIs.