Legal Framework & Authorization

1. Global Landscape --- Legislative Models

The legal frameworks underpinning central bank digital currencies vary dramatically across jurisdictions. Based on analysis of 20 jurisdictions, six distinct legislative models emerge. Each reflects the jurisdiction's legal tradition, political system, urgency of deployment, and appetite for institutional change. Policymakers designing CBDC legal frameworks should understand these models before selecting an approach.

Across the 20 jurisdictions studied, six have a CBDC that has been launched or made operationally live —

the Bahamas (Sand Dollar),

Nigeria (eNaira),

Jamaica (JAM-DEX), the Eastern Caribbean (DCash, pilot concluded and successor suspended),

China (e-CNY, operational at pilot scale), and

India (e₹, operational at pilot scale). One — the

United States — is actively anti-CBDC. The remaining thirteen are in research, design, or wholesale-pilot phases.

Model A: Dedicated CBDC Legislation

Approach: A new, purpose-built statute or regulation specifically authorizing CBDC issuance, defining its legal tender status, setting governance rules, and establishing the rights and obligations of all participants.

Jurisdictions using this model:

• EU --- The European Commission tabled COM(2023) 369 on 28 June 2023, a standalone regulation on the establishment of the digital euro under Art. 133 TFEU (legislative procedure 2023/0212(COD)). This is part of a three-regulation "single currency package" that also addresses digital euro services by PSPs in non-euro Member States (COM(2023) 368) and the legal tender of physical cash (COM(2023) 364). The Council agreed its negotiating position on 19 December 2025, endorsing both online and offline use. The regulation defines legal tender status, holding limits (modelled at EUR 3,000), offline payment requirements, privacy architecture, and a compensation model for intermediaries. The ECB's preparation phase concluded in October 2025, and the Governing Council moved the project to its next phase on 29-30 October 2025. The European Parliament adopted amendments endorsing both online and offline functionality on 10 February 2026, and the ECON Committee vote on the draft report is scheduled for 23 June 2026. Source: EUR-Lex --- COM(2023) 369 final, 28 June 2023.

• Russia --- Federal Law No. 340-FZ, signed 1 August 2023, established the legal framework for the digital ruble. The law amended Articles 128, 140, 1128, and 1174 of the Civil Code to define the digital ruble as a third form of the ruble. It designates the Central Bank of Russia (CBR) as sole issuer and platform operator, requires transaction record-keeping, and establishes collaboration with Rosfinmonitoring for AML/CFT. Source: Digital Policy Alert --- Federal Law 340-FZ, August 2023.

• Jamaica --- The Bank of Jamaica (Amendment) Act, 2022 (Act 5 of 2022), enacted 14 June 2022, formally designated JAM-DEX as legal tender and expanded all statutory references to currency to include "virtual tokens." Jamaica was the first country to designate a CBDC as legal tender by primary legislation. Source: Jamaica Information Service --- Senate Approves Central Bank Digital Currency, June 2022.

• Eastern Caribbean --- 2020 amendments to Articles 2 and 18 of the ECCB Agreement (1983) extended the definition of "currency" to include "digital currency" and conferred legal tender status, with each of the eight ECCU legislatures enacting domestic implementing law. This is the closest analogue to a dedicated multi-national CBDC statute, though DCash itself was a pilot rather than a permanently launched CBDC, and DCash 2.0 development was suspended on 13 February 2026.

Outcomes: Dedicated legislation provides the highest legal certainty. The EU model is the most comprehensive, covering distribution obligations, fee caps, privacy safeguards, and financial stability mechanisms in a single instrument. Russia's approach provides legal clarity but raises human rights concerns given the absence of judicial oversight provisions. Jamaica's model is the simplest --- a targeted amendment granting legal tender status without detailed operational rules. The Eastern Caribbean's amendments uniquely conferred cross-border legal tender across eight sovereign territories, but the pilot's suspension shows that legal authorization does not guarantee sustained deployment.

Assessment: This model works best when the jurisdiction intends to proceed to issuance and needs to resolve legal ambiguity before launch. It is the gold standard recommended by the IMF CBDC Virtual Handbook (Policy Paper 2025/041) for jurisdictions approaching issuance decisions.

Model B: Central Bank Act Amendment

Approach: Amending the existing central bank legislation to expand its mandate to cover digital currency issuance, without creating a standalone CBDC statute.

Jurisdictions using this model:

• India --- Section 139 of the Finance Act, 2022 amended the Reserve Bank of India Act, 1934, to include "bank note" issued in digital form, and inserted a new Section 22A to provide regulatory flexibility for digital banknotes. The e₹ is legal tender under Section 26 of the RBI Act, exchangeable at par 1:1, and a direct liability of the RBI. This single definitional change was the legislative enabler for India's e-Rupee pilot, which launched within months. No standalone CBDC regulation has followed. Source: RBI Act, 1934 (as amended); India Code --- Section 22A.

• Bahamas --- The Central Bank of The Bahamas Act, 2020 provides authority for the CBOB to issue digital currency and designates the Sand Dollar as "equivalent in every respect to paper currency" and full legal tender. It is supported by the Banks & Trust Companies Regulation Act 2020 and the Co-operative Credit Unions Act 2015; the DARE Act 2024 covers broader digital assets. There is no standalone CBDC statute. Source: Central Bank of The Bahamas Act; Sand Dollar Legal Framework.

Outcomes: India's approach enabled rapid pilot deployment (wholesale 1 November 2022, retail 1 December 2022) with minimal legislative friction. The Bahamas established legal authority before its October 2020 launch. Both jurisdictions avoided the delay of crafting entirely new legislation.

Assessment: This model is efficient and minimally disruptive to the legal system. It works when the existing central bank statute is broad enough that a targeted amendment suffices. The trade-off is that comprehensive operational rules (privacy thresholds, holding limits, intermediary obligations) must then be established through secondary regulation or central bank directives --- which in India's case remain incomplete as of June 2026, even as e₹-R circulation contracted roughly 24% year-on-year in FY2025-26.

Model C: Existing Monetary Law Interpretation

Approach: Relying on the central bank's existing statutory authority over currency issuance and payment systems without any legislative amendment. The CBDC operates under administrative authority and policy documents.

Jurisdictions using this model:

• China --- The e-CNY has operated since April 2020 under the PBOC's existing institutional mandate. The PBOC's July 2021 white paper established design principles, but no enacted legislation specifically authorizes the digital yuan. A draft amendment to the People's Bank of China Law (October 2020) included Art. 19, 22, and 65 recognising digital RMB, but this draft remains unenacted, leaving what NPC representatives have called a "legal vacuum." Sources: PBOC White Paper, July 2021; Dechert LLP --- China to Legalize Digital RMB, November 2020.

• Nigeria --- The eNaira launched on 25 October 2021 under Section 19 of the Central Bank of Nigeria Act, 2007, and the Banks and Other Financial Institutions Act, 2020. The CBN issued Regulatory Guidelines on the eNaira (effective 25 October 2021) but no standalone "eNaira Act" was passed by the National Assembly. Source: CBN Regulatory Guidelines on the eNaira (PDF), October 2021.

• Thailand --- A retail CBDC would be legal tender under the Currency Act B.E. 2501 (1958), but the Bank of Thailand has not invoked that authority for a full-scale launch. Thailand completed a retail CBDC pilot (Bang Khun Phrom) in 2024 under existing authority, with no specific CBDC legislation, and has since pivoted domestically toward a Programmable Payment Sandbox for stablecoin experimentation.

Outcomes: China has achieved massive pilot scale (3.48 billion cumulative transactions, CNY 16.7 trillion by November 2025) without enacted legislation, demonstrating that operational deployment is possible without formal legal authorization. However, the absence of statutory authority creates ambiguity about the e-CNY's fundamental nature — sharpened by the January 2026 reclassification toward a commercial-bank-deposit model, which PIIE analysts argued may mean the redesigned e-CNY "may no longer qualify as a CBDC." Nigeria's experience was far worse: the eNaira launched without a clear value proposition or legislative mandate, contributing to 98.5% wallet inactivity (IMF WP/23/104). Thailand concluded that its retail pilot offered insufficient incremental benefit over PromptPay and declined to invoke its legal-tender authority.

Assessment: This model carries the highest legal risk. It can enable rapid deployment but creates a "legal vacuum" (as China's own NPC acknowledged) that undermines institutional clarity. The IMF's CBDC Handbook (Policy Paper 2025/041, Chapter on Key Legal Considerations) identifies clear legal authority as a prerequisite for sustainable CBDC programmes.

Model D: Legislative / Executive Prohibition

Approach: Enacting executive orders or legislation that explicitly prohibit CBDC development, issuance, or promotion by government agencies.

Jurisdictions using this model:

• United States --- Executive Order 14178 (23 January 2025) prohibited all federal agencies from establishing, issuing, or promoting CBDCs and revoked the prior EO 14067. This executive order is the only binding prohibition currently in force. Statutory bans have advanced but have not been enacted: the Anti-CBDC Surveillance State Act (H.R. 1919) passed the House 219-210 on 17 July 2025 but did not become law; the anti-CBDC title was stripped from the final FY2026 NDAA in December 2025; and the "21st Century ROAD to Housing Act" CBDC moratorium (through 31 December 2030) passed the Senate 89-10 on 12 March 2026 and passed the House in amended form 396-13 on 20 May 2026, but the two versions remain unreconciled and the moratorium is not yet law. Kevin Warsh was sworn in as Federal Reserve Chair on 22 May 2026 (Senate confirmed 54-45) and reaffirmed his opposition to a retail CBDC. Sources: EO 14178 --- White House; H.R. 1919 --- Congress.gov; CRS --- Central Bank Digital Currencies.

• U.S. state-level legislation --- Florida enacted a law banning any CBDC (domestic or foreign) from being used as money within the state. Louisiana passed a resolution urging Congress not to support CBDC legislation. Source: Decrypt --- DeSantis Banned CBDCs in Florida, 2023.

Outcomes: The U.S. is the only major economy to formally bar CBDC development via executive action. While statutory bans have repeatedly cleared at least one chamber, none has been reconciled into enacted law; the operative legal instrument remains EO 14178. The GENIUS Act --- enacted 18 July 2025 as Public Law 119-27 (originating as S. 1582) --- positions regulated stablecoins as the preferred digital dollar infrastructure.

Assessment: Prohibition is a legitimate policy outcome. It reflects genuine privacy and surveillance concerns processed through executive and democratic accountability. Two caveats matter for accuracy: the prohibition rests on an executive order, not a statute (the statutory moratorium having passed both chambers only in differing, unreconciled forms); and the strategic risk is that, as 130+ countries explore CBDCs and China's e-CNY scales, the U.S. may lose CBDC design expertise and face competitive pressure in cross-border settlement.

Model E: Consultation-and-Design Phase (No Legislative Action Yet)

Approach: Extended multi-year research, consultation, and design work without committing to legislation until the policy case is fully established.

Jurisdictions using this model:

• UK --- The Bank of England and HM Treasury published a joint consultation in February 2023 (50,000+ responses) and entered a formal design phase in January 2024. The Government committed to requiring primary legislation before any launch, and Parliamentary scrutiny was sceptical (the House of Lords called CBDCs "a solution in search of a problem"). No draft digital-pound legislation is before Parliament. A decision on whether to proceed is expected later in 2026. Sources: BoE Consultation Paper, February 2023; Treasury Committee Report, December 2023.

• Sweden --- The Riksbank launched its e-Krona investigation in 2017 --- the longest-running CBDC research programme globally --- and concluded a four-phase technical pilot (R3 Corda) in 2024. The Payments Investigation (SOU 2023:16) concluded there was insufficient societal need for an e-Krona, and the Sveriges Riksbank Act 2022 (SFS 2022:1568) did not authorise issuance. The Riksbank's 2026 Payments Report recommends a formal parliamentary inquiry into e-krona legislation, conditioned on the EU's digital euro Regulation being finalised and the ECB deciding to issue. Source: SOU 2023:16 English Summary, March 2023.

• Japan --- The Bank of Japan has run an extended PoC-and-pilot programme but issued no CBDC and made no formal commitment; it maintains it has "no plan to issue a CBDC." Legal tender status would require amendments to the Bank of Japan Act (Act No. 89 of 1997) and, per a MOF Expert Panel (December 2023), the Criminal Code and Civil Code; no Diet bill has been introduced. A February 2026 reorganization (consolidated Discussion Groups, expansion to wholesale CBDC and tokenization) signalled a shift from exploratory toward implementation-focused work, with a retail-CBDC decision expected in 2026.

• Canada --- The Bank of Canada formally scaled down retail CBDC work in September 2024 ("not currently a compelling case"). No CBDC authority exists: both the Bank of Canada Act (s.25, physical notes only) and the Currency Act would require legislative amendment to issue a CBDC. The Stablecoin Act (Bill C-15) received Royal Assent on 26 March 2026 but is not yet in force and expressly excludes CBDCs. Wholesale experimentation continues (Project Samara, completed 5 March 2026).

Outcomes: The UK and Canada models provide strong democratic legitimacy through legislative scrutiny and have produced robust privacy and non-programmability commitments. Sweden's model has generated nine years of technical knowledge across four pilot phases, and Japan's methodical PoC-to-pilot sequence has accumulated deep design expertise. None has produced a launched CBDC.

Assessment: This model is appropriate when the policy case is genuinely unclear. The risk is indefinite delay: the UK, Sweden, Japan, and Canada all risk being overtaken by the EU's digital euro or by private stablecoins, leaving them without a sovereign digital alternative if circumstances change.

Model F: Existing Authority plus Crypto-Asset Framework

Approach: The central bank operates its CBDC programme under existing monetary authority while simultaneously building a broader digital asset regulatory framework that encompasses the CBDC ecosystem.

Jurisdictions using this model:

• Brazil --- The BCB derives Drex authority from its constitutional monetary mandate, Law No. 4,595/1964 (central bank establishment), Law No. 12,865/2013 (payment arrangements), Law 14,478/2022 (the virtual-assets framework), Decree No. 11,563/2023, and BCB Resolution No. 315/2023 (which governs the pilot). No standalone CBDC Act exists; opposition Bill 3341/2024 would require congressional approval for a state digital currency. In parallel, BCB Resolutions 519-521 (November 2025, effective 2 February 2026) operationalized the VASP/stablecoin framework. Source: Global Legal Insights --- Brazil Blockchain 2026, 2026.

• South Korea --- The Bank of Korea runs Project Hangang, a wholesale-CBDC-backed deposit-token model that the BOK explicitly describes as "an intermediate stage between a CBDC and stablecoins" rather than a full retail CBDC. It is not legal tender; the Virtual Asset Users Protection Act (Act No. 19563) excludes BOK-issued digital currency from "virtual assets," and a formal CBDC would likely require amendment of the Bank of Korea Act (Act No. 17799). The Digital Asset Basic Act remains pending (pushed to H2 2026).

• South Africa --- The SARB has no CBDC-authorizing law; it operates under the SARB Act, 1989, the Constitution (s.225), and the National Payment System Act, 1998, and any CBDC would require legislative amendment. Its November 2025 Position Paper concluded a retail CBDC is technically feasible but has "no compelling immediate need," while wholesale exploration continues under Project Khokha 2x alongside work on bank-issued stablecoins.

Outcomes: These jurisdictions integrate (potential) CBDC work into a comprehensive digital finance regulatory architecture. However, Brazil's Drex was repeatedly delayed by privacy challenges, and the November 2025 decommissioning of its Hyperledger Besu platform demonstrates that regulatory breadth does not guarantee technical readiness. South Korea and South Africa show the same model can also produce a deliberate decision to pursue wholesale/deposit-token designs instead of a full retail CBDC.

Assessment: This model is suitable for jurisdictions where the CBDC is part of a broader digital asset transformation strategy. It requires sophisticated regulatory coordination across multiple instruments.

Summary: Legislative Model Selection

Two of the 20 jurisdictions sit outside these six models in their current posture. Australia assessed and shelved a retail CBDC (no public-interest case, September 2024) and pursues wholesale experimentation under existing Reserve Bank Act 1959 authority; a retail CBDC would likely require a Currency Act 1965 amendment. Singapore operates a live wholesale CBDC under the MAS Act and Currency Act 1967 with no CBDC-specific statute, while retail (Project Orchid) remains research-only. Both are functionally Model-C-adjacent for wholesale work, with no legislative action for retail.

2. Comparative Analysis Table

The following table synthesizes the legal framework data across all 20 jurisdictions studied. "Legal Basis" refers to the primary legal instrument authorizing (or prohibiting) CBDC activity. "Legal Tender" indicates whether the CBDC has been formally granted legal tender status. "Dedicated CBDC Law" distinguishes jurisdictions with purpose-built CBDC legislation from those relying on amended or existing authority. "Retail / Wholesale" captures the scope. "Status" captures the current state of the legal framework and deployment as of June 2026.

Key Observations from the Comparative Table

Six of 20 jurisdictions have a launched or operationally live CBDC. These are the Bahamas (Sand Dollar), Nigeria (eNaira), Jamaica (JAM-DEX), the Eastern Caribbean (DCash --- pilot concluded, successor suspended), China (e-CNY, operational at pilot scale), and India (e₹, operational at pilot scale). One jurisdiction --- the United States --- is anti-CBDC. The remaining thirteen are in research, design, or wholesale-pilot stages.

Six of 20 jurisdictions have formally granted their CBDC legal tender status by statute or instrument. These are the Bahamas, Jamaica, Nigeria, India, Russia, and the Eastern Caribbean. Thailand's CBDC would be legal tender under the Currency Act but the central bank has not invoked that authority. The EU's legal tender status is proposed but not yet enacted.

Legal tender status does not correlate with adoption. The Bahamas, Jamaica, Nigeria, India, and Russia all have (or will have) legal tender status for their CBDCs. None has achieved meaningful retail adoption — India's e₹-R circulation actually contracted ~24% in FY2025-26. Conversely, China achieved the world's largest CBDC deployment by transaction volume without enacted legal tender legislation. This suggests legal status is a necessary foundation but plays no role in driving user demand.

The most comprehensive legislative frameworks belong to jurisdictions that have not yet launched. The EU (COM(2023) 369) and the UK (committed to primary legislation with privacy and non-programmability guarantees) have the most detailed legal frameworks under development. The jurisdictions that have actually launched --- Bahamas, Jamaica, Nigeria --- relied on narrower statutory amendments or existing authority. This reflects an inverse relationship between legislative thoroughness and deployment speed.

The prohibition model (U.S.) is unique among major economies --- and rests on an executive order, not a statute. No other G7 or G20 country has prohibited CBDC development. The binding instrument is EO 14178; the statutory moratorium passed both chambers (Senate 89-10, House 396-13) only in differing, unreconciled forms and is not yet law. This still creates a global bifurcation: 130+ countries exploring CBDCs while the world's largest economy actively bars its central bank from doing so.

3. What Works and What Doesn't

What Works

Clear legal authority established before or concurrent with pilot launch.

India's Finance Act 2022 amendment --- a single definitional change to the RBI Act --- enabled the wholesale pilot (1 November 2022) and retail pilot (1 December 2022). The amendment provided unambiguous statutory authority: the e₹ is legal tender under Section 26 of the RBI Act, a direct liability of the RBI. This legal clarity enabled ~19 participating banks and programmable welfare delivery pilots (Gujarat G-SAFAL, Andhra Pradesh DEEPAM 2.0, Puducherry PMGKAY) without legal challenges --- even as the FY2025-26 contraction shows legal clarity alone cannot guarantee sustained demand. Source: PIB --- CBDC Pilot Press Release.

Dedicated legislation that addresses the full operational framework.

The EU's COM(2023) 369 is the most comprehensive CBDC legislation drafted to date. It addresses legal tender status, holding limits, offline payment requirements, privacy architecture (dual-tier: cash-like offline, pseudonymised online), mandatory merchant acceptance with fee caps, free basic use for individuals, and a fraud detection mechanism --- all in a single regulation. The Council agreed its negotiating position in December 2025, and the European Parliament adopted amendments endorsing both online and offline functionality in February 2026. This level of legislative specificity provides certainty for all ecosystem participants. Source: EUR-Lex --- COM(2023) 369.

Legislation granting legal tender status before or at launch.

The Bahamas (Central Bank Act 2020, Sand Dollar launched October 2020) and Jamaica (Bank of Jamaica Amendment Act 2022, JAM-DEX legal tender from June 2022) both established legal tender status through primary legislation. Russia's Federal Law 340-FZ (August 2023) established the digital ruble as a "third form of the ruble," and the Eastern Caribbean conferred legal tender across eight territories via its 2020 ECCB Agreement amendments. In each case, the legal status is unambiguous. Source: Jamaica Information Service; Digital Policy Alert --- Law 340-FZ.

Legislative scrutiny as a legitimacy mechanism.

The UK's experience demonstrates that active legislative oversight --- the House of Lords Economic Affairs Committee (January 2022) calling CBDCs "a solution in search of a problem," the Treasury Select Committee (December 2023) demanding rigorous cost-benefit analysis, and the Government's agreement to enshrine privacy and non-programmability protections in legislation --- has strengthened the digital pound's institutional credibility even though no launch decision has been taken. Canada's September 2024 scale-down and South Africa's November 2025 Position Paper show the same mechanism producing well-reasoned decisions not to issue. Source: Treasury Committee Report.

What Doesn't Work

Launching without an adequate legal framework.

Nigeria's eNaira launched on 25 October 2021 under existing CBN statutory authority without a standalone CBDC Act. The CBN then attempted to use coercive measures (December 2022 cash withdrawal limits and naira redesign) to force digital adoption. The result: 98.5% of wallets were inactive after one year (IMF WP/23/104), a severe liquidity crisis, public protests, and bank attacks. A CBN official acknowledged at the Cedi @ 60 Conference (November 2025) that "Nigerians were not interested in the eNaira," and the CBN is shifting to wholesale CBDC focus while exploring a private stablecoin (cNGN). Sources: IMF --- Nigeria's eNaira, One Year After (WP/23/104); Carnegie Endowment --- Nigeria's Naira Redesign.

Political prohibition without alternative strategy for central bank money.

The United States has moved from cautious exploration (Biden-era EO 14067, March 2022) to prohibition (Trump-era EO 14178, January 2025). Statutory bans have passed both chambers — the Senate 89-10 and the House 396-13 — but only in differing, unreconciled forms, so the binding instrument remains the executive order. While the GENIUS Act (Public Law 119-27, July 2025) establishes regulated stablecoins as the preferred digital dollar infrastructure, this creates a structural dependency on private issuers for digital dollar provision. The IMF has noted the U.S. is the only major nation to formally bar CBDC development. Source: CRS --- Central Bank Digital Currencies, updated December 2025.

Piloting at massive scale without statutory authority.

China's e-CNY has processed CNY 16.7 trillion (~USD 2.37 trillion) across 3.48 billion transactions without enacted legislation. The draft PBOC Law amendment (October 2020) remains pending. The reclassification effective 1 January 2026 --- shifting verified e-CNY wallets toward a commercial-bank-deposit model with 0.05% interest --- was a fundamental change to the e-CNY's nature, accomplished through an administrative "Action Plan" rather than legislation. PIIE analysts argued the redesigned e-CNY "may no longer qualify as a CBDC." NPC representatives have called for legislation to fill the "legal vacuum." Sources: PIIE --- China Gives Up on State-Backed Digital Cash.

Mandatory adoption timelines without public demand.

Russia's phased mandatory adoption schedule (systemically important banks and retailers above RUB 120M revenue from September 2026) provides implementation certainty but faces a fundamental demand problem. Over 50% of Russians are unwilling to use the digital ruble for daily transactions, roughly 50% view it as a surveillance tool, and only ~30% intend to use it despite high awareness (media-sourced polling, indicative only). The gap between mandatory supply-side adoption and voluntary demand-side adoption is a core tension that legislation alone cannot resolve. Source: CBDC News EU --- State-Driven Push Meets Public Skepticism, 2025.

Legal framework exists but the technology fails to meet legal requirements.

Brazil's Drex had a clear regulatory foundation (BCB Resolution 315/2023, constitutional monetary mandate, Decree 11,563/2023) but the technology failed to satisfy the privacy requirements it was subject to. After Phase 1 and Phase 2 testing, the BCB concluded that the privacy solutions tested on Hyperledger Besu had not demonstrated the maturity needed to comply with banking secrecy and LGPD obligations. The BCB decommissioned the Hyperledger Besu platform on 4 November 2025 and is rebuilding "from scratch" (technology TBD), narrowing Phase 3 scope to collateral/lien reconciliation. A sound legal framework did not guarantee technical feasibility. Source: Ledger Insights --- Brazil's DREX CBDC Project Pivots Away from Blockchain, August 2025.

Authorizing a CBDC and then suspending it.

The Eastern Caribbean conferred full legal tender on digital currency across eight territories via its 2020 ECCB Agreement amendments, then ran the world's first multi-national CBDC pilot (DCash, March 2021–January 2024). Despite the strongest possible legal footing, the ECCB Monetary Council suspended DCash 2.0 development on 13 February 2026 in favour of a conventional Fast Payment System and CARICOM (CAPS) integration. Legal authorization, even cross-border, does not by itself sustain a CBDC against a stronger conventional-rails alternative.

Mixed Results

Pilot-first, legislate-later (China).

China's approach enabled the world's largest CBDC experiment by scale, but it created a legal vacuum with real consequences. The 1 January 2026 reclassification --- shifting verified e-CNY wallets toward commercial bank deposit liabilities with interest --- was a fundamental architectural change implemented without legislative authorization. This undermines the definitional clarity of the instrument and raises questions about whether future changes will also bypass legislative scrutiny.

Central bank authority without comprehensive regulation (India, Brazil).

India's targeted RBI Act amendment provided sufficient legal authority for pilot launch, but more than three years later the regulatory framework remains incomplete: no standalone CBDC regulation, no published privacy thresholds, no formal third-party intermediary licensing framework --- and FY2025-26 brought the first reported year-on-year circulation contraction (~24%). Brazil's BCB Resolution 315/2023 governs the Drex pilot, but comprehensive Drex-specific legislation has not been enacted, and the November 2025 platform decommissioning demonstrated that regulatory authorization alone does not guarantee technical viability.

4. Recommended Framework

Based on comparative analysis of 20 jurisdictions and the IMF's CBDC Virtual Handbook, the following framework is recommended for regulators designing CBDC legal frameworks. Every recommendation is supported by country evidence.

4.1 Essential Legal Provisions

Provision 1: Explicit Legal Tender Status

The CBDC must have unambiguous legal tender status established in primary legislation. This determines whether payees are legally required to accept it and whether it constitutes final discharge of a payment obligation.

• Evidence for: Jamaica (Bank of Jamaica Amendment Act 2022) --- first country to designate CBDC as legal tender by statute. India (Section 26 RBI Act) --- e₹ has legal tender status identical to physical banknotes.
• Evidence against: China --- e-CNY lacks enacted legal tender status, creating the "legal vacuum" acknowledged by NPC representatives. Sweden's Payments Investigation (SOU 2023:16) concluded legal tender definitions need modernization before any CBDC issuance.
• IMF guidance: Policy Paper 2025/041 identifies "key legal considerations" as one of the Handbook chapters, emphasizing the importance of resolving legal status before issuance.

Provision 2: Central Bank Mandate and Authority

Legislation must explicitly authorize the central bank to issue, manage, and operate (or oversee operation of) the CBDC. The central bank's mandate should cover issuance and redemption, technical standards, intermediary oversight, AML/CFT coordination, and smart contract governance.

• Evidence for: India (RBI Act amendment, Section 22A) --- grants the RBI flexibility to design a distinct framework for digital currency. EU (COM(2023) 369) --- ECB authority derives from Art. 128 TFEU read with Art. 127 TFEU.
• Evidence against: Nigeria --- the CBN operated under existing authority (Section 19 CBN Act) without a clear CBDC-specific mandate; the eNaira failed to achieve adoption partly because the CBN "was not prepared to function as a retail bank" (CBN official, November 2025). Canada --- the Bank of Canada Act (s.25, physical notes only) would have to be amended before any issuance.

Provision 3: Privacy Safeguards Enshrined in Law

Legislation must define what personal data the central bank, intermediaries, and law enforcement may access, under what circumstances, and subject to what oversight. Privacy commitments in policy documents or white papers are insufficient.

• Evidence for: UK --- the Government agreed to enshrine privacy protections in primary legislation. The EU's COM(2023) 369 integrates GDPR compliance, the EDPB-EDPS Joint Opinion 02/2023 recommended a low-value privacy threshold, and the offline modality provides cash-like privacy.
• Evidence against: China --- the "controllable anonymity" framework is described in PBOC policy documents but is not codified in enacted legislation. Russia --- explicitly non-anonymous by design, rated "Very Weak." Nigeria --- Cambridge University analysis found the eNaira guidelines "allow monitoring and tracking of users." South Korea --- BOK Governor Rhee acknowledged the design "chose to improve compliance at the sacrifice of privacy."
• IMF guidance: Fintech Note 2024/004 ("CBDC Data Use and Privacy Protection") recommends data minimization, separation of identity data from transaction data, tiered privacy models, and legislated data access rights and retention periods.

Provision 4: Holding Limits

Legislation should authorize the setting of individual holding limits to prevent excessive deposit outflows from commercial banks, with a transparent mechanism for adjustment based on observed data.

• Evidence for: EU (COM(2023) 369) --- modelled at EUR 3,000 per person; the Council's December 2025 position provides for an ECB-set limit within a Council-agreed ceiling reviewed at least every two years; waterfall/reverse-waterfall mechanisms handle excess amounts. UK (BoE Financial Stability Paper No. 53, November 2025) --- modelled GBP 10,000-20,000 with detailed deposit-flight analysis. China --- tiered wallet caps (Category 4: CNY 10,000; Category 1: CNY 500,000). Russia --- a RUB 300,000 monthly top-up limit framed as a bank-disintermediation safeguard.
• IMF guidance: Fintech Note 2025/008 ("Evaluating the Implications of CBDC for Financial Stability") provides a framework for calibrating holding limits based on financial stability analysis.

Provision 5: Non-Programmability by Government Guarantee

Legislation should prohibit the central bank and government from programming spending restrictions on general-purpose CBDC holdings. Private-sector programmability with user consent may be permitted separately.

• Evidence for: UK --- the Government committed in writing that neither the BoE nor the Government would be able to program the digital pound or restrict spending; this will be enshrined in primary legislation (a Parliamentary petition received 31,476 signatures). EU --- the digital euro "would never be programmable money"; conditional payments are permitted only as PSP value-added services off the core ledger.
• Evidence against: Russia --- the digital ruble supports "coloured funds" via smart contracts that can restrict what money is spent on (17,000+ smart contracts in the pilot), combined with full de-anonymisation. South Korea --- programmable subsidy restrictions raise surveillance concerns over beneficiary spending.
• Important nuance: India's programmable e₹ for welfare delivery (G-SAFAL, DEEPAM 2.0, PMGKAY) represents a distinct case where purpose-bound tokens are issued specifically for welfare programmes, not applied as restrictions on general-purpose CBDC holdings.

Provision 6: Intermediary Licensing and Obligations

Legislation should establish a clear framework for who can distribute the CBDC, what obligations they bear (KYC/AML, data protection, service availability), and what compensation they receive.

• Evidence for: EU (COM(2023) 369) --- mandates credit institutions, payment institutions, and e-money institutions to distribute the digital euro; public entities can distribute to unbanked users; fee caps protect merchants. Bahamas --- licensed AFIs (banks, credit unions, MTBs, PSPs) distribute under the Central Bank Act, with AFIs increased to 10 firms in 2025.
• Evidence against: Jamaica --- distribution was bottlenecked, with only two public-facing wallets (Lynk, JN Pay) by end-2025. India --- no formal third-party licensing framework published as of June 2026.

4.2 Tiered Approach by Country Readiness

Not all countries need the same legislative approach. The recommended tier reflects the jurisdiction's institutional maturity, payment system development, and urgency of deployment.

Tier 1: Countries approaching issuance (need comprehensive dedicated legislation)

Applicable to jurisdictions that have completed substantial technical preparation and are moving toward launch decisions. These countries need legislation addressing legal tender status, central bank mandate, privacy, holding limits, intermediary obligations, merchant acceptance, and financial stability safeguards.

Examples: EU (COM(2023) 369 in legislative process); Russia (Federal Law 340-FZ enacted, large-scale launch mandated September 2026). Countries at this stage should study the EU model as the most comprehensive template.

Tier 2: Countries in active pilots (need central bank act amendment plus CBDC-specific secondary regulation)

Applicable to jurisdictions with live pilots but incomplete legal frameworks. The priority is formalizing the pilot's legal basis and establishing comprehensive secondary regulation covering privacy, intermediary licensing, and operational rules.

Examples: India (RBI Act amended; comprehensive CBDC regulation still needed); China (draft PBOC Law amendment should be enacted to resolve the legal vacuum); Brazil (needs comprehensive Drex-specific regulation beyond BCB Resolution 315/2023); South Korea (would likely require Bank of Korea Act amendment for a formal CBDC).

Tier 3: Countries in design/research phase (need enabling legislation that preserves optionality)

Applicable to jurisdictions still evaluating whether to issue. Legislation should modernize legal tender definitions to accommodate digital forms, clarify the central bank's research mandate, and establish privacy and financial stability principles that will apply if issuance proceeds.

Examples: UK (should introduce enabling legislation defining the digital pound's legal status and privacy framework before any build decision); Sweden, Japan, and Canada (each needs legislative modernization of the legal tender concept and an explicit research mandate before any issuance).

Tier 4: Countries that have decided against (or de-prioritized) a retail CBDC (need clear alternative digital money framework)

Applicable to jurisdictions that have concluded a retail CBDC is not appropriate in the near term. Legislation should ensure adequate regulation of private digital money (stablecoins, tokenized deposits) and protect access to physical cash, while preserving central bank research capacity.

Examples: United States (GENIUS Act provides a stablecoin framework; cash access preserved); South Africa (November 2025 Position Paper found "no compelling immediate need," prioritizing PayShap and NPS expansion); Australia (retail shelved for lack of public-interest case, wholesale pursued); Canada (retail scaled down, Stablecoin Act enacted but excludes CBDCs).

4.3 International Framework Alignment

All jurisdictions should align their CBDC legal frameworks with:

• IMF CBDC Virtual Handbook (Policy Papers 2023/048, 2024/052, 2025/041) --- the most authoritative international guidance framework, covering monetary policy, financial stability, privacy, financial inclusion, and cross-border dimensions.
• BIS CPMI-IOSCO Principles for Financial Market Infrastructures --- applicable to CBDC as systemically important payment infrastructure.
• FATF Guidance on Virtual Assets and VASPs --- for AML/CFT compliance of CBDC intermediaries.
• GDPR / equivalent data protection standards --- the EU's approach (GDPR compliance by design, EDPB-EDPS oversight) should be the minimum standard for privacy protection.

5. Decision Matrix

This matrix provides actionable guidance for policymakers based on their jurisdiction's characteristics.

If your country has an advanced existing digital payment system (e.g., UPI, Pix, Swish, PromptPay, PayShap)

Consider: A wholesale-focused CBDC or a cautious retail CBDC with clear differentiation from existing payment rails.

Because: India's e₹ faces the "UPI problem" --- roughly 7-8 million users in a country of 1.45 billion after three years, with circulation contracting ~24% in FY2025-26, because UPI already provides fast, free, ubiquitous digital payments. Brazil's Drex was forced to pivot because Pix (150M+ users) already handles retail payments. Thailand's BOT concluded its retail pilot offered insufficient incremental benefit over PromptPay. Sweden's SOU 2023:16 found insufficient need given card and Swish dominance, and South Africa's SARB pointed to PayShap.

Action: Conduct a rigorous assessment of what the CBDC adds beyond existing payment rails. If the answer is "not much for retail," consider wholesale CBDC for tokenized settlement (as Singapore, Australia, and South Africa have done) or a targeted retail deployment for specific use cases (offline payments, welfare delivery, disaster resilience).

If your country has a large unbanked population

Consider: A retail CBDC with tiered KYC (low-barrier basic wallets), offline capability, and agent network distribution.

Because: India's basic wallets (phone number only) and offline NFC capability (launched October 2025) directly address rural connectivity gaps. The Bahamas' Tier 1 wallet (minimal ID, B$500 limit) targets unbanked populations on Family Islands. China's Category 4 wallet (phone number only, CNY 10,000 cap) achieved the largest low-barrier CBDC deployment globally. Ghana's offline-first eCedi design explicitly targets the ~47% of Ghanaians lacking internet access.

Action: Prioritize offline payment capability and feature-phone compatibility. India's NFC tap-and-pay solution and the Bahamas' pre-authorized offline transactions provide design models. The IMF's WP/23/069 ("Central Bank Digital Currency and Financial Inclusion") provides quantitative analysis of how CBDC features affect adoption among underserved populations.

If your country has strong data protection traditions (e.g., EU member state, UK)

Consider: A dual-tier privacy architecture with cash-like offline and pseudonymised online, legislated privacy guarantees, and independent data protection oversight.

Because: The EU's digital euro design --- where the Eurosystem cannot identify individual users for online transactions and offline transactions provide cash-like privacy --- represents the most sophisticated privacy architecture among CBDC projects. The EDPB-EDPS Joint Opinion 02/2023 recommended a low-value privacy threshold. The UK Government committed to enshrine privacy protections in primary legislation following the Treasury Committee's insistence.

Action: Adopt the EU's dual-tier model as a baseline. Legislate specific data access restrictions, retention limits, and purpose limitations. Invest in privacy-enhancing technologies (the BoE-MIT DCI collaboration on pseudonymization, zero-knowledge proofs, and secure multiparty computing provides a research model). Consult your data protection authority early.

If your country is considering CBDC for sanctions avoidance or geopolitical purposes

Consider: The evidence shows this objective is largely unrealized.

Because: Russia's BRICS Bridge initiative remained largely conceptual as of mid-2026. The BIS withdrew from Project mBridge in October 2024 amid concerns about sanctions circumvention. India's April 2026 proposal to interconnect BRICS members' existing CBDCs is a proposal, not an agreed scheme, and does not specifically name the digital ruble. Carnegie Endowment analysis concluded the digital ruble is "not a panacea for circumventing sanctions" because counterparties in third countries still risk secondary sanctions. Sources: Carnegie Endowment --- Digital Ruble; Foreign Policy --- Russia's Plans to Replace the Dollar.

Action: Do not design a CBDC primarily for sanctions avoidance. Cross-border CBDC infrastructure requires willing counterparties and interoperability agreements that are difficult to achieve unilaterally.

If your country has weak institutional trust or high corruption perceptions

Consider: Prioritizing privacy protections, judicial oversight of data access, and voluntary (not coercive) adoption strategies.

Because: Nigeria's experience is the definitive cautionary tale. The CBN launched the eNaira, then attempted to force adoption through cash withdrawal limits. The result was public backlash, bank attacks, and 98.5% wallet inactivity. Brazil's civil society raised similar surveillance concerns about Drex (Federal Deputy Zanatta, Bill 3341/2024). Russia's explicitly non-anonymous design, combined with smart-contract spending restrictions, has produced 50%+ public unwillingness to use the digital ruble.

Action: Coercive adoption strategies destroy trust. Build in judicial oversight for law enforcement data access. Provide genuine anonymity for low-value transactions. Establish an independent oversight body. The IMF's Fintech Note 2024/004 provides the framework for balancing data use with privacy protection.

If your country is a small island developing state (SIDS)

Consider: A focused retail CBDC with offline capability and disaster resilience as primary design goals.

Because: The Bahamas' Sand Dollar was specifically designed for hurricane resilience --- offline transactions can occur when inter-island communication is disrupted. Hurricane Dorian (September 2019) destroyed bank branches and left thousands unable to access money. Jamaica's JAM-DEX similarly targets financial access across dispersed geography. The Eastern Caribbean's DCash, however, had no offline capability in version 1.0 --- a key vulnerability exposed by its ~56-day 2022 outage, and a requirement for the now-suspended DCash 2.0.

Action: Prioritize offline capability and disaster resilience over programmability or cross-border features. However, learn from these countries' adoption challenges: the Sand Dollar represents only ~0.4% of physical cash; JAM-DEX has ~2,379 registered merchants; and DCash 2.0 was suspended in February 2026. Mandate commercial bank integration (as the Bahamas announced in July 2024) and ensure multiple wallet providers from launch (Jamaica's single-provider bottleneck hindered adoption for years).

If your parliament is skeptical of CBDC

Consider: A transparent design phase with robust legislative engagement, clear decision criteria, and an explicit "no-go" option.

Because: The UK model shows that legislative skepticism can be constructive. The House of Lords called CBDCs "a solution in search of a problem" (January 2022). The Treasury Committee insisted the design phase "must not be viewed as an inevitable consequence" of launching (December 2023). These challenges forced clearer articulation of the policy case and stronger privacy commitments. South Africa and Canada similarly reached well-documented decisions to de-prioritize a retail CBDC.

Action: Invite legislative review early. Publish consultation papers and respond to feedback transparently. Commit to a formal cost-benefit analysis before any build decision. Establish clear criteria for deciding whether to proceed. A "no decision" is a legitimate and credible outcome.

If your country wants to use CBDC for programmable welfare delivery

Consider: A purpose-bound token model where programmable restrictions apply only to specific welfare disbursement tokens, not to general-purpose CBDC holdings.

Because: India has deployed the most advanced programmable welfare CBDC globally. The Gujarat G-SAFAL programme distributes livelihood assistance as programmable e₹ tokens spendable only on approved agricultural inputs. The Andhra Pradesh DEEPAM 2.0 programme distributes LPG subsidies as conditional tokens. The Puducherry PMGKAY pilot (launched 26 February 2026, Canara Bank) distributes food grain entitlements as programmable CBDC tokens, targeting 800 million (80 crore) beneficiaries nationwide. South Korea's Phase 2 deposit-token treasury pilot (EV-charging subsidies) is a parallel model. These solve genuine problems: subsidy leakage, corruption, and authentication failures in existing distribution systems. Sources: PIB --- PMGKAY CBDC Pilot; CoinGeek --- India CBDC.

Action: Legislate a clear distinction between general-purpose CBDC (no government programmability) and purpose-bound welfare tokens (programmable by the issuing authority for specific disbursement programmes). Require transparent criteria for when purpose-bound restrictions apply. This prevents the legitimate tool of programmable welfare delivery from becoming a precedent for broad government spending control.

If your country is a eurozone member or closely integrated with the EU

Consider: Participating in the digital euro framework rather than developing a standalone national CBDC.

Because: The EU's COM(2023) 369 establishes a pan-eurozone framework covering 20 member states. The ECB's preparation phase concluded in October 2025, selected EU-controlled service providers (framework agreements estimated at EUR 432.1 million, potential maximum EUR 1.164 billion), and opened a PSP pilot call on 5 March 2026 (12-month pilot in H2 2027). Six national central banks are developing core settlement components internally. The digital euro scheme rulebook (v0.9, July 2025) provides the operational standard. Source: ECB --- Selected Service Providers, October 2025.

Action: For eurozone members, focus legislative effort on implementing the Digital Euro Regulation once adopted, rather than developing parallel national CBDC programmes. For non-euro EU members (Sweden, Denmark, Poland, etc.), assess whether a bilateral agreement with the ECB (enabled by COM(2023) 368) or a national CBDC better serves monetary sovereignty objectives. Sweden's Riksbank has explicitly acknowledged that the digital euro's trajectory will determine the e-Krona's future.

6. Key Takeaways for Legislative Drafters

Drawing from the full comparative analysis of 20 jurisdictions, the following principles should guide CBDC legislative drafting:

1. Legislate before you launch, not after. China's "legal vacuum" and Nigeria's regulatory-guideline-only approach demonstrate the risks of deploying before the legal framework is established. India's targeted amendment and the EU's comprehensive regulation represent the two viable approaches --- both establish legal authority before or concurrent with deployment.

2. Legal tender status matters but does not guarantee adoption. Of the 20 jurisdictions, six have formally granted legal tender status (Bahamas, Jamaica, Nigeria, India, Russia, Eastern Caribbean). Jamaica was the first by statute, yet JAM-DEX still has ~2,379 registered merchants and ~0.1% of currency in circulation. The Bahamas' Sand Dollar has legal tender status and represents ~0.4% of physical cash. India's e₹ has legal tender status and still contracted ~24% in FY2025-26. Legal tender status is necessary but far from sufficient.

3. Privacy must be legislated, not just designed. Technical privacy measures (encryption, pseudonymization, offline protocols) are necessary but insufficient. The UK Treasury Committee warned that the Bank and Government "may in future be tempted to try to make use of such a powerful source of information." Only statutory protections with independent oversight provide credible guarantees. The EU's approach (GDPR compliance, EDPB-EDPS oversight, dual-tier privacy) and the UK's commitment to legislated privacy protections represent the strongest frameworks; Russia's non-anonymous design and South Korea's "compliance over privacy" choice illustrate the opposite.

4. The IMF framework should be the starting point, not an afterthought. The IMF's CBDC Virtual Handbook (three policy papers, 10+ Fintech Notes, ~20 planned chapters) provides the most structured analytical framework available. Its coverage of monetary policy transmission, financial stability, privacy, financial inclusion, and cross-border dimensions should inform every legislative drafting process.

5. A decision not to issue --- or to bar issuance --- is a legitimate policy outcome. The United States bars federal CBDC development by executive order (EO 14178), with statutory moratoria having passed both chambers only in differing, unreconciled forms. South Africa concluded there was "no compelling immediate need" for a retail CBDC (November 2025). Sweden's Payments Investigation found insufficient societal need. Canada scaled down retail work and Australia shelved it. Other jurisdictions should not assume CBDC issuance is inevitable; a well-reasoned decision not to issue is preferable to a poorly designed launch --- and, where prohibition is chosen, drafters should note whether it rests on executive action or enacted statute, as these differ in durability.

6. Mandatory bank integration may be necessary. Voluntary bank participation has proven insufficient in every launched CBDC. The Bahamas announced mandatory bank integration in July 2024, four years after launch. Jamaica's outgoing BOJ Governor called slow JAM-DEX adoption "a disappointment" (May 2026) and pushed banks toward POS integration. Russia has imposed a mandatory adoption timeline (from September 2026). The EU's COM(2023) 369 mandates PSP distribution. Legislators should consider whether mandatory intermediary participation is needed from the outset.

7. Stablecoin regulation and CBDC legislation should be coordinated. Brazil's parallel VASP/stablecoin framework (Resolutions 519-521) alongside Drex demonstrates holistic regulatory architecture. The EU's positioning of the digital euro alongside MiCA-regulated stablecoins provides a coherent framework. The U.S. GENIUS Act (Public Law 119-27), Canada's Stablecoin Act (Royal Assent March 2026), and Nigeria's exploration of a cNGN stablecoin all position stablecoins explicitly relative to CBDC. Jurisdictions should avoid regulating CBDCs in isolation from the broader digital money landscape.

8. Financial stability analysis should precede legislative commitments. The UK's Financial Stability Paper No. 53 (November 2025) modelled deposit-outflow scenarios at various holding limits. The Council's December 2025 digital euro position provides for an ECB-set holding limit within a Council-agreed ceiling, reviewed at least every two years. Russia's RUB 300,000 monthly top-up limit is explicitly framed as a bank-disintermediation safeguard. These analyses should inform legislative calibration of holding limits and transition safeguards. Jurisdictions that skip financial stability analysis risk provisions that either unduly constrain CBDC utility (limits too low) or threaten banking system stability (limits too high).

Verification Notes

This document synthesizes data exclusively from the verified per-jurisdiction fact matrix for all 20 CBDC jurisdictions in this domain. All legal citations, dates, and source URLs are drawn from that matrix and the underlying country files, where they were previously verified during research. Adoption and transaction figures are self-reported by issuing central banks unless otherwise noted and should be treated accordingly. The following limitations apply:

1. EU legislative timeline beyond the 23 June 2026 ECON vote is dependent on European Parliament and trilogue dynamics; the 2026-adoption / 2029-issuance sequence is an ECB working assumption, not a fixed schedule.
2. U.S. legislative trajectory: The only binding prohibition is EO 14178. The "ROAD to Housing" CBDC moratorium passed the Senate (89-10, 12 March 2026) and the House in amended form (396-13, 20 May 2026) but the two versions remain unreconciled and not enacted. The GENIUS Act is enacted (Public Law 119-27, originating as S. 1582). Kevin Warsh was sworn in as Fed Chair on 22 May 2026.
3. China's draft PBOC Law status: Multiple sources confirm the 2020 draft (Arts. 19, 22, 65) has not been enacted. The 1 January 2026 reclassification toward a deposit-money model was effected by an administrative Action Plan, not legislation; the full list of the 22 authorized operators (after +12 banks on 2 April 2026) is NOT FULLY VERIFIED.
4. India's circulation figure: e₹-R in circulation of ₹771.7 crore at 31 March 2026 (down ~24% YoY) is self-reported by the RBI Annual Report 2025-26 and flagged as such.
5. Brazil's Drex: The Hyperledger Besu platform was decommissioned on 4 November 2025 and the project is rebuilding "from scratch" with technology TBD; the Phase 2 final report's publication is NOT VERIFIED.
6. Eastern Caribbean: DCash 2.0 development was suspended on 13 February 2026 (ECCB Monetary Council, 112th Meeting); the status of the Payment System and Services Act in Anguilla, Montserrat, St Kitts & Nevis, and St Vincent is NOT VERIFIED.
7. Ghana: The Governor declared the eCedi pilot "completed" on 22 May 2026 and signalled a design-phase shift to wholesale/cross-border use; enabling legislation has not been passed. The separate Virtual Asset Service Providers Bill, 2025 passed Parliament in December 2025.
8. South Africa: The SARB's definitive Position Paper (27 November 2025) found "no compelling immediate need" for a retail CBDC; work continues under Project Khokha 2x.
9. Sweden / euro area: The ECB's preparation phase concluded in October 2025, and the Governing Council moved the project to its next phase on 29-30 October 2025; Sweden's e-Krona trajectory is now conditioned on the digital euro Regulation being finalised.
10. IMF CBDC Handbook chapter publication schedule: The Handbook targets approximately twenty chapters; some chapters referenced in the November 2025 policy paper may not yet be publicly available.

All claims that could not be verified are marked as such. No URLs beyond those present in the source matrix and country files have been cited; no Wikipedia, Reddit, Quora, X/Twitter, or Medium sources are used. Policymakers should independently verify legislative status before relying on any specific provision cited herein, as CBDC legal frameworks are evolving rapidly across all jurisdictions.

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Last updated: 2026-06-04