CBDCs in 2026: 146 Countries Exploring, Only 3 Launched

The direct answer to the question this report examines is that the pilots have demonstrated three things, and not the three their sponsors advertised. First, retail central bank digital currencies have struggled to find users wherever a good private or public alternative already exists: in Nigeria, 98.5% of eNaira wallets sat unused in any given week a year after launch [2] ✓ Established, and Jamaica’s JAM-DEX amounted to about 0.09% of currency in circulation in mid-2026 [3] ✓ Established. Second, the financial-inclusion gains that CBDCs promised have been delivered instead by fast payment systems and mobile money — Brazil’s Pix, India’s UPI and Kenya’s M-Pesa — none of which is a central bank digital currency [4] [5] [6] ◈ Strong Evidence. Third, China’s e-CNY has demonstrated that a state can build a payment instrument whose visibility to the authorities is graded by design, with small payments shielded and larger ones traceable, and with features such as expiry dates already used in live pilots [7] [8] ✓ Established. The surveillance question is therefore not hypothetical. It is a question of design and law, and the democracies now writing that law are making visibly different choices.

The scale of official interest is not in doubt. The Atlantic Council’s tracker counted 146 jurisdictions exploring a CBDC in May 2026, of which 77 had reached an advanced stage of development, pilot or launch — a new high — while just 41 were running pilots and three had launched [1] ✓ Established. In July 2025 the same tracker had counted 137 jurisdictions and 49 pilots, up from 35 jurisdictions exploring the idea in 2020 [9] ✓ Established. The fall in the pilot count between those two dates is not explained in the public data and may reflect reclassification rather than abandonment ⚖ Contested. The Bank for International Settlements reaches a similar headline from the other direction: in its 2024 survey, published in August 2025, 91% of 93 responding central banks were exploring a retail or wholesale CBDC, with wholesale work — money for settlement between banks — further advanced than retail work aimed at the public [10] ✓ Established. More than one in three central banks told the BIS that the rise of stablecoins had led them to accelerate their own work [10] ✓ Established. Exploration, in other words, is near universal. Issuance to the public is rare, and where it has happened the numbers are small.

The gap between exploration and use is the first finding, and it is consistent across very different economies. The Central Bank of The Bahamas launched the Sand Dollar in October 2020 as the first nationwide retail CBDC; an IMF review found it accounted for less than 0.1% of currency in circulation [11] ✓ Established, and trade press tracking put circulation at about 2.1 million Bahamian dollars after three years, under 0.5% of cash [12] ◈ Strong Evidence. The IMF’s February 2026 Article IV statement on The Bahamas still described use as limited [13] ✓ Established. The Eastern Caribbean Central Bank ran its DCash pilot from March 2021 to January 2024 and in February 2026 suspended the relaunch, DCash 2.0, in favour of a regional fast payment system [14] ✓ Established. Canada shelved its retail CBDC in September 2024 after 85% of 89,423 consultation respondents said they would not use one [15] ✓ Established. Australia’s central bank concluded the same month that it saw no clear public interest case for a retail CBDC [16] ✓ Established. The United States went furthest, banning federal work on a CBDC by executive order in January 2025 and then by statute in 2026 [17] [18] ✓ Established.

China is the exception that defines the debate. By the end of November 2025, the e-CNY had recorded 3.48 billion transactions with a cumulative value of 16.7 trillion yuan, about 2.4 trillion US dollars, across 230 million personal wallets and 18.84 million institutional wallets [19] [20] ✓ Established. Those are large numbers in absolute terms and small ones relative to China’s payment market, as Section 2 sets out. They are also the product of a decade of state effort that began with People’s Bank of China research in 2014 [21] ✓ Established, and of policy decisions — public-sector salaries paid in e-CNY, interest payable on verified wallets from January 2026 — that have no counterpart in the smaller pilots [22] [23] ✓ Established. The e-CNY is therefore both the strongest evidence that a CBDC can operate at national scale and the clearest illustration of what a CBDC designed by a state with expansive surveillance powers looks like. It is also, through the multi-currency mBridge platform, the dominant currency in the most active cross-border CBDC experiment [19] ✓ Established.

Three claims recur in the case for CBDCs, and this report tests each against the evidence. The payments claim holds that a central bank digital currency gives the public a safe, cheap, state-backed digital means of payment as cash use declines; cash was still used in 52% of euro-area point-of-sale transactions in 2024, down from 59% in 2022, but only in about one in ten in-store purchases in Sweden [24] [25] ✓ Established. The inclusion claim holds that a CBDC can bring the unbanked into the formal financial system. The sovereignty claim, now dominant in Europe, holds that a public digital currency protects monetary autonomy against foreign card networks and private stablecoins; Visa and Mastercard carry 61% of euro-area card payments [26] ✓ Established. Against these sits the surveillance objection: that a digital currency issued and recorded by the state creates a capacity for monitoring and control of private spending that cash never offered [27] [28] ◈ Strong Evidence. The evidence from the pilots speaks to all four, and it does not fully vindicate either side.

• Payments: CBDCs work technically, but usage stays marginal where card, account-to-account or mobile money systems already exist [2] [3] [29] ✓ Established.
• Inclusion: global account ownership rose to 79% of adults by 2025, driven by mobile phones and fast payments rather than CBDCs [30] [31] ◈ Strong Evidence.
• Sovereignty: the strongest remaining argument in Europe, where 61% of card payments run on two US networks [26] ✓ Established.
• Surveillance: demonstrated as a design capacity in China, constrained by draft law in the euro area and pre-empted by statute in the United States [32] [33] [18] ◈ Strong Evidence.

The rest of this report follows that evidence. Section 2 examines what the e-CNY’s numbers actually show. Section 3 sets out how its managed anonymity works in practice and what the pilots revealed about programmability. Section 4 tests the inclusion promise against Nigeria, the Caribbean and the fast payment systems that outpaced them. Section 5 compares national trajectories from Washington to Moscow, Section 6 evaluates the safeguards now being written into European law, Section 7 sets out the genuine disagreements, and Section 8 draws the structural conclusions. The approach throughout is to separate what the pilots have demonstrated from what their advocates and critics have asserted, and to mark the difference with explicit evidence grades.

The People’s Bank of China began researching a digital currency in 2014, moved to city pilots in 2020 and has since expanded the e-CNY to most of the country’s major economic regions [21] ✓ Established. The trajectory of the headline number is steep. Deputy Governor Lu Lei told a September 2024 conference that cumulative transactions had reached 7 trillion yuan by June 2024, up from 1.8 trillion a year earlier [21] ✓ Established. By the end of November 2025 the cumulative total was 16.7 trillion yuan across 3.48 billion transactions [19] [35] ✓ Established. Wallet numbers grew too: 230 million personal wallets and 18.84 million institutional wallets by the same date [19] ✓ Established. Taken at face value, the e-CNY is by far the largest central bank digital currency ever operated, and its sponsors present it as proof of concept for the whole field.

The relative picture is more modest. When the PBoC first included e-CNY in its official cash statistics, outstanding balances at the end of 2022 were 13.61 billion yuan — 0.13% of currency in circulation and 0.005% of broad money [36] ✓ Established. No more recent official share has been published in the sources reviewed for this report. Se Ping, a former director of research at the central bank, observed in December 2022 that about 100 billion yuan had been spent in two years against 261 million wallets, while China had 903.6 million mobile payment users, and described use as extremely inactive [34] ◈ Strong Evidence. The comparison with India is instructive: the e-CNY’s 3.48 billion cumulative transactions since launch are fewer than the 21.63 billion transactions India’s UPI processed in December 2025 alone [19] [5] ✓ Established. The e-CNY is large because China is large. Its share of everyday payments remains small, and the private duopoly it was partly meant to discipline — Alipay and WeChat Pay held about 94% of third-party mobile payments in 2020, the latest market-share figure found for this report — remains in place [37] ◈ Strong Evidence.

Where the e-CNY has grown, state direction has done much of the work. In June 2022 Taicang, in Jiangsu province, began paying public-sector wages in e-CNY, and the nearby city of Changshu moved to pay all state-sector staff in the digital currency [22] ✓ Established. Local governments have distributed e-CNY in lottery-style consumption vouchers, including a 20 million yuan Shenzhen giveaway of 200-yuan envelopes in January 2021 [8] ✓ Established. Such measures put wallets on phones and money into wallets, but the evidence that they create durable habits is weak: Se Ping’s account and the persistence of the private duopoly suggest that recipients often moved money back into the platforms they already used [34] [37] ◈ Strong Evidence. The PBoC itself appears to have reached a similar conclusion, because in late 2025 it changed the nature of the instrument.

On 1 January 2026 the e-CNY became interest-bearing. Under an action plan flagged by Lu Lei in the central bank’s Financial News on 28 December 2025, commercial banks may pay interest on balances in real-name verified wallets, and those balances are covered by deposit insurance [23] [38] ✓ Established. Economically, this moves the e-CNY away from digital cash — a direct liability of the central bank that pays nothing — towards something closer to a bank deposit operated on central bank rails. Jianhua Zhang of the Tsinghua PBC School of Finance wrote that allowing operating institutions to pay interest will further increase users’ willingness to hold it [19] ◈ Strong Evidence. Analysts described it as a first for any CBDC, a claim that is plausible but not independently verified ⚖ Contested. The change also has a privacy dimension, examined in Section 3: interest is available only on wallets whose owners have verified their identity [23] ✓ Established. The incentive to hold e-CNY is now tied to the incentive to be identified.

The e-CNY’s cross-border role is growing faster than its domestic one. mBridge — a platform for wholesale CBDC settlement developed with the central banks of Hong Kong, Thailand and the United Arab Emirates — had recorded 4,047 transactions worth 387.2 billion yuan by late 2025, of which about 95.3% by value was settled in e-CNY [19] [35] ✓ Established. The BIS withdrew from the project in October 2024, and Saudi Arabia’s central bank, which joined in June 2024, left after completing a proof of concept in May 2025 [39] [40] ✓ Established. In September 2025 the PBoC opened an international operation centre for the e-CNY in Shanghai with platforms for cross-border payment, blockchain services and digital assets [41] ✓ Established. Whether this infrastructure is primarily about efficiency or about building settlement channels outside the dollar system is disputed; Section 7 returns to that question ⚖ Contested.

The e-CNY record therefore cuts both ways. It proves that a central bank can build and operate a retail digital currency for hundreds of millions of people without technical failure [19] ✓ Established. It does not prove that the public wants one: after five years of pilots, payroll mandates, giveaways and now interest, the instrument’s share of everyday payments remains small next to Alipay and WeChat Pay [34] [37] ◈ Strong Evidence. And it proves something its critics have long argued — that the design choices made in building such a system determine how much the state can see. That is the subject of the next section.

The PBoC’s July 2021 white paper set out the principle that has governed the e-CNY ever since. Wallets are graded into four levels according to how much identity information the holder provides, and the stated aim of the design is to protect personal privacy for small transactions while guarding against telecom fraud, internet gambling, money laundering and tax evasion [7] ✓ Established. The specifications published in 2021 show how the levels work. The lowest wallet, opened with only a mobile phone number, was limited to 2,000 yuan per payment, 5,000 yuan a day and a balance of 10,000 yuan; a wallet verified with a national identity document and linked to a bank account allowed 50,000 yuan per payment, 100,000 yuan a day and a balance of 500,000 yuan [43] ✓ Established. Officials summarised the rule as anonymity for small value and traceability for high value [42] [44] ✓ Established. The central bank has never claimed that the e-CNY is anonymous in the way cash is.

The lowest level is less anonymous than it sounds. Researchers at Stanford’s DigiChina project pointed out that mobile phone numbers in China have had to be registered to a real name since 2010, so even a phone-only wallet is linked to an identity held by the carrier [32] ✓ Established. Their analysis of official statements found that small transactions can be traced where they are flagged as suspicious, with police using big data analysis and then approaching carriers or banks to establish who is behind a wallet [32] ◈ Strong Evidence. The PBoC itself does not routinely see personal identity data — that sits with the commercial banks and payment operators that run wallets — but the architecture places transaction records with a small number of institutions, all of them subject to state access [32] [46] ◈ Strong Evidence. Yi Gang, then PBoC governor, described the result in October 2022 as a delicate balance between protecting privacy and combatting illicit activities, and said anonymity and full disclosure are not as simple as black and white [44] ✓ Established.

Programmability is the capability that turns a privacy question into a control question. A programmable money is one whose use can be constrained by rules attached to the money itself: where it may be spent, by when, and on what. The Shenzhen envelopes were an elementary example, with an expiry date and a merchant whitelist built into the voucher [8] ✓ Established. Legal scholars writing in Lawfare in April 2025 argued that the e-CNY’s smart contract functions give the state tools for increased surveillance, compromised privacy and economic retaliation against foreign firms [27] ◈ Strong Evidence. The Human Rights Foundation, an advocacy group critical of CBDCs, warns that the e-CNY could become a fully surveilled asset and notes the PBoC’s insistence on centralised management [28] ◈ Strong Evidence. Kazakhstan’s digital tenge, which has been used mainly for government programmes, shows the same feature in a different setting: officials describe earmarked and marked payments that restrict how public funds can be spent [47] ✓ Established.

The strongest counter-argument is that the e-CNY may expose less than the private alternatives already do. Alipay and WeChat Pay record not only payments but browsing, location and social data, and are themselves subject to Chinese law on state access; some practitioners argue that the e-CNY, which hides payment data from merchants and does not carry the holder’s name on the token, is in practice the more private option for many users [48] [32] ⚖ Contested. That comparison is real but limited. It establishes that private payment platforms in China are already highly visible to the state; it does not establish that a central bank ledger is benign. The relevant comparison for democracies is not Alipay but cash, and against cash every account-based digital payment — CBDC, card or app — is more visible [49] ◈ Strong Evidence.

The e-CNY therefore demonstrates three things about state visibility, none of which depends on assumptions about intent. Graded anonymity can be engineered, and the thresholds are policy choices that can be moved [43] ✓ Established. The privacy of a CBDC cannot be separated from the identity system around it: a phone-number wallet in a country with real-name SIM registration is not anonymous [32] ✓ Established. And programmable features such as expiry and merchant restriction are not theoretical — they have been used in live pilots, even if so far for stimulus rather than sanction [8] [27] ✓ Established. What the e-CNY does not demonstrate is that any CBDC must work this way. The IMF’s 2024 guidance treats privacy as a trade-off to be managed through institutional arrangements, privacy by design and privacy-enhancing technology [49] ✓ Established, and European law-makers are now trying to write those protections into statute, as Section 6 shows.

Nigeria launched the eNaira in October 2021 with financial inclusion as an explicit objective. A year later, an IMF working paper by Jookyung Ree found that 98.5% of eNaira wallets were unused in any given week, with only about 1.5% transacting [2] ✓ Established. At the end of November 2021 there were about 860,000 retail wallets, equal to 0.8% of active bank accounts [50] ✓ Established. The IMF noted a structural problem that undercut the inclusion goal at the outset: the eNaira was accessible only to people who already had bank accounts [51] ✓ Established. A CBDC that requires a bank account cannot reach the unbanked. By 2024, according to the IMF’s Article IV report as cited in Nigerian business press, there had been 854,512 eNaira transactions worth 29.3 billion naira in total, roughly 0.0048% of the country’s electronic payments in 2023, across some 13 million largely inactive wallets [51] ✓ Established.

Nigeria also produced the clearest natural experiment in CBDC demand. In early 2023 the central bank’s currency redesign removed most cash from circulation — notes in circulation fell from about 3.2 trillion naira to about 1 trillion — and Nigerians were forced to find digital alternatives almost overnight [52] ✓ Established. eNaira transaction value rose 63% to 22 billion naira and wallet numbers jumped to about 13 million [52] ✓ Established. But the main beneficiaries were bank transfers, cards and mobile money: total electronic payments reached 135.52 trillion naira in the first quarter of 2023, up 298% year on year [53] ✓ Established. Even under a severe cash shortage that a government had created, the public chose private digital payments over the CBDC by several orders of magnitude [53] [51] ◈ Strong Evidence. Nigeria’s account ownership, 63% of adults in the World Bank’s 2025 Global Findex, has been rising — but through fintech and mobile money, not the eNaira [54] ◈ Strong Evidence.

The Caribbean pilots tell a similar story at smaller scale. Jamaica’s JAM-DEX, rolled out to the public in 2022, stood at 290.65 million Jamaican dollars in June 2026 against 311.34 billion in currency issued, about 0.09% [3] ✓ Established. At the end of 2025 it had 305,026 registered users, but only 55.5% of the JAM-DEX in circulation was held by the public — the rest sat with wallet providers [3] ✓ Established. Only two wallets and 2,379 merchants were active in late 2025 [55] ✓ Established. Richard Byles, the Bank of Jamaica governor, accepted part of the blame in August 2026, saying the bank had spent about two years preparing before bringing commercial banks in, and that he would have involved them from the start [3] ✓ Established. In the Eastern Caribbean, the DCash pilot ended in January 2024 and the relaunch was suspended in February 2026 in favour of a fast payment system [14] ✓ Established.

The contrast with fast payment systems is stark. Brazil’s Pix, launched by the central bank in November 2020 as a free instant transfer system between existing accounts, accounted for 54.7% of all transactions in the country in the second half of 2025 and is used by 76.4% of Brazilians [4] ✓ Established. India’s UPI processed 228 billion transactions worth about 300 lakh crore rupees in 2025 [5] ✓ Established. Kenya’s M-Pesa, a private mobile money system, handled 41.68 trillion shillings in the year to March 2026 and had about 40 million monthly active users [6] ✓ Established. The BIS, reviewing evidence from Latin America and the Caribbean in March 2025, found that fast payment systems go hand in hand with greater access to loans and savings [31] ◈ Strong Evidence. More than 100 jurisdictions now operate fast payment systems [56] ✓ Established. None of these is a CBDC. Each is a public or private rail that moves commercial bank or e-money balances faster and more cheaply.

India offers a direct comparison within one country, because it runs both. The Reserve Bank of India’s e-rupee pilot, begun in late 2022, had about 1,016 crore rupees in circulation at the end of March 2025, up from 234 crore a year earlier [57] ✓ Established. By December 2025 retail e-rupee transactions had exceeded 120 million, worth more than 28,000 crore rupees, among a little over 8 million users [29] ✓ Established. UPI processed roughly 180 times that number of transactions in December 2025 alone [5] [29] ✓ Established. The global data point in the same direction. The World Bank’s 2025 Global Findex found that 79% of adults worldwide had an account, up from 74% in 2021, with 86% owning a mobile phone; about 1.3 billion adults remain unbanked [30] [58] ✓ Established. The gains came from phones, agents and fast payments [30] ◈ Strong Evidence.

The inclusion promise of retail CBDCs is therefore unproven at best. The best-documented case, Nigeria, shows no measurable inclusion effect and a structural design that excluded the unbanked [2] [51] ✓ Established. The Caribbean pilots show low uptake even in small, well-run systems with strong official backing [3] [11] ✓ Established. The evidence for fast payment systems is much stronger and comes from central banks that chose to modernise the rails rather than issue a new form of money [31] [4] ◈ Strong Evidence. That does not rule out a future CBDC designed for offline use or for populations that private systems do not serve. It does mean that inclusion is no longer a credible primary justification for one, and central banks in Canada, Australia and Sweden have reached broadly similar conclusions about their own public’s needs [15] [16] [59] ✓ Established.

The United States has moved from research to prohibition in less than two years. Executive Order 14178, signed on 23 January 2025, revoked the previous administration’s order on digital assets and directed that any ongoing plans or initiatives at any agency related to the creation of a CBDC within the jurisdiction of the United States shall be immediately terminated [17] [63] ✓ Established. At a Senate Banking hearing on 11 February 2025, Federal Reserve Chair Jerome Powell answered yes when asked to commit that there would be no central bank digital currency while he chaired the Fed [64] ✓ Established. The prohibition became statute in 2026, not through standalone anti-CBDC legislation but through a housing bill: the 21st Century ROAD to Housing Act passed the House 358 to 32 and the Senate 85 to 5 and became law without the president’s signature, barring the Federal Reserve from issuing a CBDC or anything substantially similar until 31 December 2030 [65] [18] [66] ✓ Established. In parallel, the GENIUS Act of July 2025 created a federal licensing framework for dollar stablecoins, making privately issued digital dollars the official US route [67] ✓ Established.

The euro area is moving in the opposite direction, slowly. The ECB completed a two-year preparation phase and on 30 October 2025 decided to move to the next phase, with a pilot from mid-2027 and first issuance possible in 2029 if legislation is adopted in 2026 [68] [69] ✓ Established. It estimated development costs of about 1.3 billion euros to issuance and about 320 million euros a year in operating costs thereafter [68] ✓ Established. The Council of the EU agreed its negotiating position on 19 December 2025 [70] ✓ Established. The European Parliament’s economic affairs committee approved its report 43 to 14 on 23 June 2026, and the plenary followed on 9 July 2026 by 416 votes to 169, with 22 abstentions, under rapporteur Fernando Navarrete [33] [60] ✓ Established. Trilogue negotiations began on 13 July 2026, with the holding limit, who sets it and merchant fees still unresolved [71] ✓ Established. The ECB’s Piero Cipollone said in April 2026 that the important thing is to have the legislation in place by the end of the year so that the ECB can keep to its timetable [72] ✓ Established.

The United Kingdom, Canada, Australia and Sweden have stepped back without closing the door. The Bank of England and HM Treasury received more than 50,000 responses to their 2023 consultation on a digital pound, most raising concerns about privacy, programmability and the future of cash [73] ✓ Established. A decision on whether to proceed is due by the end of 2026 [74] ✓ Established, and in October 2026 Deputy Governor Sarah Breeden was reported as saying there is no reason for the central bank to rush a digital pound given the pace of innovation in private payments [61] ◈ Strong Evidence. The Bank of Canada wound down its retail CBDC work in September 2024 after Governor Tiff Macklem said there was not currently a compelling case [75] [15] ✓ Established. The Reserve Bank of Australia is concentrating on wholesale tokenisation [16] ✓ Established. Sweden’s Riksbank, which ran one of the earliest e-krona pilots, now says there is insufficient social need for the moment and that its work tracks the digital euro [59] ✓ Established.

Russia represents the mandate model. From 1 September 2026, the country’s 12 systemically important banks were required to offer the digital ruble to customers, and retailers with annual revenue above 120 million rubles were required to accept it, with a second wave due on 1 September 2027 [62] [76] ✓ Established. Public demand was weak before launch: a SuperJob poll found that only one in ten Russians would accept a full salary in digital rubles [62] ◈ Strong Evidence. The central bank pays banks 0.67 rubles per payment instruction to support salary and benefit flows [62] ✓ Established. In the first ten days, Governor Elvira Nabiullina reported about 87,000 new digital ruble accounts and more than 50,000 transactions [77] ✓ Established. The Russian design ties adoption to state payments and to large retailers, a pattern closer to China’s payroll strategy than to the voluntary model the ECB is pursuing.

• Prohibition: United States — executive order of January 2025, statutory moratorium on a Fed CBDC to the end of 2030 [17] [18] ✓ Established.
• Legislation with limits: euro area — Council and Parliament positions adopted, trilogues under way, issuance targeted for 2029 [70] [60] [69] ✓ Established.
• Pause: Canada, Australia, Sweden and, on current signals, the United Kingdom [75] [16] [59] [61] ◈ Strong Evidence.
• Mandated adoption: China through payroll and incentives, Russia through obligations on large banks and retailers [22] [62] ✓ Established.
• Pivot to rails: Brazil switched off the Drex blockchain platform in November 2025, citing privacy, cost and security [78] ✓ Established.

The divergence is not mainly about technology, which all four camps regard as workable, but about two political judgements. The first is how far the public trusts the state with payment data: the 50,000-plus UK consultation responses dominated by privacy concerns and the 85% of Canadian respondents who said they would not use a CBDC are measures of that distrust [73] [15] ✓ Established. The second is whether private digital money is a threat or a solution. Washington treats regulated dollar stablecoins as the solution [67] ✓ Established; Frankfurt treats dependence on US card networks and stablecoins as the threat [26] [79] ◈ Strong Evidence. Moscow and Beijing treat a state-run digital currency as an instrument of policy in its own right, including for settlement outside Western financial channels [40] [62] ⚖ Contested.

The ECB’s privacy design rests on a separation of data. Under its published approach, the central bank would see only pseudonymised transaction data, protected by hashing and encryption, and would not be able to link payments to individual users; identity information would remain with the payment service providers that distribute the digital euro [81] ✓ Established. For offline payments, made device to device without a network connection, transaction details would be known only to the payer and payee, a level of privacy close to cash [81] ✓ Established. The Council’s December 2025 position retains the offline mode and a high degree of privacy, and makes basic services free to users [70] ✓ Established. The Parliament’s text goes further, requiring privacy by design and by default including the use of zero-knowledge proofs, and providing that the ECB should receive no identity data [33] ✓ Established.

Privacy advocates argue that these protections still fall short for online payments. In a joint opinion of October 2023, the European Data Protection Board and the European Data Protection Supervisor strongly recommended a privacy threshold for low-value online transactions, below which payments would not be traced for anti-money-laundering purposes [82] ✓ Established. That recommendation would have made small online digital euro payments materially more private than card payments today. Neither the Council nor the Parliament position, as reported, adopted it [70] [33] ◈ Strong Evidence. Online digital euro payments would therefore be subject to the same anti-money-laundering checks as bank transfers, with the protection resting on the separation between the ECB and intermediaries rather than on any absence of records ◈ Strong Evidence.

The ban on programmable money is political as much as technical. Fabio Panetta, then on the ECB Executive Board, told the European Parliament in January 2023 that the digital euro would never be programmable money and that the ECB would not set any limitations on where, when or to whom people can pay [83] ✓ Established. The ECB distinguishes programmable payments — conditional payments set up by the user, such as an automatic transfer on delivery of goods — from programmable money, whose use the issuer could restrict [83] ✓ Established. That distinction answers the Shenzhen precedent directly: an expiry date imposed by the issuer would be programmable money and is excluded; a conditional payment chosen by the payer would not. The Parliament text also bars interest on digital euro holdings, removing the type of incentive that China introduced in 2026 [33] [23] ✓ Established.

The holding limit exists because a digital euro would compete with bank deposits. If households could move unlimited sums into a risk-free central bank liability at the touch of a button, a banking scare could become a digital run within hours. The ECB’s own modelling, summarised above, is the reason the cap has dominated negotiations [80] ✓ Established. Markus Ferber, a German member of the European Parliament, said in October 2025 that he still saw a risk that smaller banks heavily reliant on retail deposits might run into trouble with excessively high holding limits [80] ✓ Established. The Council would have the ECB set the limit under a ceiling reviewed every two years; the Parliament wants the European Commission to set it [70] [71] ✓ Established. The Parliament also requires a rollout of at least 24 months and limits businesses to holding digital euros for 24 hours [33] ✓ Established.

The demand side is the largest unresolved risk. In a randomised experiment with more than 19,000 euro-area households, run in March and June 2024, the ECB found that most respondents considered it unlikely that they would pay with a digital euro, and that the effect of giving people information about it faded within three months [85] ✓ Established. That echoes the Canadian consultation and the Caribbean pilots [15] [3] ◈ Strong Evidence. The European design is the most carefully constrained retail CBDC yet proposed, with offline privacy, a holding cap, no interest and a ban on programmable money. Those constraints address the surveillance and bank-run objections. They also remove most of the features that might have made people want to hold it, which is why the European project now rests chiefly on the sovereignty argument examined in the next section [26] ◈ Strong Evidence.

The first disagreement is whether a CBDC is more or less surveillant than the private alternatives. Defenders of the e-CNY point out that tokens carry no name, that payment data are hidden from merchants and that Alipay and WeChat Pay already collect far richer behavioural data [48] [32] ⚖ Contested. Critics reply that central clearing, real-name phone registration, police access through big data analysis and, since 2026, interest reserved for verified wallets make the e-CNY a more complete instrument of state visibility than any private platform [32] [27] [23] ⚖ Contested. In democracies the comparison runs differently: card networks and banks hold detailed records already, and a digital euro with offline privacy could in principle be less visible than a card payment [81] ◈ Strong Evidence. Whether it would be depends on access rules that have not yet been finalised [71] ✓ Established.

The second disagreement concerns programmability. The ECB has pledged that the digital euro would never be programmable money [83] ✓ Established, and the European texts exclude issuer-imposed restrictions on use [33] ✓ Established. Sceptics answer that the capability is demonstrated — Shenzhen’s expiring envelopes and Kazakhstan’s earmarked tenge payments are working examples [8] [47] ✓ Established — and that a pledge given by one board can be revised by another, or by legislators under fiscal or security pressure [28] [27] ⚖ Contested. The empirical record so far shows programmability used for stimulus and for public spending controls, not for restricting citizens’ private purchases [8] [47] ◈ Strong Evidence. The disagreement is therefore about future risk rather than past abuse, which is why it cannot be settled by evidence alone.

The third disagreement is whether the digital euro’s privacy is sufficient. The ECB argues that pseudonymisation, the separation of identity from transaction data and an offline mode close to cash give users more privacy than any existing digital payment [81] ◈ Strong Evidence. The Parliament’s text adds zero-knowledge proofs and bars the ECB from receiving identity data [33] ✓ Established. The data protection authorities, however, wanted an untraced threshold for small online payments that neither legislative position includes [82] [70] ✓ Established, and 169 members of the European Parliament voted against the report in July 2026 [60] ✓ Established. The rapporteur, Fernando Navarrete, had earlier floated making the digital euro conditional on the failure of private European payment schemes, an idea that did not survive into either mandate [71] ◈ Strong Evidence.

The fourth disagreement is the most consequential: whether private innovation makes a retail CBDC unnecessary. The Bank of England’s current position, as reported in October 2026, is that there is no reason to rush because private payments are improving fast, and its attention has shifted towards stablecoins and tokenised deposits [61] ◈ Strong Evidence. Canada and Australia reached similar conclusions in 2024 [75] [16] ✓ Established, and the United States has made private stablecoins its official route [67] ✓ Established. On the other side, Christine Lagarde argues that Europe relies predominantly on US, and sometimes Chinese, networks to process payments and needs a European solution to be sovereign at home [26] ✓ Established. The BIS, in its 2025 Annual Economic Report, warned that stablecoins fall short on the tests of singleness, elasticity and integrity that money must pass [79] ✓ Established.

A fifth question sits underneath the four: whether wholesale CBDCs, used only between banks and central banks, raise any of these concerns. Most do not. The BIS survey shows wholesale work further advanced than retail [10] ✓ Established, and the BIS has shifted its own efforts to Project Agorá, which tests tokenised correspondent banking with seven central banks, including the Federal Reserve Bank of New York, the Bank of Japan and the Bank of England, and more than 40 firms [86] ✓ Established. The geopolitical concern attaches instead to who participates. mBridge, after the departures of the BIS and Saudi Arabia, is a platform in which almost all value moves in e-CNY [19] [40] ✓ Established. Agustín Carstens, then BIS General Manager, said in October 2024 that the BIS was leaving not because the project was a failure, nor for political reasons, but because the partners could carry it on alone [39] ✓ Established. Whether that account is complete remains disputed ⚖ Contested.

The first conclusion concerns demand. Every retail CBDC examined in this report — the eNaira, the Sand Dollar, JAM-DEX, DCash, the e-rupee and, relative to its market, the e-CNY — has struggled to attract voluntary everyday use where existing digital payments already worked [2] [11] [3] [14] [29] [34] ✓ Established. Where usage has grown, it has followed state direction: public payrolls in China, obligations on banks and retailers in Russia, and interest payments that turn digital cash into something closer to a deposit [22] [62] [23] ✓ Established. The European evidence on stated demand is no more encouraging [85] ✓ Established. This does not make a retail CBDC pointless, but it means that the decision to issue one is a strategic choice about infrastructure, not a response to consumer pull.

The second conclusion concerns inclusion. The claim that CBDCs would bank the unbanked has not survived contact with the data. Nigeria’s eNaira required a bank account and achieved no measurable inclusion effect [51] [2] ✓ Established, while fast payment systems and mobile money — Pix, UPI, M-Pesa — achieved mass adoption by cutting cost and friction on existing accounts [4] [5] [6] ✓ Established. The BIS’s own regional research associates fast payments with greater access to credit and savings [31] ◈ Strong Evidence. Central banks that want inclusion have a better-evidenced tool, and most of the world’s central banks now operate one [56] ✓ Established.

The third conclusion concerns surveillance, and it is the most important. The e-CNY has demonstrated that a central bank digital currency can be built with graded visibility, linked to a national identity system, programmed with expiry and merchant restrictions, and paired with financial incentives to identify oneself [43] [32] [8] [23] ✓ Established. None of this required new technology; it required design choices and a legal environment that permits state access [32] [46] ◈ Strong Evidence. The European design shows that different choices are possible — pseudonymisation, offline privacy, no interest and a statutory ban on programmable money [81] [33] [83] ✓ Established. But the European data protection authorities’ unmet recommendation on small online payments shows that even a privacy-focused design leaves records that a future legislature could reach [82] ◈ Strong Evidence.

The fourth conclusion concerns geopolitics. The strongest argument for a retail CBDC in 2026 is no longer efficiency or inclusion but control of payment infrastructure. Europe’s dependence on US card networks [26] ✓ Established, the US preference for dollar stablecoins [67] ✓ Established, China’s use of e-CNY in cross-border wholesale settlement [19] [41] ✓ Established and Russia’s mandate model [62] ✓ Established all point to the same reframing. Money is becoming a contest between public and private rails and between national systems. The CBDC is one tool in that contest, and its value to a state depends less on how many citizens use it than on what it allows the state to avoid depending on [79] [26] ◈ Strong Evidence.

• For legislators: privacy protections need to be statutory, with access rules for police and tax authorities fixed in law rather than left to central bank discretion [82] [49] ◈ Strong Evidence.
• For central banks: fast payment systems have the stronger evidence base for inclusion and cost reduction [31] [56] ◈ Strong Evidence.
• For the public debate: the relevant comparison for a CBDC is cash on privacy and cards on everything else [24] [81] ◈ Strong Evidence.
• For watchers of China: the 2026 interest reform is the variable to track, because it links holding e-CNY to being identified [23] ✓ Established.

The CBDC era is therefore not ending, but it is narrowing. Exploration remains nearly universal and wholesale experimentation is accelerating [1] [10] [86] ✓ Established. Retail issuance, by contrast, is concentrating in a handful of jurisdictions with strategic motives: China and Russia, which are willing to direct adoption, and the euro area, which is trying to legislate a constrained alternative to foreign networks [62] [70] [26] ◈ Strong Evidence. The pilots have answered the technical question. They have shown that the inclusion question has a better answer elsewhere. And they have made the surveillance question concrete: a CBDC sees exactly as much as its designers and their successors decide it should. The record of the next decade will depend less on the code than on whether democracies write those decisions into law before the systems are built.