The International Monetary Fund has published guidance for policymakers assessing the legal foundations for central bank digital currencies, with a primary focus on retail CBDC and separate analysis of wholesale CBDC. The note advises jurisdictions to conduct comprehensive legal reviews and, where necessary, amend legislation before issuance. It does not recommend that jurisdictions issue CBDCs. For retail CBDC, legal frameworks should establish it as a direct central bank liability under any distribution model, clarify any currency and legal tender status, and explicitly authorize the central bank to issue it and operate or oversee the payment platform. Frameworks should also regulate intermediaries, protect users’ holdings from intermediary insolvency, allocate liability among central banks, providers and users, and address holding and transaction limits, fees, programmability, offline payments and settlement finality. For wholesale CBDC, authorities should clarify the legal relationship between tokens and underlying central bank reserves, ensure the central bank has authority to issue the instrument and control its platform, and define when transfers become irrevocable and final.
2025-11-11International Monetary Fund
International Monetary Fund outlines legal foundations for retail and wholesale central bank digital currencies
The International Monetary Fund has outlined the legal foundations jurisdictions should assess before issuing retail or wholesale central bank digital currencies. The guidance calls for clear issuance mandates, protection of CBDC holders, effective oversight of platforms and intermediaries, and legal certainty over token transfers and settlement finality. It does not recommend CBDC issuance.