央行数字货币：进一步应对挑战和风险

November2025 IMF staff regularly produces papers proposing new IMF policies, exploring options forreform, or reviewing existing IMF policies and operations. The Report prepared by IMFstaff and completed onNovember 10, 2025, has been released. The staff report was issued to the Executive Board for information. The report wasprepared by IMF staff. The views expressed in this paper are those of the IMF staff and TheIMF’s transparency policy allows for the deletion of market-sensitive informationand premature disclosure of the authorities’ policy intentions in published staff reports Electronic copies of IMF Policy Papersare available to the public fromhttp://www.imf.org/external/pp/ppindex.aspx International Monetary Fund CENTRAL BANK DIGITAL CURRENCY: FURTHER November 10, 2025 EXECUTIVE SUMMARY This paper informs the Executive Board of recent global developments in centralbank digital currency (CBDC) in light of the upcoming publication of new chaptersof the IMF’s CBDC virtual Handbook (Handbook), to be released in November2025.Exploration of retail CBDC (rCBDC) and wholesale CBDC (wCBDC) remains active,with efforts on the latter gaining prominence. This third wave of chapters, summarized The Handbook aims to provide frameworks for policymakers to scrutinize CBDC.The Handbook is intended as a technical resource primarily for emerging market and developing economies (EMDEs) to reflect countries’ experiences, lessons, and researchas well as offer frameworks to help think through potential implications and tradeoffs ofCBDC. Each chapter tackles a specific question and is not intended to evaluate CBDC’s What are the implications of rCBDC for financial stability? •rCBDC could affect domestic financial stability negatively or positively throughmultiple interrelated channels, involving changes to bank funding and lending, feeincome loss, run risks, information flow, and payment system resilience. The •Countries can mitigate financial stability risks through careful rCBDC design andexisting policy tools. Impact assessments should begin with bank balance sheet How would rCBDC affect retail payments competition? •Design features such as fee structures, interoperability, intermediary rules, and legaltender status all influence whether rCBDC would strengthen or dampen competitivedynamics. A well-calibrated design is essential for balancing benefits like inclusion •rCBDC has the potential to improve competition, especially in markets dominatedby private platforms with high fees and limited access. rCBDC may have a moremoderate impact in regulated markets where there are fee caps or other controls. CENTRAL BANK DIGITAL CURRENCY: FURTHER NAVIGATING CHALLENGES AND OPPORTUNITIES What are the key legal considerations for both rCBDC and wCBDC? •rCBDC initiatives raise questions about the legal nature of rCBDC as currency, the statutory basisfor its issuance and platform operation, and the regulatory authority over service providers. Theyalso require the legal assessment of the relationships within a rCBDC ecosystem and key •wCBDC presents legal challenges mainly associated with tokenization, including in relation to itslegal nature, the central bank’s mandate to issue wCBDC and operate its platform—eitherdirectly or through outsourcing to third parties—the legal relationship between the central bank How might rCBDC affect financial integrity? •The financial integrity implications of rCBDC will depend on its design. For instance, token-based, decentralized, or direct models may pose higher or more novel money laundering andterrorism financing (ML/TF) risks, potentially requiring central banks to assume anti-money laundering and combatting the financing of terrorism (AML/CFT) responsibilities traditionallyheld by intermediaries. rCBDCs carry more complex financial integrity implications than wCBDCs.•There is little precedent on the application of the Financial Action Task Force (FATF) Standards to What lessons from payment ecosystems resilience in FCS could help inform rCBDC? •Building resilient payment ecosystems in FCS requires reinforcing five layers—users, solutions,intermediaries, infrastructure, and connectivity—through strategies like redundancy andscalability, distributed infrastructure and decentralization, operational and cybersecurity, user •rCBDC offers potential benefits, such as backup infrastructure, secure digital rails, andprogrammable emergency disbursements. However, these benefits must be tailored to local What are tokenized reserves,1and how might central banks explore them? •As issuers of the most liquid and safe assets—central bank reserves—central banks may considerissuing tokenized reserves on distributed ledger technology (DLT)-based infrastructure topreserve the role of central bank money in anchoring trust and stability in the financial system. •Central banks might also assess alternative settlement solutions such as RTGS links, omnibusaccounts, and privately-issued tokeni