Insight Report Central Bank Digital Currency Policy‑Maker Toolkit
Insight ReportCentral Bank Digital CurrencyPolicy‑Maker ToolkitCentre for the Fourth Industrial RevolutionJanuary 2020
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ContentsForeword4Executive summary5Understanding central bank digital currency8Toolkit121.Background assessment and project management142.Problem identification and analysis153.CBDC form164.Digital payments ecosystem and landscape evaluation175.‘Hybrid CBDC’ evaluation186.Operational risks and financial inclusion in retail CBDC197.Data protections and compliance for retail CBDC208.Evaluation of macroeconomic and financial risks and opportunities219.CBDC design elements2210. Technology choices, considerations and risks2311. Governance2412. Implementation strategy25ContributorsAcknowledgements2627Central Bank Digital Currency Policy‑Maker Toolkit3
ForewordIn recent years, central bank digital currency (CBDC) has risen to prominence as a policy andoperational consideration for central banks, ministries of finance and other institutions becauseof its potential to address both long‑standing and new challenges such as financial inclusion andpayment‑system stability. CBDC is a digitized version of sovereign currency, created and issued by,and a liability of, the country’s monetary authority.CBDC differs from other forms of digital or virtual currencies, including cryptocurrencies such asbitcoin and “stablecoins”, which are not issued by central banks or typically considered legal tender.Notably, CBDC may use centralized or decentralized technology systems, and policy‑makers shouldevaluate trade‑offs between technology choices before any CBDC issuance.AshleyLannquist,Project Lead –Blockchain andDistributed LedgerTechnology, WorldEconomic Forum,USAAcademic and policy research on CBDC has proliferated since 2014, as has technologicalexperimentation. More recently, numerous central banks have been actively evaluating CBDC,spanning continents and economies both large and small, developed and emerging. The motivationsfor CBDC vary between countries, as does its relevance and potential for creating value. The “case forCBDC” is unresolved, with research and experiments from central banks and academic researchersindicating different assessments of a CBDC’s value after considering costs and risks. Ultimately,countries should assess the value of CBDC on a case‑by‑case basis, evaluating trade‑offs andcarefully considering risks and design choices. Given the potentially far‑reaching consequences ofCBDC, policy‑makers must apply the utmost prudence.While many central bank researchers and policy‑makers have developed an interest in CBDC overthe past few years, most are not yet subject‑matter experts. Many research reports on CBDC providein‑depth information and analysis of issues such as macroeconomic impact, financial stability, marketinfrastructure and design without providing as much information about social risks, governance orimplementation strategies. Coupled with the ever‑growing body of CBDC research from all corners ofthe world and the rapid speed of technological developments that relate to CBDC, researchers andpolicy‑makers stand to benefit from a concise framework that can help inform their exploration.Sheila Warren,Platform Head –Blockchain andDistributed LedgerTechnology, WorldEconomic Forum,USAThe World Economic Forum’s CBDC Policy‑Maker Toolkit seeks to address the need for a concise,high‑level CBDC decision framework that provides comprehensive and risk‑aware information topolicy‑makers. The document serves as a guide to ensure that any CBDC deployment is cautious andfully considers alternative solutions, risks, deployment and governance strategies, multistakeholderinput and other salient factors. Notably, it is intended to serve as a complement to additional researchthat any policy‑maker considering CBDC should conduct.In the development of this framework, the Forum has taken a global and multisector view, drawinginput from its unique global community of CBDC experts and researchers, and developingan approach that is equally suitable for policy‑makers in developed or emerging economies.Furthermore, the toolkit can serve as a springboard to a community of practice and experienceexchange within the World Economic Forum network as central banks progress with their CBDCinvestigation and development.Richard Samans,ManagingDirector, WorldEconomic Forum,USA4Prior to crafting the CBDC Policy‑Maker Toolkit, the Forum convened central bank researchers andpolicy‑makers from more than 45 countries to guide its project work related to central banks, CBDC anddistributed ledger technology. It is from this input, as well as extensive discussion with additional experts,that the toolkit draws its motivation and content. Succinctly, this framework helps policy‑makers withincentral banks to confidently evaluate whether CBDC is appropriate for their economy.The CBDC Policy‑Maker Toolkit is developed within the Centre for the Fourth Industrial Revolution’sBlockchain and Distributed Ledger Technology Platform. It builds upon the platform’s March 2019white paper, which highlights central bank activity with blockchain technology as well as the platform’sglobally unique, curated list of more than 60 reports on CBDC research and experiments. Notably, theWorld Economic Forum does not advocate for or against the implementation of CBDC in any country.Central Bank Digital Currency Policy‑Maker Toolkit
Executive summaryIn recent years, central bank digital currency (CBDC), anew form of digitized sovereign currency, has risen toprominence as a policy and operational considerationfor many central banks, ministries of finance and otherinstitutions. The intricacies of implementing CBDC arecomplex and the implications are wide‑reaching. As a result,policy‑makers may find themselves in uncharted waterswhen attempting to evaluate the potential benefits andtrade‑offs associated with CBDC.The World Economic Forum’s CBDC Policy‑Maker Toolkitseeks to address the need for a concise CBDC decisionguide that provides comprehensive and risk‑awareinformation to policy‑makers. This document serves as apossible framework to ensure that any CBDC deploymentfully considers the costs as well as the potential benefits,appraising a multitude of risks and evaluating deploymentand governance strategies, alternative solutions and othersalient factors. Notably, it is not exhaustive, and insteadintends to serve as a complement to additional research thatany policy‑maker considering CBDC should conduct.The CBDC Policy‑Maker Toolkit provides high‑level guidanceand information for:– Retail, wholesale, cross-border CBDC and alternatives inprivate money such as “hybrid CBDC”– Large, small, emerging and developed countries.– Section 9: CBDC design parameters are then assessedin light of identified objectives and risks, including custodyand storage, anonymity, account and transaction limits,interest payments, and conversion and redemption rates.– Section 10: Following design, the process focuses ontechnology choices and requirements to supportthe CBDC.– Section 11: The process continues with an evaluation ofgovernance strategies and requirements, including userengagement, financial management, the establishment ofperformance criteria and monitoring processes.– Section 12: The toolkit concludes with an initialimplementation strategy, including guidance onexperimentation and prototyping, public engagementand collaboration in experimentation and deployment.As policy‑makers navigate this process, they shouldconsider how CBDC may introduce new capabilities thatsupport regulatory goals while also introducing new risks orcompliance vulnerabilities. CBDC could potentially be usedas a tool to achieve policy objectives such as improved safetyand resilience in payments systems; increased efficiency,access and competitiveness of payments systems; betterdata transmission and reporting to central banks; andfinancial inclusion. The achievement of these goals withCBDC must be evaluated in the full context of the associatedtrade‑offs and risks that CBDC may entail.This toolkit will walk policy‑makers through a CBDCevaluation and design process step‑by‑step, emphasizingthe incorporation of multistakeholder input. The flow chart onpage 13 of this document illustrates the steps in this process.– Section 1: The process begins with backgroundassessment and pre‑analysis, including considerationof strategic questions related to legal and institutionalchallenges, project management, decision‑making andstakeholder involvement.– Sections 2 and 3: The process continues with problemidentification and analysis, including identification of thetop CBDC objectives and goals. It results in the initialselection of the most appropriate form of CBDC.– Sections 4 and 5: The context for the digital paymentsecosystem is outlined, highlighting relevant issues. Thepolicy‑maker is then prepared to evaluate “hybrid CBDC”as a potential alternative to retail CBDC if relevant.– Sections 6, 7 and 8: The potential benefits andrisks are considered, including the operationaland cybersecurity risks, cost and accessibility,user data protection and privacy, compliance andmacroeconomic and financial impacts.Central Bank Digital Currency Policy‑Maker Toolkit5
Retail CBDCWholesale CBDCA brief summary of the cost/benefit analysis facilitated by the toolkit follows:6Key opportunitiesKey challenges or alternative solutionsCould improve efficiency in speed and costs forcross‑border interbank payments (potential to bypasscorrespondent banking systems and challengesrelated to legacy infrastructure, intermediary operatinghours or cut‑off times, and other interbank processes).Considering risks associated with CBDC, central banksshould determine how frictions can already be addressed,such as by extending central bank and processor operatinghours and establishing clear data messaging standards andgovernance.Could reduce settlement and counterparty risksand enable delivery‑versus‑payment (DvP) orpayment‑versus‑payment (PvP) in cross‑borderinterbank securities transactions and fundstransfers. Programmable nature of wholesale CBDCcould also apply to other use cases (e.g. withinfinancial market infrastructure).Domestic wholesale CBDC may not add value in domesticinterbank payments where an efficient system already exists(domestic wholesale CBDC is arguably equivalent to centralbank reserves).Potential to provide efficient cross‑border retailtransactions (reduced cost and speed) for users.Where an efficient domestic retail payment system exists,domestic retail CBDC may not add value net of risks anddownsides.Potential to improve financial data transmission andreporting to central banks; improve traceability ofpayments relative to physical cash (e.g. to reduce illicitactivity); reduce costs and frictions associated withcash management.Requires heavy investment in cybersecurity andsystem resilience.Can serve as a counterweight to market powerof private payment service providers, increasingcompetition in the payments market and providing astable public option for payment services.Existing alternatives, most notably regulation of paymentservice providers, should be considered to assess relativeattractiveness of CBDC.Can provide access to central bank money in aneconomy where cash usage or availability is declining(e.g. with the rise of digital payments).Compared to physical cash, risks from counterfeiting,theft and network failure for digital money entail morecatastrophic consequences. If retail CBDC is widely used, asystem failure would cause substantial interruptions.Can provide safe‑haven public option for savings,with lower risk of default than storing savings withcommercial banks.Where a strong deposit insurance system is already inplace, retail CBDC would probably not provide added valuein terms of offering a safe‑haven option for retail savings.Can challenge commercial banks’ market power overretail deposits, pressuring banks to increase interestrates and offer better financial services to depositors.Generates substantial financial risks, including: 1) bankdisintermediation risk, which could reduce bank profits andlending activity; 2) digital‑bank‑run risk as depositors mayrapidly convert commercial bank deposits to CBDC.Can potentially improve monetary policy transmissionand effectiveness depending on interest rate policies(research indicates mixed value for monetary policygoals alone).Necessary to consider existing alternatives such as negativenominal interest rates on reserves or fiscal policy measuressuch as tax rebates aimed at subsidizing households.Potential to support financial inclusion goals.Financial exclusion could arise if the issuing central bankdoes not take special care to ensure the CBDC is widelyaccessible within the country.Can support continued usage of the domesticcurrency if de facto dollarization or competitionfrom other currencies, including digital currencies,cryptocurrencies or foreign‑country CBDC, emerges.Retail CBDC accounts of all forms could be a significanttarget for theft and terrorism. If retail or “hybrid CBDC” is usedwidely, the monetary authority must design and implementstrict user data storage and privacy policies and protections.Central Bank Digital Currency Policy‑Maker Toolkit
“Hybrid CBDC”DLT‑ based CBDC (retail or wholesale)Alternative to CBDC and regulation in addressingOutstanding regulatory and policy considerations to bepayment‑system stability and market power risks from resolved. Does not constitute claim on central bank in casewidely adopted digital payment providers: e.g. central of issuer default.banks can enforce stronger reserve managementpolicies and oversight.Allows central bank to support provision of electronicMay have impacts on seigniorage that need to be carefullymoney with safeguards and protections for user funds. considered.Relative to retail CBDC, could probably beimplemented more rapidly and enable central bankto focus on core competencies such as transactionsettlement rather than a full suite of retail CBDCcomponents and requirements.Might not offer significant value relative to two‑tiered CBDCsystem or the current system of payment intermediaries.Potential for lower‑cost interconnectivity orinteroperability for CBDC with retail payment providersand infrastructure.Implementation of nascent technology infrastructure andassociated costs and risks, including lack of widespreadtechnical talent and track record for distributed ledgertechnology (DLT) systems at scale.Potential for lower initial implementation cost andfaster development.Higher security costs and risks from greater systemopenness (presence of multiple validating nodes increasessystem’s attack surface and risk of data leaks, dependingon privacy of transactions and accounts).Depending on implementation, may support benefitssuch as: 1) greater competition in retail financial services;2) “smart‑contract”‑driven wholesale CBDC applications(e.g. “atomic swaps and securities transactions”).Greater risk of “double‑spend” and other network attackswith transaction validation deferred to parties other than thecentral bank.Could offer diversification in payment “rails”,Potentially slower transaction‑verification process andproviding efficiency gains or serving as a contingency lower scalability, depending on network scale, size andpayment medium.consensus algorithm.Central Bank Digital Currency Policy‑Maker Toolkit7
Understanding central bank digital currencyCBDC is a new form of digitized sovereign currency, generallyconceived to be equal to physical cash or reserves held at thecentral bank. It is central bank money, or a component of themonetary base and a direct liability of the central bank.Beyond interbank payments, wholesale CBDC could beapplied in various countries to interbank securities transactionsor financial market infrastructure applications (domestic orcross‑border), discussed at the end of this section.Currently, central bank money is composed of physicalcash (coins and bills) and reserves held at the central bankby financial institutions with access to the central bank’sdeposit facility. CBDC would constitute a third form ofcentral bank money.Cross‑border CBDC (retail or wholesale)Coinsand billsReservesCBDCRetail uses X Wholesaleuses Digital formX (physical cash)Retail CBDCToday, the general public holds central bank money in theform of physical cash. For a given country, retail CBDC, whichcan also be called “general-purpose” CBDC, would constitutethe first digitized form of central bank money and liability thegeneral public could own. The public could have accounts ofthe digitized fiat currency with the central bank, or hold CBDCon mobile devices, prepaid cards or other forms of digitalwallets. While the central bank issues and manages retailCBDC, several ecosystem participants, such as commercialbanks and payment service providers, may be involved inthe system through a two‑tiered structure, introduced furtherbelow, or by offering interoperable payments and services.Wholesale CBDCWholesale CBDC could be issued by central banks tocommercial banks and potentially other financial institutionsfor use in interbank payments and securities transactions.These institutions could hold wholesale CBDC accountswith the central bank, akin to the reserve accounts theykeep today (it could be argued that wholesale CBDC alreadyexists today in many countries in the form of reserves).Wholesale CBDC for domestic use may not provideadditional interbank payment functionality to an economythat already has a well‑functioning commercial bankingsector and interbank payment system, such as a real‑timegross settlements (RTGS) system. Such banks can alreadyefficiently transact with one another using reserves held at thecentral bank in the manner they would with CBDC. WholesaleCBDC for use in domestic interbank payments may be mostrelevant for developing economies that need a more efficientinterbank system and prefer an alternative to today’s standardsystems, such as a traditional RTGS system.8Central Bank Digital Currency Policy‑Maker ToolkitThe value that a cross‑border CBDC provides dependson the economy’s unique payments infrastructure andstarting point. Cross‑border wholesale CBDC may bevaluable across economies to enable more efficientcross‑border interbank payments. As foreign banks andfinancial institutions today are generally unable to holdreserve accounts with the central banks of other countries,they must conduct cross‑border payments in a muchless efficient manner. Rather than transacting and settlingthrough a common central bank in which both partieshold reserve accounts, they route payments throughcorrespondent and other interbank payment networks,entailing extra time, costs and risks.Generally, a cross‑border form of wholesale CBDC inwhich foreign institutions might own and transact in CBDCcould potentially unlock efficiencies related to more directcross‑border interbank payments. For a given economy,the CBDC would constitute the first form of digitized centralbank money that could be held and sent directly overseas,where transactions could be made without the need fortoday’s cross‑border interbank payment networks.Likewise, cross‑border retail CBDC could allow retail usersto send payments, including remittances, across bordersin a manner that reduces the need for intermediaries.Importantly, for this to occur, the central bank must allowforeign entities to hold the CBDC. Accordingly, it may raisecomplex legal or financial integrity questions.Where cross‑border payments involve a foreign‑exchangetransaction from a domestic CBDC to another country’sCBDC, present‑day currency conversion frictions remain.The system requires either that a foreign‑exchangemarket‑making intermediary is willing to assumeforeign‑exchange risk or that the transacting commercialbanks hold accounts in foreign CBDC.CBDC and the central bank balance sheetWhen central banks issue CBDC, they may substitute anexisting liability, namely physical cash or commercial bankreserves at the central bank, for the CBDC. In this scheme,the composition of central bank liabilities changes, butthe size of the balance sheet generally does not change.Alternatively, the central bank could issue CBDC as a newliability in exchange for bonds or other assets, increasingthe total size of the balance sheet (i.e. both assets andliabilities increase).
If demand for CBDC is high and commercial bankcustomers wish to redeem their deposits for CBDC, thismight have disruptive consequences on the banking sector,with potential impacts on financial stability. The substitutionof deposits for CBDC might also have dampening effectson the money multiplier process, requiring the central bankto grow its balance sheet in order to offset the change andguarantee a sufficient supply of liquidity to the economy. Inthis case, the central bank may want to determine policiesthat ensure a controlled roll‑out of CBDC in order to preventsuch sudden disruptions.Account‑based CBDCAn account-based CBDC is said to be held directly orindirectly in accounts at the central bank. Account‑basedretail CBDC could be considered a substitute for commercialbank deposits. It exists as a claim on the central bank by aknown or pseudonymous owner.Considerations:– Under this approach, the central bank may need to openand manage a large number of accounts and conductrelated regulatory compliance and customer-servicefunctions, where applicable. As these functions have nottraditionally been performed by central banks, particularlyin the retail context, they may entail extra operationalcosts. A two‑tiered structure, described below, couldhelp address this challenge.– Account-based retail CBDC may raise commercial bankdisintermediation risks and corresponding financialstability concerns.Token‑based CBDCToken‑based retail or wholesale CBDC is said to be held bythe owner in digital wallets of various kinds and, like physicalcash, represents a “token” or object of stored value thatis digital fiat money and that can be directly transacted byowners who are either known or pseudonymous. Becausetoken‑based CBDC centres on the token object ratherthan the holder’s identity (particularly related to transactionvalidation), it can arguably afford greater anonymity andfewer user‑identity requirements than account‑based CBDC.– However, a universally accessible CBDC without identityrequirements would increase the risk that the CBDCcould be used for illicit activity and also conflict withmost know‑your‑customer (KYC), anti‑money laundering(AML) and countering the financing of terrorism (CFT)requirements. As a result, token‑based CBDC for walletholders who are non‑identified parties may be moresuitable if restricted to small‑value transactions.– Without strict user‑identity requirements, it might alsobe more difficult to restrict usage to certain types ofparticipants or within state borders with token‑basedCBDC. All else being equal, accessibility is both easierto scale and more difficult to control in the token‑basedCBDC concept.Conceptions and implications related to token oraccount‑based CBDC vary across institutions and research,potentially calling into question the categorization and itsvalue for CBDC investigation.Two‑tiered CBDCA two‑tiered CBDC system could enable customersto hold CBDC with commercial banks or other thirdparties that serve as the user‑facing intermediary,managing accounts, customer service, compliance andother requirements. Two‑tiered models could alleviatechallenges related to customer account management andcompliance requirements and mitigate commercial bankdisintermediation. CBDC remains a claim on the centralbank by users, despite the involvement of intermediaries.Conceptions of two‑tiered structures vary as few havebeen fully designed or developed. For instance, CBDCheld in a two‑tiered structure at a commercial bank mightneed full 100%‑reserve backing in order to remain aliability of the central bank and guaranteed in the event ofcommercial bank insolvency. Based on interests and needs,policy‑makers can evaluate whether a potential two‑tieredstructure meets their goals and objectives.Considerations:– Token‑based retail CBDC may be preferred if the centralbank seeks to design a CBDC that is widely accessiblelike cash, potentially allowing foreign citizens andentities of various kinds to use it and not requiringuser identification.– If user identities are not required, and the CBDC can besent to anyone with a suitable digital wallet, then a wideraudience could employ the digitized sovereign currency.This could potentially support policy goals related towidening access to central bank money and an efficientmeans of retail payments. Anonymity and transactionprivacy could also be stronger.Central Bank Digital Currency Policy‑Maker Toolkit9
What is innovative about CBDC?Account‑based CBDC, in all forms, is feasible today withexisting technologies. For any central bank consideringCBDC, the question should be asked as to why anaccount‑based form of CBDC has not yet been established.Put differently, why have central bank accounts for retailcustomers (retail CBDC), or for foreign financial institutions(cross-border wholesale CBDC), not yet been ial userscould hold accountsof digitized centralbank moneyForeign non‑financialusers could holdaccounts of digitizedcentral bank moneyWholesaleAkin to electroniccentral bankreservesForeign financialinstitutions could holdaccounts of digitizedcentral bank moneyTransaction verificationTransaction verification for any digital money is crucial to itsoperation. For physical cash, anti‑counterfeiting measuresensure cash is genuine. Digital money is also subject tocounterfeiting risk: A vulnerability in the system could allowdigitized money to be created out of thin air. Digital moneyalso suffers the added complication of “double‑spending”risk, an instance in which the same digital money isspent multiple times illegitimately. The purpose oftransaction verification for CBDC is to verify there is no“double‑spending” or other electronic manipulation of thedigital currency and transactions.Within the cryptocurrency ecosystem, the Bitcoin networkwas the first to solve the “double‑spend” problem of digitizedmoney in the context of decentralized transaction verification,in which transactions are not validated by a trusted authoritybut rather a network of computer nodes. Two innovationswere combined to make double‑spend economically unviable:a linear trail of transaction history for all bitcoins (or fractionsof bitcoins) to ensure they have not been double‑spent;and a computational puzzle (the “proof of work” consensusalgorithm), which raises costs to the types of network attacks(e.g. 51% attack) that could enable double‑spending.Transaction validation for CBDC can occur with a singleparty such as the central bank validating transactions, orin a decentralized manner with multiple parties validatingtransactions using blockchain and distributed ledgertechnology (DLT). If DLT is employed for transactionverification, then the validating parties (“nodes”) in thesystem reach agreement (“consensus”) on transactionvalidity in a decentralized manner according to a specificconsensus algorithm. This process could occur as it doeswith bitcoin, with an unconstrained network of nodes. Inthis case, scalability protocols that can support highertransaction performance would probably be required.These could include second‑layer systems that improvescalability for a given blockchain network, or potentiallynew blockchain networks whose designs and consensusmechanisms enable faster transaction processing.10Central Bank Digital Currency Policy‑Maker ToolkitMost likely, DLT-based CBDC would operate best within aclosed “permissioned” network of pre‑identified validatingparties that use simpler and resource‑efficient consensusalgorithms such as “proof of authority”. The central bankcould remain a validating node if desired, and regulators orother institutions could participate as additional validatingnodes or observer nodes where they could have validatingor view privileges.What role could DLT serve in CBDC?One important determinant of whether DLT should be usedis whether the central bank or a centralized transactionverification authority is best positioned to verify and settlepayments made in the system, or whether this should bedelegated to a distributed network. DLT enables decentralizedtransaction validation for CBDC when a centralized validationsystem within the central bank is not preferred.If DLT were to be used in a CBDC system, the central bankwould fully control the issuance of CBDC, as it does with acentralized system. However, it could delegate transactionapproval to a more decentralized network, most likelyconsisting of regulated financial institutions. Transactionapproval could follow a pre‑specified consensus processdetermined by the central bank, which could includeprivileges for the central bank such as transaction “veto”powers or visibility. It is also possible to develop a DLT systemin which the central bank remains the only validating nodeyet it benefits from other advantages related to DLT. In theNational Bank of Cambodia’s Bakong National PaymentSystem, the world’s first full‑scale deployment of a quasi‑formof CBDC that launched in July 2019, the central bankperforms all transaction validation, although transactionsoccur within the Hyperledger Iroha DLT framework. This effortis summarized in the Section 12 Appendix.If policy‑ma
Central Bank Digital Currency Policy‑Maker Toolkit 5 Executive summary In recent years, central bank digital currency (CBDC), a new form of digitized sovereign currency, has risen to prominence as a policy and operational consideration for many central banks, ministries of finance and other institutions. The intricacies of implementing CBDC are
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