DPF Response to the Consultation on the digital Pound and accompanying Technology Working Paper

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The Digital Pound Foundation (DPF) takes pleasure in responding to the Bank of England and HM Treasury’s (HMT’s) Consultation on a Digital Pound (the “Consultation”), and to the Bank of England’s accompanying Technology Working Paper on the digital pound.

The DPF’s stated remit is to advocate for and support the implementation of a well-designed digital Pound, in both publicly and privately issued forms, and a diverse, effective and competitive ecosystem for these new forms of digital money in the UK. As such, we wholeheartedly support the Bank of England’s continued exploration of a digital Pound in the form of a retail CBDC, and we appreciate the chance to share our thoughts and expertise on the subject. We would welcome the opportunity for further engagement and discussion with HMT and the Bank of England on the Consultation, and any other related consultations and discussion papers as may be relevant and appropriate.

The DPF’s members are uniquely qualified to contribute to the discussion around introduction of a CBDC, as they are all already actively involved and engaged in the development of new forms of digital money – whether as professional service and technology providers for CBDC projects, issuers of digital money, or firms whose business models depend on the existence of new forms of digital money. Our response to this Consultation is therefore informed by a collection of forward-looking viewpoints and an active envisaging of the future ecosystem of new forms of digital money and of any CBDC’s role and place within this context.

We share the Bank’s view that public access to public money is of fundamental importance to maintaining trust within the UK’s financial system. It is our view that public money also represents a fundamental expression of the relationship between the UK government and the general public. We are in agreement as well with the Bank’s consideration that a more radical shift towards greater use of private money, in the form of both existing commercial bank money as well as the emerging paradigm of tokenised deposits, tokenised e-money and other variants on privately-issued stablecoins, could result in a situation whereby some members of society are left behind or further excluded from access to the financial system, due to the focus of the private sector on more commercially advantageous customers.

Furthermore, despite the dramatic increase in usage of commercial bank money – private money – for everyday transactions over the past two decades, and the corresponding decline in cash usage, cash remains an intrinsic part of the money ecosystem, and millions of UK residents still depend on using it for many reasons. It is our view that, ultimately, public money represents the only fully accessible and inclusive form of money that we have. As physical cash use declines[1], therefore, the case for introducing a digital alternative to publicly-issued cash (whilst not necessarily supplanting cash in its entirety) grows ever stronger – as does the need for full transparency and clarity around the differences between the various new forms of digital money, the risk profiles attached to them and the need for enhanced digital inclusion.

In designing its own CBDC, the UK has an opportunity to play to its strengths – including its desired strategic objectives – and to develop a CBDC that can contribute not only to maintaining a position of global leadership, but also to lead the way in standard setting, effective regulation, sustainability and delivery of ESG objectives. As a digital-native form of public money, a retail CBDC could have significant benefits for the UK public, as well as becoming a key means of delivering more effective public policy in the transition to a digital economy. A nation’s currency is not only its store of value, unit of account and medium of exchange; when deployed strategically, it has the potential to create new economic opportunities. The introduction of a sovereign currency that is able to participate fully and actively in digital ecosystems will enable the UK to further build on its economic and social development and growth. It could act as a potential differentiator and accelerator of innovation for the UK on the global stage, by providing a vital component of the financial markets and payments infrastructure of the future.

We therefore welcome the Consultation – The digital pound: a new form of money for households and businesses? – and in particular its proposed ‘platform model’ for public-private partnership that fundamentally acknowledges the role played by public money – accessible to retail users – in maintaining confidence in the financial system, alongside the role of the private sector in the wider financial services ecosystem that underpins our economy.

We also appreciate the Bank’s recognition of the importance of public trust and confidence in the design of any CBDC system, and its proposal of a design and market structure in which, importantly, neither the Bank nor the Government will have visibility of user data, and which does not create a more intrusive system that that currently in place with respect to accounts, cards and payments today.

We would also strongly advocate for the Bank to encourage practical initiatives to support ongoing retail CBDC design exploration, building on the Project Rosalind work to date. This could take the form of a sandbox along the lines of the FCA Regulatory Sandbox or a competitive Proof of Concept build process along the lines of that recently carried out by the Australian central bank. In this practical vein, the DPF’s Use Case Working Group (WG) has been exploring real-world use cases for a retail digital Pound for some time and our current thinking is presented in Annex 2 below. We would welcome the opportunity to discuss these and to explore them further with the Bank at its convenience.

The DPF does however observe that the Bank, whilst progressing its exploration of a retail CBDC, has thus far remained largely silent on the topic of wholesale CBDC. We note the Bank’s reference to a private sector initiative for wholesale settlement on distributed ledger technology using central bank money via an omnibus account. But there is no reference to the extensive work being undertaken by the various Bank for International Settlements (BIS) Innovation Hubs, in conjunction with a number of central banks globally, in exploring the potential for wholesale CBDCs and their role in improved cross-border settlements as well as in enabling enhanced digitisation of financial markets and their infrastructures. This also stands at odds with jurisdictions such as Brazil, Australia and India, which all have wholesale CBDC pilots currently underway. It also stands in contrast with the House of Lords Economic Affairs Committee’s observation, in its report on CBDCs, that there is a strong case to be made for the introduction and uptake of a wholesale CBDC.

As a point of clarification, throughout this Consultation response document we have referred to the Bank’s proposed digital Pound CBDC as “CBDC”, “retail CBDC”, or “digital Pound CBDC”. This is due to the fact that, for the Digital Pound Foundation, when we refer to a digital Pound we are referring to both public and privately issued versions of a digital Pound, and so wish to make clear throughout this document that we are commenting exclusively on the Bank’s proposed introduction of a central bank-issued digital Pound CBDC.

Policy Drivers for a Retail CBDC

We are aware of many industry discussions, including those amongst our own members, on the ultimate utility and use cases for a retail CBDC in the UK. We expect that these will continue to progress over the coming months and years, and indeed the DPF’s own Use Case Working Group is exploring these potential applications. Furthermore, the DPF is actively embarking on a programme of activity to highlight the foundational role of a UK retail CBDC in enabling enhanced policy delivery across a number of areas of the UK economy and Government focus, including but not limited to better delivery of benefits, enabling digital trade (an area ripe for development following the introduction of the Electronic Trade Documents Bill), and improved revenue collection capabilities. We would welcome the opportunity to discuss these topics with HMT, and in understanding how we can shape our work to support HMT’s wide policy agenda for a UK CBDC, should this be of interest.

That said, we see the following as key policy drivers for the introduction of a retail CBDC in the UK:

  1. Central bank money as the anchor of monetary and financial stability – we are very much in agreement with the Bank’s assertions around the role played by both retail and wholesale central bank money, as well as robust regulation and supervision, in maintaining trust in the financial and monetary system. As transactional use of cash – the only other form of publicly accessible central bank money available – continues to decline, it makes sense to maintain public access to public money through the introduction of a digital-native form of central bank-issued money both for transactional purposes and as a store of wealth. We note as well the Bank’s observation that the role played by a future CBDC in supporting the uniformity of money is not necessarily dependent on high public uptake of the CBDC; it is sufficient that it exists, and is accessible, and that other privately-issued forms of the Pound sterling can be converted to it on demand and at par.
  1. A vector for interoperability between new forms of digital money – The DPF envisages a future in which multiple different forms of money – both public and private, and both those currently in use as well as new forms of digital money – coexist. Each has the potential to fill a different niche in the ecosystem and to provide enhanced consumer and business choices, arising from their different characteristics, the technical functionality that they offer, the nature of their issuers and the risk (both real and perceived) attached to them as a consequence of all of these taken together.

In order for our vision of a diverse, competitive and effective ecosystem for new forms of digital money to become a reality, seamless interoperability, convertibility, and – above all else – preservation of the singleness of a digital Pound in all its varied formats, will be required. Just as bank deposits can today be converted into cash, or e-money into bank deposits, the future evolution of money and payments will require equally seamless, trusted and invisible conversion between cash, bank deposits, e-money and new forms of public and private digital money.

We are supportive of the Bank’s vision (Box E), of the role that can be played by a CBDC in a mixed payments economy, in coexisting with, and complementing, systemically important stablecoins, tokenised deposits and tokenised e-money, and other new forms of digital money, and also providing a form of interoperability and rails between existing payment infrastructures and future digital platforms.

  1. Platform for innovation – Sir Jon Cunliffe, in many of his speeches as well as most notably in his oral evidence given to the House of Lords Economic Affairs Committee[2] has often noted the potential for a UK CBDC to provide a platform for innovation in ways that might, at present, not be entirely foreseeable – much in the same way that the role of the smartphone in everyday life and the extent to which it has transformed the way in which people interact with each other, with services and with businesses, could not have been foreseen at the time the first iPhone came to market.

There has also been a growing recognition of the wider benefits associated with CBDCs beyond their use as payments instruments. This includes opportunities for innovation and competition arising from a digital-native central bank-issued money offering programmable functionality. Nevertheless, the adoption of any CBDC is heavily dependent not only on its technical features but also on the way in which characteristics such as privacy, resilience, security, and consumer protection are built into its design and that of its accompanying infrastructure.

A UK CBDC, if implemented, with its potential as a platform for innovation as a driver of design choices, can form a vital piece of national infrastructure underpinning not only the UK’s transition to a digital economy, but also the continued attractiveness of its financial services and FinTech sectors relative to other jurisdictions. The existence of a CBDC that can be used, for example, to underpin settlement of digital asset transactions, or can have smart contracts embedded, is in itself an attractive feature and draw for innovative firms to locate themselves in the UK.

  1. National security and monetary sovereignty – At present, the US dollar is either used directly for settlement or indirectly as an intermediary currency for settlement of  88% of all FX transactions globally. Along with the degree of dollarisation (partial or full) inherent in a number of jurisdictions, and the use by most central banks of the US dollar as a reserve currency, this reliance on the US dollar enables the US to exercise a significant degree of extraterritorial economic and political power in terms of sanctions enforcement and influence. Recent events in Ukraine, and the West’s response in cutting Russia off from the financial system, have further spurred interest from many jurisdictions in exploring CBDCs for cross-border payments as a means of insulating themselves from similar situations. This in turn has incentivised the US to pick up the pace on its own CBDC explorations, particularly when it comes to wholesale CBDC which can be used for cross-border settlement (albeit with considerable negative views being expressed with respect to the introduction of a retail CBDC, and two States, Texas and Florida, passing legislation to prevent the use of any future federal-issued CBDC within their territory).

There is certainly an advantage to being a first mover, or an early adopter, with respect to CBDC. A jurisdiction that has implemented a well-designed CBDC with design features that appeal to a broad user base, and relatively open access to users outside its own borders, may find its currency in greater demand. Some jurisdictions may start to mandate payments to and from service providers in their own CBDC. If, for example, China were to do this with respect to its “Belt and Road” initiative, the consequences for uptake of its Digital Yuan CBDC and payments system – outside its own borders – would be significant, and could have knock-on effects in local economies, effectively leading to a reserve currency status in certain parts of the world. A CBDC, therefore, can have geopolitical impacts, and impacts on the monetary sovereignty of nations.

Initially, at least, CBDCs represented a reaction from central banks to proposed new forms of privately-issued digital money, most notably Meta’s (formerly Facebook’s) Diem (formerly Libra). Even as the case for CBDCs has further broadened, privately-issued stablecoins continue to pose a potential challenge for the monetary sovereignty of some central banks. A US dollar-denominated stablecoin that is made available to consumers and businesses beyond the US could quickly begin to supplant the use of the local currency, particularly in times of currency volatility or political uncertainty (a situation which can arise even in developed economies such as the UK, as the events of 2022 have shown). For the impacted central bank, this could in turn lead to a creeping dollarisation effect and corresponding loss of monetary sovereignty domestically alongside loss of confidence on the world stage – a wholly undesirable situation, by any standard (as the Bank itself notes on p28 of the Consultation). 

From an international perspective, it is becoming increasingly apparent that CBDC is a necessity for any nation-state wishing to preserve its sovereignty in determining fiscal and monetary policy in a world that will be increasingly fuelled by both privately operated, decentralised digital currencies and other types of digital assets. The exercise of sovereign power by a nation is closely linked to its ability to leverage and exert influence through its currency and how that currency is perceived and used at both domestic and international levels.

  1. Continued competitiveness of the UK’s currency on the global stage – in a world in which 68% of central banks consider it likely that they will issue a retail CBDC in the short or medium term (p34), it is increasingly likely that the form and functionality offered by a currency will become a competitive differentiator for a jurisdiction like the UK.

The UK, at present, has a world-leading financial services industry, in terms of both incumbents and new entrants/challengers, as well as FinTechs. Its regulatory environment is extremely conducive to innovation, and its common law system and ability to adapt to change at pace are the envy of many jurisdictions. However, the UK is in danger of falling behind many of its global trading partners and competitors when it comes to the transformational capabilities of new technologies, including CBDC, that are increasingly capable of influencing the balance of power in trade and finance. Whilst no technology implementation can be completely future-proof, we also observe that many of the jurisdictions that are actively experimenting with, piloting or implementing CBDCs are doing so on advanced and frontier technologies, presenting them with potential opportunities to exploit competitive advantages with respect to the capabilities and functionalities offered by their currencies and payments infrastructure.

The Bank of England has been the centre of finance for over 300 years and a well-designed digital Pound will enable the UK to maintain its position as a leading global financial centre at the cutting edge of innovation.  The introduction of a UK CBDC will have impacts and repercussions far beyond payments infrastructure. It will provide a platform for innovation that can support the UK’s transition to a digital economy. It is a fundamental infrastructure that can underpin the delivery of numerous policy objectives. Taking a forward-looking approach to policy and technology decisions will help deliver a design that is more future-proof and ultimately enable the UK to maintain a leading edge in an increasingly competitive global financial markets and FinTech landscape.

Additional Observations

In addition to our responses to the Consultation questions, and to the Annexes that we have attached, we would like to make the following observations:

Legal basis for CBDC issuance

There remain outstanding questions as to the legal characteristics and functionality of a digital Pound CBDC, as well as more granular regulatory considerations surrounding its issuances.

  1. The legal features

Firstly, the Consultation has not fully considered whether the CBDC design should be token-based (equivalent to currency) or account-based (functioning as a settlement mechanism). The ramifications of the former characteristic, regarding the dual position of digital and private/public money, requires high-level policy consideration.

Secondly, the Consultation notes that micropayments could be a driver of end-user engagement (p34). Further consideration is therefore needed as to how such fractionalisation would be reflected in the legal ownership of the CBDC.

Thirdly, the Consultation notes that programmability, delivered by PIPs, would improve functionality for end-users – for example, through the ability to implement smart contracts (p32). It is not entirely clear whether such programmability is expected to be a feature offered within the currency as an API, for example, that can be used by PIPs, or whether the implication is that PIPs could offer services involving programmable payments around a CBDC. In the case of the former, further consideration would be required as to the Bank of England’s authority for issuing programmable currency, and regulatory oversight with respect to PIP delivery of that programmability.

The Consultation also makes clear that the Bank is not proposing to introduce a CBDC that enables government or central bank-initiated programmability (p79). It is unclear as to how such a restriction might be enforced, in the long term, if the CBDC is designed to be programmable by some ecosystem participants and actors and not by others, and the extent to which such a design might erode the basis for trust amongst users should also be considered.

We would also welcome additional clarity as to how and at what level PIP-implemented programmability could exist in a system based on a single account held in a centralised ledger by the Bank of England. Would programmability in this scenario be implemented at the wallet level, and not at the base central ledger level? Would this potentially make it easier to circumvent, and potentially less useful from a functional perspective?

  1. Interoperability

The Consultation states that uniformity and trust in the safety, interchangeability and equal value of all forms of money are the bedrock of the UK’s economy (p25). Following on from this, it goes on to assert the role of interoperability as a key feature of the CBDC, in preserving the uniformity of money and in bolstering UK systemic resilience (p51). The DPF recommends that further consideration should be undertaken of the legal frameworks necessary to facilitate the interoperability of the CBDC with other forms of money (such as bank deposits, cash, e-money and stablecoins), as well as interoperability with existing domestic and cross-border payment platforms.

As the Consultation also states, a recent survey of central banks showed that 68% consider it likely or possible that they will issue a retail CBDC in the short or medium term (p34). We would strongly recommend that the Bank and HMT develop their consideration of the legal and diplomatic processes necessary to facilitate interoperability between retail CBDCs denominated in different currencies. The Bank may also wish to consider the types of forum/policy discussions that may be necessary to aid the development of a consistent framework between different jurisdictions.

For a UK CBDC to have maximum utility for people and businesses, it will need the ability to support cross-border transactions, and to maintain the UK’s currency as a competitive one on the global stage, offering an attractive platform and infrastructure for the financial services community. If lacking in the ability to support cross-border transactions, a UK CBDC may ultimately have use only within domestic UK financial services and activities, and thus put at risk the UK’s attractiveness and openness as a global financial centre. We are mindful of the explorations undertaken by the various BIS Innovation Hubs as well as private sector actors around how such interoperability bridges might be implemented in practice across different jurisdictions and their CBDCs, and would encourage the Bank to monitor these developments closely and to potentially explore the prospect of multiple solutions to these challenges, including potential private-sector solutions.

  1. Payment Systems

The Consultation states that settlement finality for any transactions must be a feature of the CBDC (p51). Integration with or amendment of the UK Settlement Finality Regulations should therefore be an area of consideration with respect to legal prerequisites to the introduction of a CBDC. The Consultation also notes that a retail CBDC could improve domestic payment system resilience by acting as an entirely new payment system that could operate outside of existing ones for CBDC-to-CBDC payments only (p36). There is also an implication that in effect the Bank will become a payment system operator. If this is the case, then further consideration is required as to the role (if any) that PIPs will play alongside the Bank in operating a new payment system, and therefore the extent to which they would be integrated into (a potentially extended version of) the Payment Services Regulation and be regulated by the Payment Systems Regulator, or whether it would be more appropriate for them to be subject to new system rules.

Additional Considerations around Regulation of PIPs

The Consultation envisages that PIPs will serve as the main interface between end-users and the CBDC, and states (p61) that PIPs participating in the retail CBDC system would be held to at least the same standards relating to financial crime as those to which regulated payment services providers (PSPs) are held today, including to prevent money laundering, terrorist financing, and fraud. This is a good starting point, although more detail is required as PIPs may operate very differently from current PSPs (e.g. authorised electronic money and payment institutions). We concur that PIPs are unlikely to require extensive prudential regulation merely by virtue of their activity in the course of providing CBDC services, given that they will not be in possession of end users’ CBDC funds, like Payment Imitation Service Providers in the Open Banking ecosystem, which therefore limits the counterparty or credit risk to customers. Nevertheless, there are some issues surrounding data privacy and due diligence which warrant further consideration.

Firstly, the Consultation states in Part D.1 that PIPs will be responsible for Know Your Customer (KYC) and Anti-Money Laundering (AML) checks, and compliance with Combating the Financing of Terrorism requirements. Further consideration is needed as to how this responsibility will be reflected in any PIP-specific regulatory framework, or whether PIPs would fall under the scope of the existing Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, and the Funds Transfer Regulation 2015.

As the Consultation recognises, such regulation serves as a source of friction between national payment systems. Therefore, the PIP regulatory regime should balance the need to prevent financial crime with the goal of facilitating more efficient cross-border payments to the UK’s economic advantage.

Secondly, we appreciate that a retail CBDC will not be anonymous, as gathering customers’ personal data is necessary for KYC / AML and ongoing financial crime prevention, detection and enforcement activities. PIP compliance with existing data protection laws can help to protect users’ privacy. However, there are additional levels of security and confidentiality which can be built into the CBDC and which should be considered further.

We also note that the Consultation proposal for PIPs to access personal data and their ability to use it for different processing purposes is stricter than UK GDPR and Data Protection Act provisions. Various legal bases available under the GDPR are excluded including the potential to process personal data where the firm has a ‘legitimate interest’ in the processing, on the condition that there are no overriding negative impacts on the rights and interests of the individual. This prevents PIPs from using data for various functions which would have a low impact on privacy – for example: training models, market analysis, protecting vulnerable customers, and compliance processing.

These functions can be beneficial to society and, as such, alternative means of providing strong privacy protections should be considered such as: giving tools to customers to ‘opt out’ of certain data processing (for example, having data processing ‘on’ by default but allowing customers to turn it off) or working with the ICO and industry on specific CBDC guidance (for example, a Statutory Code under the Data Protection Act 2018). Moreover, there remain outstanding policy questions in relation to the protection of user-generated data. Given that PIPs will need to become identity holders and verifiers, they could become potential targets of cybercrime.

It is our view that, given the Consultation’s assertion that at a minimum the standards that apply to PSPs will apply to PIPs, if we follow the “same risk, same regulatory outcome” principle then the Payment Services Regulations (PSRs) represent a good starting point for all of the above considerations, and the question of whether more or less is needed, or why a different approach might be required, should be considered in light of the potential differences that might arise from unique PIP business models and their associated risk profiles. Presumably, a PIP would also be subject to the new FCA Consumer Duty rules, as well as other principles that are broadly applicable to regulated firms.

D. Consultation Response

1. Do you have comments on how trends in payments may evolve and the opportunities and risks that they may entail?

The payments landscape is already highly digitised in nature, and this is often used as an argument against the need for the introduction of new forms of digital money – and, in particular, CBDCs. Nevertheless, it is important to note that credit, debit and charge cards (and the payments services built on these) are not themselves forms of digital currency; they are mechanisms for effecting payments using digital money, with underlying credit facilities or corresponding bank transfers. Payments apps are labelled in some jurisdictions as “e-money”; they are functionally the same as cards, creating an electronic means for transferring digital money. E-money accounts are also provided by many challenger banks and offered by payment solutions providers.

The introduction of regulatory regimes for e-money and open banking has opened up a host of opportunities for innovation in payments, as has the development and widespread adoption of near field communication (NFC) and “contactless” payments. Consumers and businesses are now able to access a wide range of payment services and to transact through a variety of channels and mechanisms.

The emergence of cryptocurrencies, and in particular the distributed ledger technologies (DLT) on which they are implemented, has also driven greater exploration of and challenge of the fundamental assumptions underpinning existing money and payments infrastructures. The development of DLT-based cryptoassets that can be used for payments and cross-border settlement represents the next evolutionary stage of digital-native money and digital payments. Digital payments built on this technology deliver near-instantaneous transaction settlement combined with a high degree of transparency and traceability.

The creation of privately-issued stablecoins, in their various forms, has further spurred interest in the public sector – particularly in light of then-Facebook’s proposed introduction of then-Libra in 2019, and the impetus this gave to central banks in terms of exploring the potential benefits, challenges and opportunities of new forms of digital-native money. Whilst it is true that, at present, the primary live use case for stablecoins remains settlement on cryptocurrency exchanges, the possibility of a new non-bank-issued stablecoin emerging and rapidly gaining widespread retail usage remains real, and has been recognised in HMT’s recent consultations on cryptoassets and stablecoins.

Privately-issued stablecoins, whether they are used as a means of payment in retail transactions, a means of cross-border settlement, a means of facilitating payment on-ledger for digital assets or for enabling smart contract execution, generally create counterparty exposure to the private issuer. The creation of a large number of private stablecoins, that are themselves not necessarily interoperable, may also lead to greater market fragmentation. There are also many undesirable effects of large-scale stablecoin use from a monetary policy perspective – including the potential for public money to be moved from general circulation and onto closed, private networks, and for private companies to (inadvertently or not) manipulate currency value through large movements in the currency or assets backing the stablecoins. Stablecoins also necessarily ‘piggy-back’ on the value and acceptance of the reference fiat currency (unit of account and store of value); the only feature of money where they could differ is as a means of payment, for example by being more convenient to use. A directly digital form of public money could be more efficient.

That said, we do also recognise the positive benefits and role to be played by stablecoins and other private issuances (e.g. tokenised deposits and tokenised e-money) in the ecosystem of new forms of digital money. The DPF actively advocates for an ecosystem of new forms of digital money that is diverse, effective and competitive, and we envisage a future in which these all coexist with CBDC and existing forms of money, playing different roles and perhaps competing on the basis of accessibility, functionality and utility. There is potential value to the Bank in engaging with issuers and supporting both the Government and private sector in exploring the use cases and benefits offered by privately issued new forms of digital money (especially those that might be backed by reserves held at the Bank) alongside its ongoing work in designing and implementing a CBDC.

The use of unregulated stablecoins and cryptocurrencies for fraudulent purposes, money laundering, terrorism financing and other criminal activities has largely been addressed by the FATF, with stringent new AML and KYC requirements introduced via local regulations such as the EU’s 6th Anti-Money Laundering Directive (6AMLD). Nevertheless, there remains potential for private stablecoin providers to replace banks and payments institutions in terms of holding value and processing transactions, and the rules governing the former are not as strict in terms of conduct or prudential requirements as they are for banks. In light of these risks, many jurisdictions, including the UK, are moving swiftly to bring stablecoins into the regulatory perimeter.

There are also consumer protection concerns associated with the widespread use of stablecoins and cryptocurrencies in payments and settlements. In the UK, under the Financial Services Compensation Scheme (FSCS), deposit-holders are currently protected to a limit of £85000 should their bank fail. Similar protections apply for other regulated forms of private money, like e-money (including in tokenised form). In contrast, the future failure of a popular stablecoin, or a crash in a widely used cryptocurrency – understandably without any form of protection scheme at present given the relative lack of prudential oversight – could have a damaging impact on financial stability, with both retail customers and businesses at risk of losing their holdings in these assets.

The extent to which these privately-issued alternatives will be adopted remains to be seen. However, central banks must be open to the risk of the market moving in this direction and equip themselves with the means of replicating the utility of cryptocurrencies and private stablecoins, so that their central and independent roles in preserving trust and confidence in the financial system remain effective. The introduction of a well-designed digital Pound CBDC would provide a central bank-backed alternative digital-native form of money, that preserves consumer protections whilst also enabling the benefits associated with digital currencies and payment mechanisms associated with them.

That said, there are indeed risks associated with the introduction of a retail CBDC:

  1. The introduction of a CBDC could lead to outflows from commercial bank deposits into CBDC holdings, resulting in lower deposit balances being held with commercial banks and hence posing challenges to the ability of commercial banks to maintain their lending abilities and role in credit creation, all other things being equal. The Bank of England has proposed that the introduction of a CBDC be accompanied by holding limits for consumers, and that the CBDC itself would not be interest-bearing – two features which would, taken together, encourage use of the CBDC for transactional purposes as opposed to stores of value.
  2. We are not, however, in favour of the prolonged long-term use of limits as a means of managing this risk. As per our response to Question 7 of the Consultation, continued use of limits to disincentivise individuals from large-scale holdings of CBDC will, in our view, only serve to disincentivise financial institutions from offering genuinely competitive account rates and services, thus ultimately distorting the market and delivering sub-optimal consumer outcomes.
  3. Furthermore, the decision to make the CBDC non-interest-bearing, whilst aligned with the treatment of cash, may in the long term prove to be a limiting factor in the Bank’s ability to propagate monetary policy decisions through the economy at pace. A number of economists have recognised the potential value of an interest-bearing CBDC. Whilst we recognise the drivers for a CBDC that is, initially at least, non-interest-bearing, we would strongly urge the Bank to consider adoption of a design that allows for future interest rate propagation, but is initially set to 0%.
  4. It is often argued that CBDCs could lead to the disintermediation of commercial banks. The Bank’s proposed “platform model”, encompassing a layer of payment interface providers (PIPs) who offer services and products based on the CBDC, is aimed at mitigating this risk (although the commercial incentives for PIPs to offer these products and services are yet to be fully understood, and this may influence the uptake of institutions applying to become authorised as PIPs and the subsequent product and service offerings). Additionally, to the extent that development of a CBDC results in greater competition from non-bank providers to fill the roles traditionally played by commercial banks, consumers could benefit as well.
  5. Introduction of a CBDC will require financial institutions, including both banks and payments market participants, to assess the impact on all of their front-to-back technology and operational infrastructure and processes. When viewed in the context of the wider wholesale review, re-engineering, modernisation and digitisation required for a successful transition to a digital economy, this is not necessarily a negative development. Nevertheless, the challenges associated with loss of data, sunk investment costs due to CBDC making previous or planned changes redundant, and general re-engineering challenges are all challenges that must be managed.
  6. More significantly, Pay.UK will need to ensure that the retail payment systems (Bacs and Faster Payments / NPA) are compatible with a retail CBDC, so as to ensure interoperability between those users that wish to pay with the CBDC vs those that want to receive commercial bank money, for example.
  7. Public trust in a CBDC is vital, in order for successful commercial uptake. Public trust can be negatively impacted, for example, by a perception that the design of the CBDC does not adequately address privacy concerns, that there are insufficient legal safeguards for privacy and autonomous control of personal finances and transactions, and that the use of features such as programmability may violate an individual’s autonomy over their own finances. Again, the Bank’s choice of certain design pathways (preserving privacy to the extent that it is preserved in the existing accounts and payments systems, and introducing a non-programmable CBDC) are aimed at mitigating these.
  8. There is also a cost associated with adopting new forms of money and payments systems, on the part of businesses and consumers. This is largely unavoidable, and uptake would ultimately be driven by the perceived value and utility associated with a CBDC and the payments functionality that it enables.

The DPF envisages a future in which multiple different forms of money – both public and private, and both those currently in use as well as new forms of digital money – coexist. Each has the potential to fill a different niche in the ecosystem and to provide enhanced consumer and business choices, arising from their different characteristics, the technical functionality that they offer, the nature of their issuers and the risk (both real and perceived) attached to them as a consequence of all of these taken together. In order for our vision of a diverse, competitive and effective ecosystem for new forms of digital money to become a reality, seamless interoperability, convertibility, and – above all else – preservation of the singleness of a digital Pound in all its varied formats, will be required. Just as bank deposits can today be converted into cash, or e-money into bank deposits, the future evolution of money and payments will require equally seamless, trusted and invisible conversion between cash, bank deposits, e-money and new forms of public and private digital money.

2. Do you have comments on our proposition for the roles and responsibilities of private sector digital wallets as set out in the platform model? Do you agree that private sector digital wallet providers should not hold end users’ funds directly on their balance sheets?

The DPF broadly agrees that the platform model as proposed by the Bank of England represents a good division of operational roles and responsibilities between the public and private sectors, in terms of providing the market infrastructure and services that are necessary for the successful introduction of a retail CBDC. Furthermore, the provision of public infrastructure on which private sector firms can develop products and services can incentivise competition and innovation in this space.

As a retail CBDC is introduced, we would expect a diverse range of firms to be able to comply with the regulatory requirements and operational standards associated with PIPs and wallet providers, leading to a diverse, competitive and innovative commercial market.

Privacy is a topic of vital importance, and must be addressed at an early stage if the public is to have trust in a CBDC. The Bank should not look to ‘cut and paste’ today’s regulations and industry best practices with respect to identity verification, but should instead consider from first principles which elements of data should be collected and shared with which parties and for which types of purposes.

In the retail CBDC design envisaged by the Bank, private sector digital wallet providers will not be liable for end users’ funds. With respect to the digital wallet provider’s responsibilities around identity, the wallet provider essentially offers its customer a safe and secure digital deposit box. The eligibility of a person to own retail CBDC is not its commercial interest. Ideally, its regulatory interests should align. Emerging standards for Verifiable Credentials, which we expect to be addressed in subsequent iterations of the Digital Identity and Attributes Trust Framework, will enable a person to establish eligibility from an independent entity and hold the Verifiable Credentials within the digital wallet. 

We are particularly heartened by the fact that private sector digital wallet provision will not be restricted to commercial banks, but will rather be opened up to a range of market participants (subject to appropriate regulatory requirements and oversight being introduced). The various business models, opportunities, products and service offerings that may emerge with respect to PIPs remains very much an unknown, and commercial banks may not be best placed – or indeed best incentivised, given the direct impact to credit creation that CBDC outflows may present – to offer these services in a competitive manner, at scale whilst leveraging the full innovative potential on offer.

We absolutely agree that private sector digital wallet providers should not hold end users’ CBDC funds directly on their own balance sheet. There is also an analogy to be drawn to the position of the commercial banks that participate in the Wholesale Cash Distribution process with the Bank. The entire objective of a CBDC is that it should be a form of public money representing a direct claim on the central bank. Should an intermediary hold the CBDC in trust or as a deposit on its own balance sheet, the CBDC would become a liability against the intermediary as opposed to the central bank, thus defeating the objective. It would also create potential confusion between forms of private money such as commercial bank money and e-money, and CBDC as public money. Finally, there is a risk that such models would merely replicate the way in which bank deposits work at present, as a lever for credit creation.

Concerns around an account-centred model

As per above, the DPF is broadly in agreement with the proposed platform model – and in particular the concept that the public sector should have a clear and defined mandate to do only those things that are within its recognised remit, with the private sector then driving innovation (although perhaps not solely responsible for managing and guiding such innovation). This approach will likely result in the most resource- and cost-efficient allocation of roles and responsibilities, as well as the most end-user-friendly outcome, if it is driven by commercial demand and imperatives.

Nevertheless, some of our members are also mindful that the proposed model, without further clarification, may be overly prescriptive, with all transactions ultimately undertaken via a centralised infrastructure, and that this may lead to potentially perverse outcomes. Specifically, these members are concerned that the primary proposal appears to indicate a CBDC model that is primarily account-based – and difficult to distinguish from a centralised (if sophisticated and very large-scale) database. Furthermore, a centralised model of this nature would not be capable of leveraging the benefits and innovative potential of distributed ledger technology and the well-documented innovative leaps that have been made in the traditional financial services sector with respect to digital assets and tokenisation in recent years[3].

A proposed alternative design might take the form of non-custodial wallets, provided by a regulated PIP, holding retail CBDC tokens that are issued by the Bank. This would not only eliminate financial risk to the intermediary (and any concept that the intermediary might hold end user CBDC funds on their own balance sheet) but also, if designed appropriately, could enable the end-user to interact with a broader digital asset and smart contract ecosystem, including private, programmable stablecoins or NFTs, for example, as these technologies become more commonplace and mainstream across the digital economy.

Ensuring successful adoption through a viable retail CBDC ecosystem

The launch of a CBDC will require the creation of a multi-party ecosystem comprising both CBDC service providers and end-users (e.g. businesses and consumers). The CBDC ecosystem will ultimately compete for market share against well established ecosystems like card networks and account-to-account payments networks. A successful ecosystem, in our view, will exhibit two key features:

  1. Innovation must be a shared responsibility between the ecosystem owner and the ecosystem partners.
  1. Joining the ecosystem must be underpinned by the ability of participants to extract value from participation.

On the first point, the CBDC ecosystem may require the Bank of England to play a bigger role in innovation. Successful ecosystems have in common the ecosystem owner being the one responsible to develop the first value added services built on top of the platform. For example, before the Apple ecosystem was open to 3rd party developers, it was Apple that developed the iPhone apps. Once the iPhone gathered a critical mass of customers, Apple could attract 3rd party developers. Ecosystems, like that of the iPhone, are characterised by ‘network effects’ whereby the intrinsic value of the ecosystem grows as the number of participants increase.

At the point at which the CBDC is introduced, the ‘network effects’ will be low, due to an initially small number of customers using the CBDC, and an initially small number of merchants accepting the CBDC. Government can also proactively help to create network effects by accepting the CBDC as a means of payment and / or disbursement of funds (for example on taxes, pensions, benefits, etc). Once the CBDC attracts a critical mass of customers, the value of the ecosystem grows as the network effects multiply, and other participants (e.g. merchants and payment interface providers) will have greater incentives to join the ecosystem, thereby increasing the value of the ecosystem as a whole. In addition to developing the first value-added services, the ecosystem owners should work closely with the ecosystem partners to ensure that the platform’s core features are aligned to the value-added services built by the ecosystem partners.

On the second point, the Bank of England, as ecosystem owner, might have a central role in designing a revenue model across the CBDC ecosystem. A UK CBDC, when introduced, will likely compete – at least to some extent and depending on the quality and appeal of PIP services offered – for customers against established means of payment, such as card payments and account-to-account payments. It is common practice in the UK that payments are free of charge for the customer. The competition from free-of-charge payments, will likely prevent PIPs from charging customers for processing CBDC payments, thus also limiting the extent to which PIPs may be incentivised to offer services. A lack of direct revenue opportunities for retail payment interface providers may present a significant barrier to adoption, which in turn may result in the CBDC not reaching an optimal level of end-customer uptake that would enable it to demonstrate benefits. Card networks have solved this problem by introducing a revenue sharing mechanism, that splits the merchant charges between the acquirer bank and the issuer bank.

We can also perhaps draw a comparison with cash, as the current form of publicly-issued central bank money available to the general public. On the withdrawal side, some ATMs are free and others are fee-charging; on the acceptance side, some smaller retailers still prefer cash given that this saves them card handling fees (albeit with handling effort required to deal with the cash). One of our members provided an example of a recent US holiday, at which they saw many petrol stations offering two prices: one for cash and one for card, and some restaurants offering up to a 6% discount for paying in cash. In this example, these businesses are actively beginning to price in the cost of card handling fees and passing these on to their clients. A retail CBDC could enable retailers to lower their overheads when accepting digital payments.  A fine (competitive) balance would need to be achieved between any fees charged against existing payment mechanisms.

However, as with the precedent of Open Banking services (e.g. account information services, payment initiation services, etc.), PIPs may be able to generate revenue through additional value-add services (such as subscription fees for features such as automated sweeps, spend analytics, etc.). Firms could also use CBDC wallets as a channel to attract deposits or investments, touting the features of their wallets and then attracting transfers from CBDC into interest-bearing deposits, investment holdings, etc., perhaps on a dynamic/automated basis with user consent. Noting the Bank’s expectation that non-financial firms might also seek to become PIPs, retailers may use this technology as a better way to understand their share of a user’s wallet, redirect users to preferred payment methods, or find value in other ways.

The potential combined effect of a lack of differentiation vis-a-vis competing means of payment and the lack of a clear business case for key ecosystem participants (i.e. retail PIPs) could result in an ecosystem that may ultimately fail to drive adoption on the part of both end-users and service providers. Something to clearly consider as part of the design.

That said, we must emphasise the crucial importance of a regulatory and legal framework around the authorisation, oversight and obligations of PIPs and wallet providers, particularly in terms of ensuring the “singleness” of and convertibility between all forms of the pound Sterling. End users should have certainty of their ability to convert, on demand and at par, between privately-issued commercial bank money / e-money / other (regulated) stablecoin representations of the Pound and CBDC / cash, and this must be supported by the necessary technical interoperability and rails between these different forms of money.

3. Do you agree that the Bank should not have access to users’ personal data, but instead see anonymised transaction data and aggregated system-wide data for the running of the core ledger? What views do you have on a privacy-enhancing digital pound?

The DPF is strongly supportive of a privacy-enhancing retail CBDC; that said, any new form of digital money should be designed such that some of the main types of crime that are plaguing the existing payment networks are reduced, if not eliminated. We agree that public trust in the retail CBDC is of utmost importance in ensuring successful adoption, and applaud the Bank for recognising this and for prioritising it as a design consideration accordingly. The central bank, as an issuer, is in a unique position in comparison with the private sector, in that it does not have a commercial incentive to collect or monetise individual transaction data. Similarly, whilst the government might have an incentive to identify or monitor individual transactions for taxation purposes or for benefits management, for example, the Bank’s narrow remit and focus on delivering monetary and financial stability policy leaves it well-placed to advocate for and to implement a privacy-enhancing retail CBDC. The time and investment spent in developing a privacy-enhancing retail CBDC could be perceived as a public good for the broader economy, as well as an opportunity for leadership on the global stage.

We imagine that the role of the Bank of England will not change in the course of introducing a CBDC. It should therefore aim to have access to the data needed for managing monetary policy and financial stability. We do not believe this requires the Bank to have access to users’ personal data. It should be noted, however, that many members of the public end-user population may not be comfortable with the Bank having access to or being able to view even anonymised transaction data and wallet holdings, given the potential that they might be subject to additional surveillance and scrutiny.

In the short term, the existence of holding limits may also help to mitigate some of these concerns, as the existence of millions of anonymised wallets holding relatively low balances would not likely be perceived as a likely vector for large-scale criminal activity, and so would be subject to correspondingly lower levels of scrutiny. Similarly, a CBDC that lacks programmability (whilst this may have downsides) does have clear benefits in terms of public trust in their control over their money and transactions.

However, money laundering and financial crime are a growing problem – globally estimated at costing between 3 and 5% of GDP.  As payment innovations develop, financial crime evolves alongside them; recently the PSR announced requirements for mandatory reimbursement from banks and payment firms with respect to authorised push payment (APP) scams. A retail CBDC must not make it any easier for any crime to take place, and ideally, should actively prevent fraud, crime or AML layering. The Bank should take this opportunity to consider why current regulations, initiated in the 1980s and incrementally revised at great cost to all parties, have been so ineffective in addressing these issues.

Today, individual financial institutions are responsible for preventing financial crime. There is no overarching governance body with responsibility for policing the unlawful use of payments systems and, as the Bank has set out in the Consultation, data protection law inhibits sharing of data between institutions. However, without sight of the end-to-end flows of payments, it is very difficult for an individual financial institution to detect suspicious patterns. The result is a costly requirement and process for financial institutions, and a poor customer experience for users.

It is important for all that the system for the CBDC should be able to identify and police misuse of the payments infrastructure without posing a risk – whether real or even merely perceived – to civil liberties and personal privacy. Technological solutions are available that can enhance privacy safeguards when people transact. However, these solutions require the rethinking of the roles and responsibilities of the various stakeholders involved in the ecosystem surrounding a CBDC, and the data to which they will require access in order to perform those roles effectively.

A new entity is potentially required, with distinct and separate governance, to oversee the safeguarding of the CBDC from misuse by criminals. The DPF’s Identity and Privacy Working Group is currently considering this subject and would happily share its outputs with the Bank as they are developed.

The Bank’s ability to access unique identifiers also feeds into the solutions to certain of the notions covered in the Consultation, for example the functioning of the limit on CBDC holdings. Without a centralised view of unique holders of the CBDC, creative solutions will be required to police the limit, in a scenario in which user identity is known only to the PIP(s) who onboard(s) them. An alternative would be a self-certification regime akin to that for ISAs, but this is unlikely to be as effective for a retail CBDC without the tax fraud deterrent, adverse tax consequences more generally, and abuse of the limits still not increasing the credit risks faced by dishonest users. However, if the limit’s main purpose is to minimise disintermediation, then the FSCS, interest rates on commercial money and honesty among the general populace should achieve most of that policy goal while preserving privacy and managing development cost.

4. What are your views on the provision and utility of tiered access to the digital pound that is linked to user identity information?

The Bank envisages in the Consultation, that tiered access to services and products around a retail CBDC could allow for different levels of user access and functionality depending on the level of identification and personal data that a user is willing or able to provide. The DPF agrees that, as part of a privacy-enhancing retail CBDC design, tiered access can not only empower individual end-users to make informed decisions about their transaction data, but also allow for the offering of entry-level services to a user base that may traditionally be excluded from the financial system due to a lack of adequate documentation.

Commercial advantages of a tiered access model

From a commercial perspective, a tiered access model could be very attractive to would-be PIPs, enabling PIPs / wallet providers to offer a competitive range of products and services to end-users whilst realising commercial benefit through the ability to monetise consumer data where this is actively permitted by the end-user. This could also open up opportunities for a range of non-bank PIPs to offer services around a retail CBDC, and the prospect of cheaper – or enhanced – wallet services for those that are willing to share more data and to specify how that data might be used.

Nevertheless, we are also mindful that this may be an idealised outcome, and there is a genuine risk that some types of firms – based on historical experiences with data collection and sharing via cookies, or complex and difficult to understand End User Licence Agreements (EULAs) – may attempt to obfuscate the true extent and intended use of the data that they collect. In this scenario, choice may be an illusion, and end-users may in fact have little choice but to accept unfavourable and undesirable terms around data collection and usage in exchange for services.

It could also result in an outcome whereby those who are either excluded from existing financial services, or on lower incomes, may be unable to control their privacy and identity to the same extent that other end-users might be able to. Conversely, there is also a need to ensure that the “lowest” tiers of users are not more susceptible to being targeted for financial crime or scam purposes. We are also very strongly of the view that the introduction of a tiered access retail CBDC should not become a platform for creating products and services that target lower income groups and vulnerable individuals, as we have seen happen with Buy Now Pay Later and payday lending. A tiered access system based on varying levels of individual identity data disclosure will therefore require careful regulation and supervision on the part of the Financial Conduct Authority, a high standard of consumer protection that is proportionate to the risk of data misuse, and clear disincentives to the misuse of data.

Tiered access and potential for fraud

Fraud vectors change over time. Electronic payments have replaced the movement of cash and cheques over time (initially for high value payments although the trend has been to ever-smaller payments). Customer demand for contactless payments is now driving out cash usage even for the smallest payment amounts. This trend is likely to continue and the introduction of the CBDC, with its close coupling of identity data and payment mechanisms, may facilitate innovations in micropayments where, for example, a person can conveniently access information on a ‘pay-per-page’ basis.

However, it is also likely that fraudsters will seek to exploit future ‘regulatory arbitrage’ opportunities. Whatever threshold is set, technology may allow fraudsters to cost-effectively split large payments into smaller and smaller amounts in order to fall below the threshold. These techniques are already employed in cryptocurrencies so there’s no reason to think the same would not be attempted in CBDC. This is a risk that must be considered as well when introducing any tiered approach to identity verification. 

Proving one’s identity should not be complex. Over time, we expect the introduction of the Digital Identity and Attributes Trust Framework to make it easier and more commonplace for people to assert highly trustworthy identity details through digital means. Inclusion is a key objective: the use of a bus pass or driving licence as the only available form of identification will diminish quite rapidly.

We should also distinguish between the process of enrollment and that of transactional authentication. During enrolment, a person establishes an identity and, in this context, their eligibility or suitability to open a given type of digital Pound account. Subsequently, the method of authenticating that the transaction is being conducted by the right person would require an appropriate level of security, depending upon the risks.

5. What views do you have on the embedding of privacy-enhancing techniques to give users more control of the level of privacy that they can ascribe to their personal transactions data?

We are supportive of measures that can provide end-users with greater control over the level of privacy that they can ascribe to their personal transaction data, provided that this is balanced with the need to ensure that a retail CBDC is not used as a conduit for proceeds of crime. Such measures, if they are to engender the greatest level of public trust and confidence, should be embedded in the technology by design and within the core publicly-run infrastructure. Notwithstanding this, we also acknowledge that it will be necessary for the Bank and the CBDC ecosystem participants to be able to access data on an anonymised or aggregated basis, not only with respect to prevention and detection of financial crime activities but also in order to monitor usage of the CBDC across the economy and as a means of designing and developing end-user products and services.

As the Bank has observed, privacy is a relative term. It is not possible to transact without an exchange of information. The more information that a person is prepared to share, the greater potential for value in the transaction. However, many firms are able to recognise and (profitably) exploit the power of personal data because its value is not always apparent to the person to whom it belongs.

Privacy enhancing techniques offer many exciting opportunities to provide people with greater control over their personal data. However, it is not the individual that makes the data ‘trustworthy’ to a third party. Open Banking has indeed been successful but that is because highly valuable bank curated data has been opened to the market for free.

Security and the creation of trustworthiness are costly. People in their daily lives seldom consider their value until a fraud vector makes them vulnerable. This allows some organisations to exploit data that is exposed to them and that they are able to aggregate.

We should not begin by discussing how one technology or another is used. Instead we should consider the roles required and which personal data are required to fulfil those roles effectively. For example, if determination of eligibility to open a CBDC account were delegated to a government certified third party organisation (such as that envisaged under the government’s Digital Identity and Attributes Trust Framework) then the PIP need be responsible for authentication only i.e. providing assurance to customers that their money is safe.

Even without the ‘real world’ identity of the account holder being known, there are arguments for and against the tracking of transactions by a PIP. Having established what a PIP can and cannot do with the personal data to which it is exposed, it is then possible to consider how privacy-enhancing techniques can or should be used. But the regulatory framework – not technology – should be relied on in the first instance to protect data privacy rights (although this does not preclude the inclusion of ‘privacy by design’ as a consideration in the technical architecture and market structure of a retail CBDC).

The DPF’s Identity and Privacy Working Group will be undertaking a review of existing Privacy by Design principles in the context of the Bank’s proposals for a retail CBDC digital Pound, and expects to publish this in due course.

6. Do you have comments on our proposal that in-store, online and person-to-person payments should be highest priority payments in scope? Are any other payments in scope which need further work?

The DPF agrees that in-store, online and person-to-person payments should be the highest priority payments in scope. In addition, we recommend that government payments should be in the highest priority from day one.

If the Bank’s intention is, at this stage, to create a CBDC that will primarily be used for retail payments, then it makes logical sense to prioritise in-store, online and person-to-person payments. That said, if retail CBDC payments are being made to businesses then either a mechanism should be devised such that all CBDC payments are swept to commercial bank accounts on receipt, or businesses should be allowed to use their retail CBDC holdings as a store of value as well as a means of payment. The Bank has also made reference to employee salaries being paid in retail CBDC; these funds would presumably need to come from their employers’ CBDC accounts.

The extent to which such payments and their supporting applications will be successful has a significant dependence on their ease of use by the end-user, and the additional utility / benefit they are perceived as offering over and above that of other payment mechanisms. A system that introduces more friction than existing forms of in-store, online or person-to-person payments – or one that does not align with the possibilities offered by initiatives such as Open Banking – will be unlikely to experience sufficient uptake. The user experience in terms of the level of seamless conversion and interoperability between existing forms of money and payments, and future systems, will also be key.

The Bank for International Settlements (BIS)[4] has analysed the three factors that might make adoption of a retail CBDC, such as the digital Pound CBDC, a success. The conclusion is based on previous implementations of payment innovations, and includes the following criteria that a given retail CBDC must, in order to be successful, deliver the following:

  1. fulfils unmet user needs; and
  2. achieves network effects; and
  3. does not require users to buy new devices.

In-store and online payments are a hygiene factor in terms of adoption. They are required if the CBDC is to provide basic convenience, without which customers would be unlikely to consider adopting it as a payment method. Every payment innovation faces a ‘chicken-and-egg problem’ whereby merchants are not incentivised to adopt the payment innovation unless there are customers using it, yet conversely customers lack an incentive to use it unless there are merchants accepting it. Person-to-person / peer-to-peer payments are an important mitigant in the ‘chicken-and-egg problem’ with respect to merchants and customers, helping to build the critical mass on the customer side, so that merchants see clear commercial benefit in joining the ecosystem.

Government payments are important to the establishment of a successful digital Pound CBDC ecosystem from two angles:

  1. Firstly, adoption of the CBDC by the UK Government, for its own payment and disbursement requirements, would bring additional credibility to the CBDC, thereby creating a sense of trust and confidence underpinning the adoption of a new form of digital money.
  1. Secondly, given the scale of users / ‘customers’ to which it has reach, adoption on the part of the UK Government could contribute significantly towards building the network effects of the CBDC, thereby breaking the ‘chicken-and-egg problem’ between the merchants and customers.

If history can be a guide for the future, two mainstream payment innovations, contactless and Open Banking, have had public sector firms as successful early live use cases. It was Transport for London that enabled contactless payments to enter onto a path of widespread adoption. Transport for London became such a symbol for the success of payment innovations that it became common to define the quest for the identification of a key use case for a payment innovation as finding ‘the TfL moment’. Similarly, HMRC has become a flagship[5] use case driving customer trust in Open Banking payments.

Additionally, there is another payment use case that could potentially be in the highest priority. This payment use case would have the objective to ‘fulfil unmet user needs’. The UK is currently lacking in a service that can enable the delivery of requests for payment in a secure channel like home banking or a banking app. In reality, such a service has been created – in the form of ‘Request to Pay’[6]; however, it is not yet provided by any bank and is not yet in use by any business. The key reasons for the failed adoption of Request to Pay include a ‘lack of business case for retail banks’ and the ‘chicken-and-egg adoption problem’. Notwithstanding this, the market itself has arguably brought a variation on this capability before the scheme, with several challenger banks including Starling, Monzo and Revolut offering a pay request feature both within their ecosystem (P2P) and as a card payment option; additionally, companies such as Comma have introduced Open Banking options for payment requests. These offerings do prove that there is a market for Request-To-Pay-like services.

In Australia[7] and Switzerland[8], Request-to-Pay-like services have achieved relative success, empirically proving that there is a market need and appetite for this service. In these two jurisdictions, the service was a market solution, meaning that the banks were not mandated to implement it as a regulatory initiative such as Open Banking in the UK. Their success may be ascribed to the role of the payment companies behind the schemes in creating the ecosystem and realising the network effects. In Switzerland, the Request-to-Pay infrastructure existed for some years prior to SIX Group merging two different Request-to-Pay ecosystems and thus building a larger and more solid base for network effects. In Australia, the BPAY company was successful in convincing banks and large utilities to join the ecosystem from the beginning[9], thereby realising the network effects from the start. The ability of a CBDC to support Request-to-Pay-like services could help to differentiate the CBDC – in the minds of consumers – from bank deposits, thereby helping to attract customer adoption.

7. What do you consider to be the appropriate level of limits on individual’s holdings in transition? Do you agree with our proposed limits within the £10,000–£20,000 range? Do you have views on the benefits and risks of a lower limit, such as £5,000?

The Bank of England has clearly stated its reasons for introducing limits on individual holdings of a CBDC within the Consultation; namely, to mitigate the risks of bank disintermediation (and hence any potential impact on credit creation) in the course of introducing a CBDC, and to create a window for gathering data on user behaviour, and understanding the demand for a CBDC and its potential impact on the wider economy. The DPF is supportive of this proposed approach when rolling out a CBDC, and we are of the view that the higher limit of £20,000 would better support the Bank’s learning objectives during a transitional period. We think that a lower limit, such as £5000, may deter some users from making full use of a CBDC and would be unhelpful in achieving the aim of understanding the impact of a retail CBDC on consumer behaviour, financial institutions and the economy.

Some of our members expressed concern that a £20k limit might actually be too low, giving the example of NS&I premium bond holdings, for which the limit is £50k per individual. There are no similar concerns raised at the prospect of disintermediation of bank and building society savings accounts as a consequence of this. On the other hand, NS&I is a savings product, and so faces a different set of trade-offs to a retail CBDC which would be primarily intended as a transactional product, and if NS&I were a new product that was introduced today, the macroprudential regulator would probably want to phase it in gradually to manage any potential impact on financial stability.

It can also be argued that most individuals in the UK do not have savings levels that would cause the levels of disintermediation that are envisaged with respect to the introduction of a retail CBDC. Others observed that a digital-native retail CBDC, with effectively zero cost to acquire, does potentially lead to the risk of accumulation by speculators and a potential break of parity (and the “singleness” of the pound Sterling across its different forms).

Members proposed consideration of alternative solutions that might equally or better address the same risk, such as:

  • The introduction of overall limits to retail CBDC issuance, similar to those used for notes and coins in circulation.
  • Disincentivising higher holdings with a charge on holdings above a certain limit (i.e. a form of negative interest rate, similar to what commercial banks have done to EUR and JPY business deposits above a certain amount during negative interest environments).

However, having a vector such as a retail CBDC might increase the ease – and therefore risk – of large-scale runs when there is next a more general loss of trust in the banking system. Whilst lining up at a bank or ATM to withdraw cash has intrinsically limited throughput, and can provide more time for the bank and its supervisors to find an orderly solution, recent banking crises have been accelerated by customers’ ability to transfer their balances to “safer” banks at the touch of a button. During a more systemic event, a no-limit CBDC could make it easier and more likely for large-scale, high-velocity withdrawals of funds from the banking system to occur. Conversely, this systemic loss of trust is something that the current deposit guarantee schemes have been designed to address, and for which purpose they so far appear to remain a useful tool.

Perhaps more pertinently, the bank deposits and e-money holdings of individual consumers are guaranteed to the level of £85,000 through the Financial Services Compensation Scheme (FSCS), enhancing trust in the current commercial banking system.

Guaranteed deposits and physical cash are probably more accessible to most members of the general public than are gilts. It is worth noting, however,  that the availability of such relatively low-risk assets has not been shown to create, or to exacerbate in such a way that the Bank is not confident of being able to mitigate, financial instability in the banking sector, nor has it led to any disintermediation of commercial banks. A future area for navigation may involve the education of customers about there not being any real need to move (large) deposits below the FSCS limit into CBDC. (We qualify “large” in this way to give some spending runway while the FSCS pays out – some small CBDC holding may still make sense for that reason.)

We are also mindful that the introduction of limits may have a critical role to play in the viability of the early CBDC ecosystem, and this should also be a guiding principle in any consideration or discussion of limits. Whilst limits might not ultimately be the most necessary or effective means of preventing and managing financial instability, the existence of limits may be a crucial vector in obtaining support from financial institutions and banks for a retail CBDC.

Should incumbent financial institutions perceive a retail CBDC as a threat to their business models and to their firms’ financial stability, they might actively resist its introduction. In a worst-case scenario, they might desist from becoming PIPs (unless mandated to do so as part of their regulatory authorisation requirements), or from providing rails between their own infrastructure and that of any PIPs (thus posing a threat to a singleness of the pound Sterling). Given the scale of their activities and the extent to which they have an overwhelming share of the market captured today, this would ultimately make the retail CBDC ecosystem unviable. That said, in reality, banks normally charge businesses for their accounts and banking services, and most retail CBDC transactions would likely involve a business. Additionally, even if the incentives are low, it is unlikely that banks would want to be “left out” of the CBDC ecosystem.

Challenges around the enforcement of limits

We also note that there are logistical and operational challenges with respect to the Bank’s ability – or the ability of any individual PIP or wallet provider – to enforce such limits across an individual’s CBDC holdings, particularly where that individual may have multiple wallets across different PIPs. If the Bank is to remain unaware of the wallet owners’ identities, then would each wallet provider need to share, or request, information around other wallet holdings, or to somehow monitor balances collectively across other wallet providers? This does not seem feasible in practice.

Operational and technological solutions do exist, although these may ultimately sit at odds with the Bank’s stated intentions around preservation of user privacy. For example, one option might be for the Bank’s central ledger to associate different wallets held with different PIPs, with a single (aliased) identity; this would, however, appear to defeat the privacy objectives and protections documented by the Bank in the Consultation. However, building on our point around alternative solutions above, if CBDC were to be limited by central issuance value as opposed to individual holding limits, then this issue largely goes away.

Limits in the long-term

In the longer term, however, we are of the view that there should be no need for a holding limit for individuals, as we believe that the market should and will find its own equilibrium. A CBDC may compete against other forms of money, most notably commercial bank deposits, but there are well-established terms on which commercial bank accounts compete with public money in the form of cash holdings today. These include – most significantly – the interest-bearing nature of deposit accounts, which offer the most direct financial incentive to consumers, as well as other services and products based around deposit holdings.

In the long term, continued use of limits to disincentivise individuals from large-scale holdings of CBDC will, in our view, only serve to disincentivise financial institutions from offering genuinely competitive account rates and services, thus ultimately distorting the market and delivering sub-optimal consumer outcomes.

8. Considering our proposal for limits on individual holdings, what views do you have on how corporates’ use of digital pounds should be managed in transition? Should all corporates be able to hold digital pounds, or should some corporates be restricted?

The introduction of limits for corporates may have a significant impact on the extent to which consumers are motivated to adopt a retail CBDC. Businesses should be able to accept CBDC payments from retail clients, and to pay out refunds and rewards in the form of CBDC as well. With respect to B2B transactions, businesses also need to be able to spend the CBDC holdings that they accumulate through taking payments, and payments to suppliers would/could be a key use (tied in to more efficient supply chain management through the use of programmable money / programmable payments, for example). An interest-bearing CBDC could provide a solution to disincentivising significant holdings; if necessary, negative interest charges on corporate balances above certain thresholds could be considered, to incentivise conversion to commercial bank account holdings.

The case becomes less clear when we consider high-value transactions and settlements between corporate treasuries and financial institutions, for example. This is an area that certainly warrants further exploration, modelling, data gathering and analysis on the part of both the Bank and corporates as well as financial institutions. We echo our response to Q7 above – that in the longer term, we are of the view that there should be no need for a holding limit for corporates, as we believe that the market should and will find its own equilibrium.

On the second part of the question “Should all corporates be able to hold digital pounds, or should some corporates be restricted?” We believe that all corporates, including both financial and non-financial corporates should be able to hold CBDC. One of the key reasons, as identified by the Bank in the consultation paper, is that both financial and non-financial firms have the need to make retail-like payments (e.g. payment of wages to employees). The other key reason for the requirement of financial and non-financial firms to hold retail CBDC derives from the issuance and distribution model. One of our DPF members, Accenture, has analysed different models of issuance and distribution of CBDC (e.g. one-tier, two-tiered and mixed-tiered) and in all the models the issuance of CBDC occurs against reserve balances. Once the retail CBDC has been issued, it can be distributed to end-users in exchange of bank deposits[10].

The issuance and distribution of a retail CBDC requires that the CBDC can be held by PIPs, which may be either financial or non-financial firms. Sweden’s Riksbank has tested a two-tier distribution model “where the e-krona, like the model with physical cash, are distributed from the Riksbank to the general public via approved participants in an e-krona network. […] The participants in the network operate nodes and can order e-krona from the Riksbank which are debited from their reserves in the Riksbank’s settlement system, RIX.”[11]

9. Do you have comments on our proposal that non-UK residents should have access to the digital pound, on the same basis as UK residents

We view the question of whether or not non-UK residents should have access to a UK retail CBDC on the same basis as UK residents, as one having both policy and regulatory / technical considerations associated. From a policy perspective, for example, a key motivation for introducing a retail CBDC might include maintaining the competitiveness of the UK’s currency on the global stage, and making it an attractive means of exchange between UK and non-UK residents. In Annex 1 to the Consultation, however, the Bank considers that “widespread use of non-sterling digital money could compromise the UK’s monetary and financial sovereignty”; it would not be surprising if the governments and central banks of other jurisdictions felt similarly, and put in place restrictions or disincentives for their own public to access such forms of money.

The Consultation states that: “non-UK resident individuals would be able to hold and use digital pounds when visiting the UK (for example, as tourists), and when outside the UK for payments with either a UK or non-UK resident. To ensure consistency and equal treatment, non-residents’ holdings of digital pounds would be on the same basis as residents.” This implies that holding limits will also apply to the CBDC holdings of non-UK residents. It is not, however, clear from the preceding text as to whether 1) the individual is envisaged to be located outside the UK and the holding is envisaged to be located within the UK, or 2) the individual and the holding are both envisaged to be outside the UK. We would envisage implementation to be significantly easier if option 1 is the correct assumption. Nevertheless, we have also considered option 2 in our response to this question.

The Consultation also considers that non-resident access would involve two requirements:

  1. A recognition regime to determine which non-UK PIPs and ESIPs could offer digital Pound CBDC wallets and other services, and
  1. The ability for the UK authorities to withhold access to the digital Pound CBDC from residents of high-risk jurisdictions, for example, those flagged by FATF as having weak AML / CFT regimes. 

From a regulatory and technical perspective, this suggests that there are a number of considerations that will need to be practically addressed if access to a digital Pound CBDC is opened up to non-UK residents located outside the UK:

  1. The extent to which their own jurisdiction’s local legal and regulatory framework permits them to hold the currency of another jurisdiction, or any local restrictions on such holdings (analogous to, but potentially different from, the Bank’s proposed holding limits).
  1. The extent to which the non-resident’s jurisdiction permits the provision of cross-border services by UK-based and UK-authorised PIPs and ESIPs, and the impact of local compliance requirements on these (e.g. FATCA).
  1. The existence of local PIP and ESIP equivalents, which would not only require the aforementioned recognition regime to be in place, but would also require access to the Bank’s own infrastructure and central ledger if they are to truly perform the equivalent functions of UK PIPs and ESIPs (enabling option 2 as envisaged above).
  1. The ability of the UK authorities to exercise equivalent powers with respect to prevention and detection of financial crime, and any enforcement procedures associated with foreign residents having access to a UK retail CBDC.

From the perspective of other jurisdictions, the ability for their own public to access a UK CBDC could lead to concerns around the equivalent of “dollarisation”, in which a foreign currency becomes more prevalent and in more widespread use across the economy, leading to an unwelcome loss of local monetary and financial sovereignty.

Our view, in light of these many considerations, is that while a digital Pound CBDC should be capable of being offered to non-UK residents, this may not necessarily be desirable in the early stages of rollout and adoption. In any case, the extension of the user base to non-UK residents who are not located in the UK should be accompanied by a carefully designed and controlled series of trials and pilots with ‘friendly’ jurisdictions, through which the governance, framework, controls and operational logistics can be explored, tested and proven.

10. Given our primary motivations, does our proposed design for the digital pound meet its objectives?

The Consultation states that two key policy outcomes have driven the development of its proposal around a retail CBDC:

  1. Reinforcing public trust in UK central bank money as an anchor of monetary stability, and;
  1. increasing innovation, competition and choice in the UK economy.

The DPF agrees that a widely available retail CBDC will help to protect the uniformity of money in an environment where people are increasingly interacting with privately issued forms of money, digital currencies and digital assets. The Bank’s design choices leave space for privately issued money in various forms, including stablecoins, to coexist alongside a UK retail CBDC, which we see as also helping to meet the objective around increasing innovation, competition and choice in the UK economy. However, if the Bank’s motivation is also to ensure frictionless convertibility with both existing and future forms of money (and potentially assets), then we believe that there is a risk in pursuing a technology design and platform that is insufficiently future-proof, or becomes outdated as the industry continues to innovate. In the longer term, this could hamper a retail CBDC’s role as a platform for innovation.

It is vital that the choice of technology promotes – rather than constraining – innovation. We therefore urge the Bank to consider more closely the technological developments in progress across the industry – and globally – and to take into account the primary technologies underpinning such innovation that are emerging, particularly with respect to digital currencies, digital assets, and the evolution of financial services and products more broadly (in areas such as tokenised bond issuances, and derivative contract automation using smart contracts, for example).

Following on from our response to Question 2 of this Consultation, an additional risk arises from the pursuit of an account and API-based model, in that it misses an opportunity to encourage the banking and financial system to replatform and innovate at a more fundamental level, leveraging the opportunities afforded by a retail CBDC that offers a genuine platform for innovation as a foundational piece of market infrastructure. This could also result in an ultimately superficial improvement in competition, whereby a proliferation of wallet providers end up offering a very thin layer of the value chain, but are unable to provide genuine competition to incumbent commercial banks.

It is our view that some of the alternative design models included in the Consultation can provide an enhanced platform for innovation, and the potential to offer capabilities and benefits to end-users, PIPs and the Bank. In particular, the current proposal does not leverage the potential and opportunities of frontier technologies such as DLT. Without the potential for genuine innovation and wider support of the digital-native ecosystem that is presented by DLT, there is a risk that a CBDC platform will lack sufficient utility or differentiation from other payment systems, which may at worst hinder the UK’s adoption of Web3, digital assets and digital-native financial services. In order for a CBDC to be truly successful, it must provide more than is possible with today’s payment systems, as well as providing a platform for innovation. In our view, DLT offers the opportunity to create new financial infrastructure that can help to future-proof the UK’s infrastructure for payments and value transfer, and open up wider opportunities for the UK.

11. Which design choices should we consider in order to support financial inclusion?

It is important to distinguish between financial inclusion and digital inclusion. Digital inclusion is both a policy and a technological issue. The ability for a broad swathe of the general public to have access to a retail CBDC will ultimately have a significant dependence on the extent to which digital inclusion is embedded in the design and delivery of a retail CBDC. Digital inclusion can be solved through a policy commitment to delivery (for example, through the concept of ‘internet as national infrastructure’) as well as ensuring that a retail CBDC may be technically accessible through a range of devices, including potentially cards and wallet hardware devices, as well as through the implementation of proportionate offline payment solutions.

Financial inclusion, on the other hand, is not a technological problem; it is a policy challenge, and one that manifests through operational and regulatory constraints, and a lack of clear commercial incentives and imperatives. Regulatory obligations on financial institutions for KYC / AML create significant costs. For some demographics, these costs outweigh the commercial incentives of the financial institution. A further regulatory obligation to provide ‘Basic Bank Accounts’ compounds the problem and shuts out specialist providers that wish to focus on the financially excluded. As suggested previously in this response, a retail CBDC presents an opportunity to rethink a more cost effective approach to KYC / AML. The reduction of regulatory barriers to entry for digital wallet providers will allow more demographics to be served with commercially viable financial services.

In a relatively sophisticated market such as that of the UK, obstacles to financial inclusion also exist in terms of certain consumers’ inability or ineligibility to access financial services due to their individual circumstances. These could involve a lack of official documents or proof of identity / address needed to pass KYC / AML on-boarding checks in order to open a bank account, for example. One financial institution specialising in the financially excluded overcomes these problems by using an informal, telephone based ‘vouching’ system in which a local benefits office validates personal data asserted by the customer. The government has written guidance on how to accept a vouch but no formal vouching service has been developed as yet, to our knowledge. However, the ability for all people in the UK to be able to assert trustworthy identity information is a critical success factor for the Digital Identity and Attributes Trust Framework

Over time, such obstacles build upon themselves, as someone who is unable to access basic financial services finds themselves absent a credit rating, which in turn impacts their housing and employment prospects, creating a self-reinforcing vicious cycle.

It is important to note as well that financial inclusion is not only a socio-economic challenge but also one that impacts any highly mobile population. Recent immigrants, for example, may lack access to the required documentation. The self-employed may lack access to the same documentation in the terms of payslips and proof of income that are required to access loans and credit. Banks and other financial service providers may also lack the commercial incentives or risk appetite to provide services to these types of customers. None of these barriers is fundamentally of a technological origin or nature.

In terms of how a retail CBDC might be designed so as to promote greater financial inclusion, we therefore see the key considerations as being around:

  1. The requirements for KYC / AML and on-boarding of end-users by PIPs, and the extent to which these will accommodate customers who are currently unable to access traditional financial services for all of the reasons mentioned above.
  1. The incentives – whether regulatory or commercial – that will be created for PIPs to offer services and business models that include those financially excluded by the current banking model.
  1. The potential for a government-sponsored or public sector-operated PIP or service provider to focus on those customers that would not normally hold commercial appeal or be within the risk appetite of financial service providers (given their constraints when it comes to said KYC / AML processes and the types of documentation accepted).
  1. The need to investigate potential means to reduce digital exclusion / improve digital inclusion, and to enable those that are currently cash dependent to be able to utilise CBDCs as a reliable and secure form of transactional public money.

The potential for enhanced public policy delivery via a retail CBDC is enormous; delivery of benefits and other payments to beneficiaries could be made easier, cheaper and more effective through an accessible, inclusive wallet offering. To that end, we believe that there may be genuine value in exploring Option C above.

12. The Bank and HM Treasury will have due regard to the public sector equality duty, including considering the impact of proposals for the design of the digital pound on those who share protected characteristics, as provided by the Equality Act 2010. Please indicate if you believe any of the proposals in this Consultation Paper are likely to impact persons who share such protected characteristics and, if so, please explain which groups of persons, what the impact on such groups might be and if you have any views on how impact could be mitigated.

As per our response to Question 11 of this Consultation, a UK retail CBDC that is exclusively accessible via smart phones and devices could be less accessible than cards/cash for elderly people, blind people and those with learning difficulties or reduced cognitive capacities. That would need to be managed, and an important mitigant is the commitment to retain bank notes for as long as there is public demand for them.

E. Technical Working Paper – Discussion Question Responses

1. Do you agree that these six considerations[12] are foundational technology considerations for CBDC? Are there additional or alternative technology considerations that the Bank should be focused on? (Section 3)

We are generally in agreement that the six considerations identified by the Bank are foundational ones for a CBDC – albeit with the caveat that the performance objective of 100,000 tps is significantly higher that would be needed in the context of any current national volumes. As a long term target with headroom to scale to, it makes sense (the system may be in service for 20-30 years); nevertheless it may be quite onerous as a requirement for an initial deployment, and may lead to very high initial costs. A design that can plausible scale to that level may be a sufficient requirement, with an initial deployment in the 5000-20,000 tps range.

2. Which privacy-enhancing technologies, or other privacy mechanisms, might support the proposed policy objectives, and how might they be used? (Section 3.1)

We would advocate for data minimisation, as a baseline privacy-enhancing technology, to be applied to any CBDC technology implementation. This would effectively meet the majority of the Bank’s stated objectives and requirements around privacy. When collecting personal data during end-user onboarding KYC and AML checks as well as on an ongoing transactional basis, PIPs and ESIPs should ensure that the data collected is limited to that required for these specific purposes, and furthermore that it remains under the control of the relevant PIP or ESIP. The regulatory regime around authorisation and supervision of PIPs and ESIPs should include requirements around the collection and management of this personal and transactional data. There would not appear to be any requirement or justification for this data to be captured on the Bank’s ledger or within the CBDC public infrastructure, which would only contain anonymous / aliased transactional and aggregate data, controlled by the Bank.

Beyond data minimisation, the choice and application of privacy-enhancing techniques will likely depend on the Bank’s own privacy requirements with respect to anonymous / aliased and aggregated CBDC data. With respect to more sophisticated methods such as blind proofs and zero-knowledge proofs, these must be considered carefully in the context of the Bank’s privacy requirements around the CBDC, as they would have a significant impact on the complexity and performance of the CBDC system and infrastructure.

Personal data can be provided with a proof using selective disclosure. In order to be compatible with offline use cases, the solution for personal data sharing needs to take into account the performance constraints in terms of space and speed. An interesting initiative that is worth following is the Ethereum Attestation Service (EAS). The EAS is open source and free for creating, verifying, and revoking on/off-chain attestations. It is available today and focuses both on usability, with various human friendly tools, and performances. Attestors can selectively disclose parts of their attestations without revealing the entire attestation data. This allows for greater control over the information being shared, while still providing the necessary proof or verification for specific payment use cases.

PET techniques like group signatures permits unlinkability between two payments; it is a method for allowing a member of a group to anonymously sign a message on behalf of the group. Given two messages and their signatures, it cannot be understood whether the signatures were from the same signer/payer or not. It permits some optional traceability by the group manager (e.g. the PIP). Interestingly, it allows coalition resistance i.e. colluding members cannot hide from the group manager.

The role of testing

The DPF considers it very valuable to test, at a practical level, how technologies might be applied to meet the Bank’s policy objectives. The Bank is already progressing such work but there are many questions to be answered and the decisions taken as a result will have a great impact.

To conduct testing properly requires time and effort, which must be funded. It is in everyone’s interests to create a structure through which the public and private sector can work together to enable testing projects that answer the Bank’s questions and are funded by stakeholder organisations that have an interest in knowing the feasibility of alternative approaches – and engaging with the Bank to promote them.   

Such a process should be conducted openly but allow Intellectual Property to be developed and retained by those participating. Open collaborations are performed in other areas of technology where there is shared communal benefit. The contractual frameworks used in these contexts could be repurposed by the Bank.

We believe that a public-private collaboration, or series thereof, to further explore and develop the Bank’s specific technology and design questions and considerations would be the best way to accelerate the design of a retail CBDC. Such a collaboration might, for example, take the form of a sandbox environment in which these design options can be safely explored in conjunction with private sector participants. The DPF would be willing to open a discussion with the Bank on how it might collaborate or facilitate this process with wider industry and ecosystem. In particular, some of our members would be keen to explore the possibility of creating a framework through which, during the CBDC design period, stablecoins issued in the UK by UK regulated institutions and backed by reserves held at the Bank might be a means of proving the design of a CBDC, and exploring the associated use cases and impacts to the payments ecosystem.

3. Are the provisional requirements and metrics discussed in the paper, particularly for uptime, transaction throughput and transaction speed, realistic and appropriate? (Sections 3.3 and 3.4)

DPF Response:

As per our response to Question 1 above, the proposed transaction throughput to be supported at launch is very high and possibly unrealistic in the context of both current transaction volumes and the current state of the art. We view both the proposed uptime and latency requirements as being sensible.

4. Are there other significant components or activities that the Bank should consider in designing a CBDC? (Section 4)

Additional significant components and activities that the Bank should consider include:

  1. Transaction history data, and the policy around access to such data for the purposes of preventing and detecting financial crime. Given the possibilities for de-anonymisation of pseudonymous transaction data when combined with other datasets, the uses and access to the data should be carefully considered.
  1. Alias services and PIP level mapping of users’ other accounts (e.g. cards, bank accounts) for interoperability purposes, and how these might work in practice.
  1. The process of conversion from commercial bank money to CBDC for consumers, and how the distribution (and any remuneration / charging models), will be important, along with the design of the conversion – i.e. a real time, transaction by transaction conversion model may present different opportunities and risks than a periodic (perhaps netted) model.
  1. Integration and interoperability with existing retail payment systems (e.g. FPS / NPA and Bacs).

5. Are there alternative models that might better address the technology considerations and technical requirements outlined in this paper? (Section 4)

We appreciate the attention drawn by the Bank to the various considerations around design and implementation of a CBDC. In our view, it is of paramount importance to consider design principles in context of the specific aims, usages and requirements associated with a CBDC, ensuring that form follows function. Furthermore, these aims, usages and requirements for a CBDC should be forward-looking and should seek to encompass support not only for greater innovation in the payments space, but also to enable wider adoption and innovation in other emerging technologies such as distributed ledger technology (DLT)and the internet of things (IoT).

It is our view that some of the alternative design models included in the Consultation can provide an enhanced platform for innovation, and the potential to offer capabilities and benefits to end-users, PIPs and the Bank. In particular, the current proposal does not leverage the potential and opportunities of frontier technologies such as DLT. Without the potential for genuine innovation and wider support of the digital-native ecosystem that is presented by DLT, there is a risk that a CBDC platform will lack sufficient utility or differentiation from other payment systems, which may at worst hinder the UK’s adoption of Web3, digital assets and digital-native financial services. In order for a CBDC to be truly successful, it must provide more than is possible with today’s payment systems, as well as providing a platform for innovation.

DLT offers the opportunity to create new financial infrastructure that can help to future-proof the UK’s infrastructure for payments and value transfer, and open up wider opportunities for the UK. The proposed technology model places a significant burden on the Bank as both gatekeeper to maintenance and future innovation of the CBDC platform, as well as a significant cost of ownership. DLT as a model can share some of this cost and burden across multiple market participants. It also brings with it an inherent resilience that arises from the absence of a single point of failure, that is lacking in highly centralised infrastructures. This type of resilience is critical when we consider that a retail CBDC may ultimately become in effect a cash replacement, and the risk that can arise from a high dependency for payments coupled with the need for a single party to approve peer-to-peer wallet transactions.

Additionally, DLT, combined with the smart contracts functionality afforded by it, could enable new ways of interaction between ecosystem participants and the ledger, and even the potential to “roll back” chains of transactions should the need arise. Careful consideration would need to be given as to whether such features could / should be built into the core contract (the CBDC itself), and to who would ultimately be responsible for arbitration and remediation in such circumstances – the PIPs, the Bank, or other regulatory bodies?

6. Other than those described in this paper, are there additional important factors to consider related to ledger design? (Section 4.1)

Additional factors to be considered include upgradability, extensibility and future-proofing. The high specifications in the requirements for a CBDC and its infrastructure, and the consideration of frontier and emerging technologies such as DLT, may mean that relatively nascent technologies are in use from the outset, and the upgrade and further development of ledgers, smart contracts, database technologies, etc – while the system is running under load – will likely be needed more than once (and possibly on a continuous and cyclical basis) during the system’s operational lifetime.

7. What are the most appropriate approaches or technologies for collecting and analysing aggregate transaction data? (Section 4.2)

In terms of collection, ideally transactions should be streamed in real time to a data repository, which is not inline with operational data flows (i.e. along the lines of the old SWIFT Y-Copy operation). Operations that impact the live databases / ledgers to gather data should be avoided, as they create periodic spikes in load and could affect system performance or reliability.

8. Do you agree with the need for aliases (both well-known and disposable)? If so, should the alias service be hosted as part of the Bank-managed infrastructure, or should it be distributed across the CBDC ecosystem? (Section 4.3)

Aliases will very likely be needed to preserve privacy, and while new aliases will be created by PIPs at account creation, the alias service could be entirely decoupled from the CBDC ledger itself (though with the same non-functional requirements). When considering broader requirements around interoperability, it is worth considering the potential for these aliases to be utilised across other payment systems, to ensure that a CBDC can fully and seamlessly interact with other payment systems.

Given that a failure in the alias service will effectively be a failure of the CBDC service, it would need very high uptime and performance, and this may be a burden which should not be imposed on PIPs.

A failure on one PIP’s infrastructure should not result in customer service issues for other PIPs (i.e. when they are unable to make a payment as an alias cannot be looked up), and it is our view that any alias service should be decoupled from the PIPs and run either by the Bank itself or by another service provider or utility with a proven track record of operating highly available platforms.

9. What features would a CBDC API require to enable innovative use cases? (Section 4.4)

Careful consideration needs to be given to the “innovation perimeter” between the Bank and supporting PIPs in the retail CBDC ecosystem. An API alone may be insufficient to ensure the outcomes envisaged by the Bank, and a scenario in which innovation is driven and managed primarily by the PIPs themselves may lead to significant market fragmentation. Common primitives or “building blocks” beyond the currently envisaged Programmability and Alias service may need to be provided by the Bank. Examples of these could include:

  • Streaming and rules based payments.
  • Earmarking / locks, including third party locks.
  • Pre-authenticated request-to-pay and request-to-lock flows.
  • An open offline payments enablement API.
  • Fast, possibly real time conversion to other forms of money.
  • Compatibility with Open Banking APIs.
  • (Authorised) account balance monitoring to provide input triggers for programmability.

10. Do you agree with the suggested list of devices for making payments with CBDC? (Section 4.5)

The DPF agrees with the Bank of England’s proposed list of devices to be supported for making payments with CBDC. It is ultimately frictionless customer experience, accessibility and security that are key determinants of end-user and merchant adoption. Merchants should not be required to invest on new devices in order to accept CBDC payments, as this would essentially create cost and resource barriers to merchant adoption. From a merchant perspective, the CBDC should be compatible with existing Point of Sale (PoS) and mobile Point of Sale (mPOS) systems and solutions. 

From a customer perspective, it would be desirable for the CBDC to be compatible with widely used and trusted devices, including but not limited to smartphones, tablets, computers and cards. Nevertheless, we note that whilst integration with existing card and contactless terminals is likely possible, it would also be complex to implement, and very time-consuming. QR codes could eventually become a more ubiquitous method of use for physical payments, as consumers are gaining familiarity with paying by QR from supermarket loyalty apps and some other retail use cases.

11. How viable is it to enable interoperability between CBDC and other forms of money using existing payments infrastructure? (Section 4.6)

Interoperability between a retail CBDC and other prevalent forms of money will be fundamental for the viability of the CBDC ecosystem. When a retail CBDC is initially introduced it will compete with other forms of payment on ‘network effects’. The value of an ecosystem is, to a significant extent, a function of how many participants are in the ecosystem. In payments terminology, this is usually described as ‘reachability’ – the size of the customer base associated with a specific means of payment. A ‘network effects’ competition between a retail CBDC and bank deposits would likely be largely favourable to bank deposits, in the early days at least, due to the established network of users of bank deposits, thus deterring users from widespread adoption of a retail CBDC. A strategy of enabling – or even mandating – interoperability between a retail CBDC and bank deposits could avoid competition between a retail CBDC and bank deposits on ‘network effects’ only (note that they may still compete on relative attractiveness in terms of functionality, use cases, interest payments etc).

Interoperability between a retail CBDC and other forms of fiat money – both traditional and digital-native – may be achieved by having one or more institutions that are participants in both the retail CBDC ecosystem and infrastructure as well as being participants in other payments systems and infrastructures. Faster Payments, for example, is the real-time account-to-account payment scheme in the UK. Enabling interoperability between a retail CBDC and Faster Payments would require the existence of an entity that is both a member of the retail CBDC ecosystem (most likely as a PIP) as well as being a member of the Faster Payments scheme. This entity would need to be integrated with the infrastructures of both the retail CBDC and Faster Payments Scheme, and would need to be able to hold both CBDC and “traditional” central bank reserves.

We see two options for such an interoperability entity. They are not necessarily mutually exclusive, and indeed Option 1 might, for example, be a precursor to Option 2:

  1. The Bank of England – the Bank itself could act as the entity exchanging retail CBDC with traditional central bank reserves, and integrating with the Faster Payments infrastructure. This option removes the need for an intermediary to provide the interoperability service.

The absence of a requirement for an interoperability intermediary has three distinct advantages. Firstly, the interoperability service could be provided free of charge as a public utility. Secondly, there is no requirement for a third party private sector intermediary to hold digital Pound funds (see Question 2 of the Consultation). Thirdly, the existence of a willing third party private sector interoperability provider may not be guaranteed from Day One, due to the potential lack of revenue generation opportunities and firm business case for would-be PIPs in the early stages of retail CBDC rollout and adoption (a common pattern of adoption in all payments innovations) – whilst the very introduction of interoperability could help to overcome some of these adoption challenges.

  1. Pay.UK – as operators of the main retail UK Payment Systems (FPS/NPA, Bacs & ICS), Pay.UK should have a responsibility to ensure that interoperability is present so that CBDC can be exchanged into existing forms of money across the network and vice versa.
  1. Financial institutions – one or more appropriately authorised third party private sector firms could act as the entity/entities exchanging retail CBDC with bank deposits. This interoperability model requires a commercial arrangement between the PIP(s) and the financial institution(s) providing the interoperability service. The commercial agreement would be a sponsoring arrangement for the PIP to have ‘indirect access’[13] to the payment scheme through the financial institution The PIP would be subject to the eligibility criteria defined by the financial institution and would be charged for the service.

Looking at both options at a high level, it seems that the only commercially viable option in the early stages of rollout and adoption would be for the Bank of England to act as the interoperability entity; however further analysis might change this initial conclusion. For example, if UK commercial banks are mandated to provide wallet and other services with respect to the CBDC, and / or to offer conversion on demand and at par between bank deposits and retail CBDC, this would eliminate the need for a dedicated intermediary / intermediaries to provide the interoperability service. Since in this scenario, UK commercial banks would be both members of the retail CBDC ecosystem as PIPS, as well as being existing members of the Faster Payment Scheme, they would be able to act as the bridge between the retail CBDC and bank deposits.

12. Is programmability and smart contract functionality an important feature of a CBDC system? If so, what is the best approach to enabling such functionality? (Section 4.7)

We see significant potential for CBDCs, and other new forms of digital money, to revolutionise the payments landscape as we know it today. The availability and functionalities of emerging technologies provides the central bank and the wider supporting network, predominantly PIPs, with an opportunity to add value through innovation. Value is key here; not offering features over and above those currently available through traditional payment mechanisms may restrict the appetite and uptake for a CBDC. Its success therefore relies on users feeling compelled to take the time to set up a CBDC wallet or account, and then of course to actually use the new form of money.

Programmability and smart contract functionality enables a CBDC to enhance existing digital money capabilities. For example, new technologies, such as distributed ledger technology, allow for the alignment of data and money flows. This functionality can not only enable organisations to realise payment processing efficiencies, largely through the elimination of unnecessary intermediaries and the reduction of error and fraud handling, but also enables firms to better control their funds. Through embedded logic, funds can be released only when certain criteria is met, a particular task has been validated or information provided etc. This could be particularly appealing for corporates dealing with clunky and operationally burdensome mass payouts, or indeed governments and local authorities distributing grants and benefits. From the side of the user, they can be paid quickly and accurately, also benefiting from opportunities for enhanced engagement between the payer and the recipient. These are all significant features that would enhance the attractiveness of a CBDC.

Programmable money vs programmable payments

There are however two points that need to be addressed here. Firstly relating to the important distinction between programmable money and programmable payments, and secondly where the programmability capabilities will be designed and implemented.

The concept of programmable money, where spending rules are embedded into the money itself, is challenging; most people are naturally inclined to be sceptical about any control over how citizens spend their own money, including money received from the government. Whilst there may be positive use cases for programmable money such as government-issued relief funding or charitable donations, there is reasonable concern that programmable money could be used to impinge on civil (and human) rights.

It is the view of some of our members, therefore, that the Bank should be cautious in any proposals to programme the CBDC itself, even if, as the Bank has noted, there is no intention to allow the central bank or Government to programme the CBDC – as there are likely to be many public relation and educational considerations and challenges that emerge as a result – and to focus instead on programmable payments and the benefits that they can bring.

With regards to where responsibility for programmability of payments will fall, some of our members would advocate for the PIPs incorporating this feature into their innovation strategy and CBDC propositions. This would enable PIPs to design their own commercial framework for CBDC distribution and related platforms, and may contribute positively to the debate around how PIPs can leverage financial gain from their regulated PIP role. Programmability, alongside varying attitudes to data protection, privacy and data monetisation, will become the key differentiators between PIPs and will therefore help to determine a users’ decision with regards to their preferred CBDC distributor. These varying approaches will provide user choice and help to mitigate any concerns that indeed a CBDC is to become a tool for user control.

Other members, assuming the introduction of programmability of the CBDC itself at a certain level, would also welcome additional clarity as to how and at what level PIP-implemented programmability could exist in a system based on a single account held in a centralised ledger by the Bank of England. Would programmability in this scenario be implemented at the wallet level, and not at the base central ledger level? Would this potentially make it easier to circumvent, and potentially less useful from a functional perspective?

Programmable payments powered by Distributed Ledger Technology (DLT) enable the ability to integrate business logic with payments, without the need of tight payment integration between different backend systems. Programmability enables atomic settlement of financial transactions, which means that either all legs of a transaction settle successfully or neither leg of a transaction settles. The most common use cases of atomic settlement fall under two categories (1) Delivery versus Payment (2) Payment versus Payment. Atomic settlement enables the reduction of counterparty and credit risks, and by consequence it increases the efficiency of financial transactions.

Riksbank tested the benefits of smart contracts for the atomic settlement of the transfer ownership of a car and the associated payment transactions[14]. Programmability allows for the transfer of ownership and transfer of money only to happen when all the required parties fulfil their obligations (Delivery versus Payment). Delivery versus Payment requires programmability to ensure that trading and settlement can be collapsed into a single transaction. This model also does not require another intermediary (e.g., escrow provider) to enforce the atomic settlement between two or more parties. The reduction of the number of intermediaries improves the efficiency of financial transactions and can result in reduction of costs to customers.

13. How important is offline functionality in a CBDC system? What are the most effective ways to implement offline capability? (Section 4.8)

In a jurisdiction such as the UK, which lacks the concept of ‘internet as infrastructure’,

offline functionality and support for a UK CBDC is of great importance, as without this there is significant risk of digital exclusion.   A reliance on WiFi and other permanent internet connections, for example, will have significant impact on individuals’ – and businesses’ – ability to utilise and fully realise the benefits of a CBDC. It is not uncommon, even in UK city centres, including Central London, to find oneself without a mobile signal. In addition to locations that might not ordinarily have a mobile phone signal, more remote parts of the UK are regularly hit by winter storms which can result in power outages lasting a few days. For these parts of the UK, offline functionality would take on greater day to day importance.

Lack of digital inclusion also threatens the Bank’s goal in ensuring that the CBDC – and continued public access to a digital-native form of public money – continues to underpin trust and stability in the UK’s financial system. Support for offline transactions can also play a significant role in enabling the adoption of the internet of things (IoT) and associated innovations, as well as transactions in which one side may be offline and the other online.

Other jurisdictions have undertaken extensive exploration of approaches to implementing offline payments. Approaches include the effective ring-fencing of funds for offline usage, and enabling offline payments for a given wallet on only a single device at a time.

F. Annex 1 – Preparedness of the UK retail payments infrastructure and landscape for a digital Pound

Pay.UK is the leading operator of retail payments infrastructure in the UK. It operates most of the UK’s national retail payment systems: BACS, Faster Payments, and the Image Clearing System (which provides a digital mechanism for processing cheques). Pay.UK undertakes these activities under the supervision of the Bank of England’s Financial Market Infrastructure Directorate (FMID), and is also regulated by the Payment Systems Regulator (PSR). The systems that Pay.UK operates underpin many of the digital payments services provided by banks, fintechs and other payments providers, including direct debits, bill payments, internet and mobile banking, and mobile payments.

In 2018, Pay.UK launched its New Payments Architecture (NPA) programme, with the aim of consolidating and simplifying the clearing and settlement of payments between Payment Service Providers (PSPs – including banks and non-bank providers) and promoting competition in the service layers above. The architecture was originally designed to bring all of the above payment systems together onto one infrastructure with a single set of standards, rules, and processes, creating a platform that could support the evolution of payments in the UK. In July 2021, following a number of delays and the identification of a number of risks associated with the rollout, the PSR announced its intention to phase the rollout of the NPA, and to limit its initial scope in order to prioritise the most critical deliveries.

It is in this context that, on 2nd March 2022, Pay.UK launched its new strategy paper entitled Our Foundation for the future 2021-2026. The Strategy represents an attempt to balance ongoing enhancements to existing platforms with the delivery of Pay.UK’s “next generation payments platform” (or what was previously referred to as the NPA). It is notable that the Strategy makes no reference to the emergence of new forms of digital money, including both privately issued stablecoins and the potential introduction of a retail CBDC in the UK.

Given the work being undertaken by HM Treasury and Bank of England at present in exploring the potential introduction of a retail CBDC in the UK, this seems a surprising omission. Whilst it is not necessarily anticipated that Pay.UK would want or need to provide infrastructure in direct support of a digital Pound (CBDC or otherwise), it would however be prudent to consider the potential interoperability requirements that might arise from the introduction of a CBDC in particular. This is particularly relevant given that many of Pay.UK’s payment system participants are likely, in the future, to become PIPs in the new CBDC ecosystem, and to provide services in the future that bridge both traditional payments and payments based on CBDC and other new forms of digital money.

This potentially means that any work on the new Pay.UK platform may not incorporate the necessary “hooks” to provide interoperability with a new digital Pound, and creates a significant risk with respect to the new platform’s resilience in the face of future developments – the extent to which it is “future-proof”. The original NPA blueprint, published in 2017, predates most discussions of both public and private digital currencies. In an alternate scenario, the Strategy could have represented an opportunity to look ahead to the changing and expanding payments landscape, and to develop a vision of Pay.UK’s new infrastructure in this context.

Given the risks and delays associated with development of the NPA to date, the PSR has published consultations that explore potentially limiting the scope of the new architecture to single immediate payments. These represent just part of what FPS currently handles, leaving the remaining payments processed by FPS and BACS in an ongoing state of uncertainty. In light of this it is possible that, for a significant period of time, PSPs may need to connect to multiple infrastructures for the same service coverage that they receive today. FPS also shares the same identity solution as BACS (meaning that PSPs using both BACS and FPS need only run a single identity solution at present), and so there is also a question as to whether they will retain compatibility in the future, or whether support for both will be required for this indeterminate interim period.

These challenges, arising from the phased introduction of the delayed new infrastructure, become more relevant for PSPs when considered in the context of other external changes to the landscape. Not only are they faced with the emergence of digital currencies and the new infrastructures associated with these, but also the emergence of digital identity solutions (which are integral to adoption of digital currencies). For PSPs wishing to maintain their existing business models as well as introducing new products and services that leverage the opportunities of a CBDC, these factors can pose significant barriers. In light of all this, it is a surprising omission that the new platform – designed to handle the UK’s real-time retail payment needs for the foreseeable future – does not contemplate the introduction of a CBDC. Given Pay.UK’s position as the pre-eminent provider of retail payments infrastructure in the U.K, the DPF believes that this should be of concern to all stakeholders in the payments ecosystem – including policymakers, regulators, PSPs, would-be PIPs and end-users.

G. Annex 2 – DPF Use Case Working Group Overview

The DPF’s Use Case WG has been making great progress since its formation and has brainstormed a wealth of possible use cases across both public and private sectors, grouping these into themes and beginning its deep-dive work on the next level of detail.

The Use Case WG, which consists of representatives from various DPF members including Electroneum, Herbert Smith Freehills, Modulr, OneStep Financial, Quant and Ripple, has put together a project canvas building the foundations of our purpose, the outcomes we hope to achieve, the activities that we will undertake, who will be involved (in terms of both direct participants and actors), and how we can measure the impact of this work. We have also developed use case selection criteria to ensure that the WG is exploring valuable and relevant opportunities. These include but are not limited to: the impact on the end-user, business opportunity, degree of government interest and policy alignment, the WG’s ability to access industry expertise, and how clearly a use case will showcase the unique potential of a digital Pound CBDC.

We have identified four themes to explore in depth:

  1. Making tax effortless – removing friction in the process of making or receiving tax repayments to benefit individuals or businesses.
  1. Only pay for what I use – with utilities where there is no debit risk, or for content where pay per view/play models can be delivered & royalty distribution simplified.
  1. Control your money – enhancing the way you pay for complex purchases such as cars and high-value electronics, auctions and cross-border trade.
  1. Supporting sustainability – product lifecycle & ESG considerations supported by providing a common store of value and enabling small value payments.

Each of these is illustrated in detail on the subsequent page.

The WG has recently started to develop the above themes in detail, focusing on the ‘so what’ for the end-user, examining the barriers to implementation in the absence of a CBDC, and assessing the benefits of delivering these use cases via a CBDC versus current payment technologies. The WG’s output takes the form of content pieces, webinars and roundtables, with the eventual aim being for WG members to build pilots / POCs in cooperation with the Bank and other stakeholders if possible.

Appendix

[1] We note that the rate at which cash use is declining is often overstated, as per this from the Bank of England – https://www.bankofengland.co.uk/quarterly-bulletin/2022/2022-q3/knocked-down-during-lockdown-the-return-of-cash  – and that therefore this should not be relied upon solely as a driver for introducing a CBDC. We focus therefore on the need for optionality and future-proofing throughout this response.

[2] https://committees.parliament.uk/oralevidence/3062/html/

[3] For example, https://www.gfma.org/wp-content/uploads/2023/05/impact-of-dlt-on-global-capital-markets-full-report.pdf

[4] https://www.bis.org/publ/othp42_user_needs.pdf

[5] https://www.openbankingexpo.com/news/uk-sees-growth-in-open-banking-payments-in-2022-as-use-case-proliferate/

[6] https://www.requesttopay.co.uk/

[7] https://bpay.com.au/business/business-faqs

[8] https://www.ebill.ch/en/news/ebill-success-story.html

[9] “The service was released to the public in November 1997, with participation from seven different financial institutions and 35 different billers, mainly utilities which had large customer numbers and payment volumes.” https://bpaygroup.com.au/news/articles/how-bpay-came-to-b/

[10] https://www.accenture.com/us-en/insights/blockchain/evolution-money

[11] https://www.riksbank.se/globalassets/media/rapporter/e-krona/2022/e-krona-pilot-phase-2.pdf

[12] Based on the policy objectives outlined in the digital pound CP, the Bank assesses that privacy, security, resilience, performance, extensibility and energy usage are foundational technology considerations for CBDC (Section 3).

[13] https://www.wearepay.uk/what-we-do/payment-systems/access-to-payment-systems/indirect-access/

[14] https://www.riksbank.se/globalassets/media/rapporter/e-krona/2023/e-krona-pilot-phase-3.pdf

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