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A retail central bank digital currency (CBDC) could be designed to keep some payment details private, much like physical cash. But “digital cash” is not automatically anonymous: privacy depends on which parties can see or store transaction data, how long they keep it, and what the law permits. The Bank for International Settlements (BIS) also warns that information held by system operators or intermediaries could be exposed in a large-scale breach. Its publications describe design risks and trade-offs—not a breach of a live retail CBDC or a recommendation that central banks issue one.
What “digital cash” means—and what it does not
In this discussion, digital cash means a retail CBDC: a digital form of money issued by a central bank for public use. That differs from a bank-deposit balance, which is generally a claim on a commercial bank or another intermediary. A CBDC would represent a claim on the central bank. The BIS paper The technology of retail central bank digital currency examines technology and design choices for a central bank that decides to issue one; it does not argue that issuance is necessary or desirable.
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Nor does the label “cash-like” guarantee cash’s degree of privacy. Physical cash can change hands without creating the same digital records as an electronic payment. A digital system necessarily involves technology and may involve intermediaries, so privacy depends on its architecture, data practices, and governing laws. The BIS describes privacy as one objective to balance alongside security, accessibility, convenience, and law enforcement.
How CBDC payment data could create privacy risks
Payment information can reveal sensitive details about a person’s life. The BIS identifies two distinct exposure points: what participants learn during an ordinary transaction, and what could happen if information held by an operator or intermediary is compromised.
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Data visible during routine payments
A merchant, payment service provider, wallet operator, or other participant may receive information needed to authenticate or complete a payment. The design question is whether that information also lets the participant identify the user, see other transaction details, or connect a payment to a broader customer profile. The BIS argues that systems should avoid allowing merchants to link payment data to customer profiles by default.
Its definition of “privacy by default” is that consumer data are used only for steps strictly necessary to determine whether a transaction is lawful and, if it is, to execute it. Users should not have to take extra action to get that baseline protection.
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Data concentrated in systems and exposed to breaches
Transaction data may be held by system operators or intermediaries. If a system collects or retains more information than necessary, a breach could expose a larger store of sensitive records. This is a system-level risk, not evidence that CBDC user data have already been breached: the BIS materials cited here do not document such an incident or quantify the rate of breaches or resulting harm specifically for CBDCs.
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Token-based and account-based access make different trade-offs
A CBDC’s access model affects how identity and transaction information are handled. Neither model is automatically anonymous or automatically surveilled; the result depends on how the system is implemented.
| Design choice | How access works | Privacy and oversight trade-offs |
|---|---|---|
| Token-based | Access can rely on cryptographic signatures rather than personal identification. | May support cash-like access and anonymity, but losing a private key can mean losing funds. The BIS also identifies effective anti-money-laundering and counter-terrorist-financing (AML/CFT) arrangements as difficult to design. |
| Account-based | Access is rooted in a digital identity system. | Can be more compatible with monitoring illicit activity. Authentication can still be designed to shield transaction details from commercial parties and public authorities. |
The comparison reflects options discussed in the BIS’s 2021 Annual Economic Report, not a claim that every project uses one of these models in a pure form. Choices about what each party sees, what is stored, retention periods, lawful access, and credential recovery also matter. A token that reduces routine identity disclosure may create a harder recovery problem; an account linked to identity need not expose every payment detail to every participant.
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What protections a privacy-conscious design needs
Privacy is not produced by a single feature. The BIS design discussion points to a combination of technical choices and rules governing data use. Relevant questions for a proposed system include:
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- Collection: Does the system gather only what is needed to validate and execute a lawful transaction?
- Access: Which parties can see identity, balances, and transaction details, and can authentication be separated from payment information?
- Retention: What data are retained, for how long, and can they be deleted, aggregated, or anonymised?
- Storage and resilience: Can data be segmented or held offline where appropriate, and how would users recover access if a device or credential is lost?
- Governance: What institutional safeguards and laws limit use or disclosure, including access for law enforcement?
These choices involve competing goals. Less data collection and shorter retention can reduce exposure, while AML/CFT controls and lawful investigations may require some ability to detect or examine suspicious activity. Strong privacy also has to coexist with cybersecurity, dependable operation, accessible recovery, and—where intended—offline payments.
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The BIS Innovation Hub’s Central bank digital currencies: System design, published 26 November 2024, discusses privacy alongside cybersecurity, quantum computing, offline functionality, and point-of-sale considerations. It emphasises that the questions are interconnected, that laws and policy choices differ by jurisdiction, and that open questions remain; it does not draw specific policy conclusions or set one global privacy standard.
What the BIS evidence does—and does not—show
The BIS material establishes a design concern, not a measured prediction that CBDC users will suffer breaches. It does not provide a directly applicable statistic on breaches or harm in retail CBDC systems, and the cited material does not establish that a live retail CBDC has had user records exposed. General banking breach figures should not be treated as CBDC-specific evidence.
A separate BIS account of Project Tourbillon describes an experiment exploring payer anonymity. Morten Bech, Head of the BIS Innovation Hub Swiss Centre, said: “Privacy is indeed a key requirement for a retail CBDC. But it cannot be the only one: security and scalability are also crucial to how payments are handled.” Tourbillon demonstrates exploration of a concept; it is not proof that all deployed digital money has those properties. The BIS’s Project Tourbillon account should be read in that limited context.
AML/CFT rules are another part of the policy debate. BIS Paper 166, published 3 March 2026, considers how those rules shape privacy and choice across cash, bank deposits, cryptoassets, and retail CBDCs. Its authors discuss balancing privacy with financial-system integrity and note that their views do not necessarily represent the BIS or its member central banks. Including these payment forms in one analysis does not make them equivalent: a CBDC is central-bank money, while deposits and many cryptoassets have different issuers and legal structures.
What this means for prospective users
There is no single global CBDC model or settled privacy standard to evaluate. For any specific proposal, look for clear answers about who can access payment records, whether identity is visible to merchants or service providers, how long records are retained, how breaches are managed, and what legal process governs disclosure. Also check how users regain access after losing a device or credential and whether offline payments are supported. A claim of “cash-like privacy” is meaningful only when the system’s design and rules explain what that means in practice.
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