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A retail central bank digital currency (CBDC) could be designed to provide some privacy features associated with physical cash, but “digital cash” is not automatically anonymous. Payment records may reveal sensitive details to transaction participants, and information held by system operators or intermediaries could be exposed in a large-scale breach. The Bank for International Settlements (BIS) describes these as design and governance risks—not evidence that a live CBDC has suffered a data breach.
What “digital cash” means—and what it does not
In this discussion, digital cash means a retail CBDC: a digital form of central bank money intended for public use. It would differ from ordinary electronic retail money, which generally represents a claim on an intermediary such as a commercial bank. A CBDC could instead be a claim on the central bank. The BIS paper The technology of retail central bank digital currency examines technology and design choices in the event a central bank decides to issue one; it does not argue that every central bank should issue a CBDC.
Nor is “cash-like privacy” a property guaranteed by the label. It is a possible design objective. What a user’s payment reveals depends on the system’s architecture, which parties receive data, what is retained, and what law and governance permit. The BIS does not identify one global CBDC model or a settled privacy standard.
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Why payment privacy matters
Transaction histories can reveal sensitive personal information. A series of payments may help infer where someone goes, what services they use, or which organizations they support. That makes privacy relevant even when a transaction is lawful and no individual payment seems revealing on its own.
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The BIS technology paper defines privacy by default as limiting consumer-data use to what is strictly needed to determine whether a transaction is lawful and, if it is, to execute it. The user should not have to take extra steps to obtain that baseline protection. The paper also warns against designs that let merchants link payment data to customer profiles by default.
Two different ways privacy can be exposed
Information shared during ordinary payments
A payment system may disclose information to a merchant, payment provider, central bank, or other participant as a transaction is authenticated, checked, and completed. The privacy question is not only whether a transaction is recorded, but which party can connect it to an identity, see its amount or other details, and combine it with data from elsewhere.
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Information collected in one place and later compromised
Operators and intermediaries may hold information needed to run a payment system. If a large amount of personal or transaction data is concentrated in those stores, a breach could expose records beyond the parties to a single transaction. The BIS treats this as a system-level risk that privacy design should reduce; its cited materials do not document a breach of user records from a live retail CBDC.
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Token-based and account-based access have different trade-offs
The BIS discusses two broad access approaches. Neither is inherently anonymous or inherently surveilled: the outcome depends on implementation, data handling, and applicable law.
| Design question | Token-based access | Account-based access |
|---|---|---|
| How access is represented | A cryptographic token or signature can support access without personal identification in routine use. | Access is rooted in a digital identity or account relationship. |
| Potential privacy advantage | Can support cash-like access and anonymity because a payment can be authorized without disclosing personal identification. | Authentication can be designed to shield transaction details from commercial parties and public authorities. |
| Important challenge | Loss of a private key can mean loss of funds, and effective anti-money-laundering and counter-terrorist-financing arrangements are difficult. | Identity-based access creates questions about who can associate an identity with balances and transaction details. |
| Oversight and safeguards | Must address lawful oversight and illicit-finance controls without assuming that token access resolves them. | May be more compatible with monitoring illicit activity, but still requires limits on access, use, and retention of data. |
The account-based option is not necessarily a record visible in full to every participant. The token-based option is not a risk-free privacy upgrade: users need secure key management and a way to address loss, while system designers still face oversight requirements. The BIS’s 2021 Annual Economic Report chapter on CBDCs describes these approaches and the need for institutional and legal safeguards, particularly where data are concentrated.
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What privacy protections could look like
Privacy depends on a combination of technical design and rules governing the institutions that operate the system. The BIS technology paper discusses several measures:
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- Limited retention: delete data promptly when it is no longer needed for a defined purpose.
- Aggregation or anonymisation: reduce the ability to connect retained information to an individual where individual-level detail is not necessary.
- Separation of sensitive stores: keep some offline information physically separated to reduce exposure through a connected system.
- Limits on routine disclosure: prevent merchants and other commercial participants from linking payment data to customer profiles by default.
- Legal and institutional controls: set clear rules for access, permitted use, oversight, and accountability.
These protections address different parts of the problem. For example, deleting records can reduce the amount available to attackers later, while access controls and legal safeguards govern who may use information that must be kept. A design still has to meet security, accessibility, convenience, privacy, and law-enforcement needs together.
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Privacy also depends on resilience and usability
A payment system must work reliably and let people recover from ordinary problems, not only limit data exposure. Token systems raise questions about lost credentials and recovery; digital identity systems raise questions about authentication and data linkage. Offline functionality and point-of-sale design can affect both usability and what information is exchanged. Cybersecurity—including the potential implications of quantum computing—also connects to privacy because a failure in security can expose data or disrupt payments.
The BIS Innovation Hub’s Central bank digital currencies: System design, published 26 November 2024, examines privacy alongside cybersecurity, offline functionality, and point-of-sale considerations. It emphasizes that these issues are interconnected, that legal and policy choices vary by jurisdiction, and that open questions remain; it draws no specific policy conclusions.
What the BIS evidence does—and does not—establish
The BIS material explains why CBDC privacy and data security need to be considered before a system is designed. It does not establish a measured rate of bank-data breaches that would apply to CBDCs, quantify resulting user harm, or show that a live retail CBDC has already exposed user records. General banking breach figures should not be treated as CBDC-specific evidence.
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A separate BIS Paper 166, The interplay between privacy and financial integrity, published 3 March 2026, considers how anti-money-laundering and counter-terrorist-financing rules affect privacy and choice across cash, bank deposits, cryptoassets, and retail CBDCs. Its authors discuss the balance between privacy and financial-system integrity; they note that their views do not necessarily represent the BIS or its member central banks.
In a BIS account of Project Tourbillon, 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 a concept; it is not evidence that all digital money, or every deployed CBDC, has the same privacy properties. The BIS account is available at Project Tourbillon.
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