When a corporate finance officer opens a digital RMB wallet and finds an extra interest payment at the end of the quarter, the amount may be modest, but it raises a question more important than the interest rate: who exactly owes the enterprise the money represented by the balance in the wallet?

In the early digital RMB framework, public documents emphasized its positioning as digital cash and M0 and the fact that it did not bear interest. Starting January 1, 2026, a new-generation digital RMB measurement framework, management system, operating mechanism and ecosystem took effect, under which commercial bank wallet balances are included in bank deposit liabilities and bear interest in accordance with deposit interest rate management requirements.

If this change is understood only as "wallets now earn demand deposit interest too," it is easy to miss its real impact on enterprises.

The thesis of this article is that digital RMB 2.0 moves the question of how enterprises choose a wallet beyond a simple comparison of payment functions to identifying the obligor, the scope of protection, fund permissions and exit mechanisms. Interest payment is only a surface signal; who bears the repayment obligation is the underlying question.

I. From 1.0 to 2.0: What Changes Is a Legal Relationship

The 2021 white paper China's Digital RMB Research and Development Progress positioned digital RMB as a digital form of fiat currency issued by the People's Bank of China, primarily positioned as a cash-type payment instrument (M0), emphasizing central bank liability and the absence of interest.Digital RMB White Paper

This historical statement is important for understanding the early design, but it cannot directly override the new 2026 framework. Information released by the Chinese government website in December 2025 shows that the People's Bank of China introduced an action plan to strengthen the digital RMB management service system and financial infrastructure: digital RMB in commercial bank wallets is established on an operating basis as bank deposit liabilities; banks shall pay interest in accordance with deposit interest rate management requirements; balances are included in bank balance sheet management and deposit insurance; and the relevant balances are counted in the base for reserve deposits.Relevant Information from the Chinese Government Website

This is not simply "attaching interest" to the original digital cash. For commercial bank wallets, the balances held by customers enter the bank's balance sheet, and the creditor-debtor relationship and risk allocation between customers and the operating bank become more prominent. The fact that the central bank still provides infrastructure, technical support and supervision does not mean that every balance in an enterprise wallet can be described, without distinction, as a central bank claim held directly by the enterprise.

The term "digital RMB 2.0" used in this article is a colloquial summary of the new 2026 framework and is not treated as the formal name of a legal document.

II. Identify the Specific Wallet First, Then Discuss "Whose Liability It Is"

The 'digital renminbi balance' displayed on a corporate page may correspond to several different structures.

A genuine digital renminbi wallet opened by a commercial bank

According to public information on the new framework, the digital renminbi balance in a commercial bank wallet constitutes a deposit liability of the commercial bank. For enterprises, the operating bank not only provides the payment interface but is also the entity liable for the corresponding balance. When enterprises select an operating institution, service stability, contractual terms, risk management and exit arrangements therefore become more important.

A digital renminbi wallet in whose operation a non-bank payment institution participates

Public information also indicates that non-bank payment institutions that participate in digital renminbi operations in the future should implement a 100% digital renminbi reserve arrangement. This is not the same structure as a commercial bank independently conducting asset and liability management.Policy interpretation of Digital Renminbi 2.0

Therefore, the fact that both types of wallets can display digital renminbi does not by itself permit the inference that the liable entity, interest, safeguards and manner of fund deployment are entirely the same. The institution's qualifications, the applicable rules and the user agreement still need to be verified.

A 'digital currency balance' or 'sub-wallet' within a platform

This type of display requires particular caution. The platform may merely be displaying a wallet genuinely opened by an operating institution, or it may be recording merchant receivables itself under an umbrella wallet, or it may even be merely an internal value in a database.

If an enterprise cannot confirm which operating institution's wallet the balance corresponds to, who the real-name holder of the wallet is, and whether it can directly inquire with and redeem from the operating institution, it cannot treat the balance as a bank digital renminbi deposit merely on the basis of the page name. Internal balances may also give rise to issues concerning fund pooling, secondary settlement and payment business licensing; see'Technical Services or Payment Business? Compliance Boundaries for Digital Renminbi Projects'。

III. Deposit insurance coverage does not mean that any amount is fully guaranteed by the state

“Inclusion in deposit insurance” is easily simplified in market promotion to “funds are absolutely safe.” Enterprises should return to the institutional framework itself.

The Deposit Insurance Regulation provides that insured deposits in principle include RMB and foreign currency deposits absorbed by the insured institution; the principal and interest of all insured deposit accounts of the same depositor at the same insured institution are combined for calculation, with a maximum payout limit of RMB 500,000, and any excess is compensated from the insured institution's liquidation assets in accordance with law.Deposit Insurance Regulation

There are at least three points to note for enterprises regarding digital RMB wallets.

First, protection is calculated on a combined basis by “same depositor, same insured institution,” not RMB 500,000 separately for each wallet or each page. Where an enterprise has other insured deposits at the same bank, it should understand the position as a whole in light of the rules applicable at the relevant time.

Second, limited payout is not an unlimited guarantee. Enterprise operating funds are usually far higher than RMB 500,000, and deposit insurance cannot be treated as a substitute for selecting operating institutions and setting funding limits.

Third, it should first be confirmed whether the balance constitutes an insured deposit absorbed by an insured institution. Platform internal balances, non-bank institution structures or other products cannot, merely because they use the name “digital RMB,” be subjected without analysis to the protection conclusions applicable to commercial bank wallets.

This article does not make a case-by-case determination of whether any specific wallet constitutes an insured deposit. Before allocating large balances, enterprises should obtain clear, retainable written explanations from the operating institution and verify the liability entity, interest calculation and risk disposal clauses in the agreement.

IV. Enterprises cannot treat wallets as “bank accounts in a different skin”

Digital RMB wallets and bank settlement accounts can be linked and can be used for exchange in and out, and may also be used through corporate online banking or bank-enterprise direct connection. However, connected functions do not mean that the two are already fully equivalent under all institutional frameworks.

Bank settlement accounts involve the existing management framework of basic accounts, general accounts, special deposit accounts and others. Digital RMB wallets have their own opening, real-name verification, limits, payment and operating agreements. Public policy interpretations in 2026 also indicate that, after digital RMB acquires deposit attributes, it may still not automatically enjoy policies in fiscal, financial, cross-border and other fields that are completely identical to those for ordinary bank accounts.Reprinted policy interpretation from People's Daily

Enterprises should confirm each item in actual business operations rather than drawing analogies on their own:

  • whether corporate wallets can be used directly for specific taxes and fees, payroll, financing or cross-border scenarios;
  • whether balance and transaction limits exist, and whether they can accommodate batch payments;
  • how wallet payment receipts enter ERP, treasury and accounting records;
  • what procedures apply when a wallet is restricted, frozen or otherwise subject to anomalies;
  • how balances and historical data are handled after a wallet is cancelled or the operating institution is changed.

The functions a product can perform, the functions a contract permits an enterprise to use, and the business activities regulatory rules permit remain three distinct levels.

V. Changes in the liability subject will bring the choice of operating institution into corporate treasury management

Under a digital-cash-style understanding, wallets of different operating institutions are easily regarded as different entry points to the same currency. Under the 2.0 framework, commercial bank wallet balances constitute liabilities of the respective operating banks, and enterprises should begin to manage operating institution relationships as they manage bank accounts, while not copying all bank account procedures wholesale.

At a minimum, the following views need to be established:

Feishu spreadsheet (original table retained)
Feishu spreadsheet: view the complete spreadsheet in Feishu

This table may look like financial management, but it actually involves both law and IT. The agreement determines who bears obligations, the system determines who can operate, and the financial policies determine how much funds may accumulate. If any one of these is missing, the "bank wallet balance" will become, within the enterprise, a new account for which no one is fully responsible.

VI. Interest itself also needs to be incorporated into contract, accounting and authority design

For corporate wallets with relatively large amounts, interest is not an entirely negligible residual amount. Enterprises need to clarify:

  • whether interest accrues on the entity wallet, and which quoted interest rate and interest settlement date apply;
  • which wallet interest is credited to, and what interest settlement records the operating institution provides;
  • who is entitled to interest generated by project funds or entrusted management funds;
  • where the platform operates the wallet on behalf of the enterprise, whether the platform has the right to view, use or transfer interest;
  • how interest calculation results are to be reviewed when a wallet is closed, the balance is redeemed, or a dispute arises.

This is where mismatches of rights are especially likely to occur. The financier provides dedicated funds, the platform is responsible for technical management, and the supplier ultimately receives payment. If interest is generated in a wallet under the platform's name but no agreement specifies its ownership, then even if the amount is small, it will expose the project's lack of design for the structure of rights over funds.

However, attention should not be focused entirely on returns. Interest calculated at the level of demand deposits is usually not sufficient to be the sole reason for an enterprise to accumulate large operating funds over the long term. Liquidity, authority, business continuity and risk concentration are often more important.

VII. Enterprises can conduct a "wallet look-through review"

Before opening or making large-scale use of corporate wallets, it is advisable to put the following questions in writing:

  1. Which qualified operating institution opens the wallet, and with whom does the enterprise contract?
  2. Can the balance displayed on the page be independently verified on the operating institution's side?
  3. Under this structure, whose liability is the balance, and what is the basis for interest accrual?
  4. To what extent do deposit insurance or other protections apply, and what are the limits and exclusions?
  5. Who may redeem, make payments, split accounts, modify smart contracts and export logs?
  6. How are the wallet, bank accounts, ERP and accounting records reconciled on a daily basis?
  7. How does the enterprise exit in the event of restrictions, freezes, operating institution failures or termination of cooperation?

If the answers given by the operating institution, the platform and the enterprise's internal team are inconsistent, the structure should first be clarified before expanding balances and use cases.

Digital RMB 2.0 has not made wallets harder to understand. It merely requires enterprises to move beyond the intuition that "this is central bank digital currency, so it is all the same." The same name of the currency does not mean that every layer of service relationship, liability subject and protection arrangement is the same.

FAQ

Will all digital RMB wallets accrue interest starting in 2026?

This cannot be summarized merely on the basis of the name "digital RMB wallet." Public information focuses on real-name wallets and operating arrangements under the new framework; the scope of interest accrual, interest rates and interest settlement methods for corporate wallets, different operating institutions and specific products should be governed by the rules in force at the time and the agreements with the operating institutions.

Is the balance in a commercial bank's digital RMB wallet a direct liability of the central bank to the enterprise?

According to public information on the new framework for 2026, commercial bank wallet balances are included in commercial bank deposit liabilities. The central bank provides infrastructure support and exercises supervision, but this does not mean that every balance in a commercial bank wallet can be broadly described as a central bank liability directly held by an enterprise.

Once digital renminbi wallets are covered by deposit insurance, can large balances also be fully compensated?

This cannot be understood in that way. The Regulations on Deposit Insurance provide that the principal and interest of insured deposits of the same depositor at the same insured institution are calculated on a combined basis, and the current maximum compensation limit is RMB 500,000; any excess is compensated from the liquidation assets of the insured institution in accordance with law. Whether a specific wallet constitutes an insured deposit still needs to be verified.

If a platform page displays a "digital renminbi balance," does that mean it is a bank deposit?

Not necessarily. It should be verified whether the balance corresponds to a wallet actually opened by an operating institution, the entity registered for the wallet, the counterparty to the agreement, and whether it can be independently queried on the operating institution's side. Internal bookkeeping by a platform cannot acquire the legal attributes of a bank deposit merely by virtue of its name.

Sources and Scope of Application

The sources in this article were verified as of September 26, 2026 (Beijing time). The digital renminbi 2.0 framework still requires ongoing verification in light of subsequent formal rules, specific operating institution agreements and product arrangements. The term "liability" as used in this article is a general description in the sense of financial legal relationships and asset-liability management, and does not replace a specific accounting presentation opinion.

This article is a general professional analysis and does not constitute legal or financial advice regarding any specific wallet, operating institution or balance protection. Before large-value use, enterprises should verify the latest formal rules, the qualifications of operating institutions, wallet agreements and internal treasury systems.