Introduction
The concept of “money” stands at the threshold of a profound transformation. Should the money of the future be issued by the state, or left to the market?
—Perhaps,the answer is not an either-or choice.。
As countries accelerate the launch of central bank digital currencies (CBDCs), another form of currency—stablecoins, born from the market yet recognized by law—has quietly entered the global financial system. Rather than acting as adversaries, they resemble partners continually refining their collaboration. Their coexistence and cooperation will redefine every payment and transaction we make—whether in U.S. dollars, euros, or renminbi.This quiet revolution is writing the rules for the future of money.
Stablecoins vs. CBDCs
Although stablecoins and central bank digital currencies (CBDCs) are often discussed together, their origins and missions are fundamentally different.
- Stablecoins Are Created by the Market
Created by enterprises or institutions, stablecoins thrive on the open soil of blockchain technology, making them inherently suited for rapid payments, cross-border transfers, and decentralized finance in the digital world. While subject to regulatory oversight, they still retain a certain degree of privacy and offer clear advantages in speed and flexibility.
- CBDCs are state-led
and issued directly by central banks, with the core mandate of safeguarding monetary sovereignty, strengthening financial oversight, and serving the public interest. Each transaction is generally traceable, facilitating regulatory supervision and the implementation of monetary policy. The objective of CBDCs is not to displace stablecoins, but to providea reliable national-level infrastructure。
In practice, they are forming adivision of labor and collaborativerelationship:
- CBDCs focus on domestic applications: they are better suited for “onshore” scenarios such as everyday domestic payments and policy adjustments.
- Stablecoins focus on cross-border applications: they perform better in “offshore” environments such as cross-border payments, crypto finance, and global asset flows.
Jurisdictions around the world, such as Singapore and Hong Kong, China, are simultaneously piloting CBDCs and issuing licenses to compliant stablecoins, promoting their coexistence and development.
In the future, we are likely to live in atwo-tier monetary systemwhere:
State-issued digital cash serves as a stable cornerstone, while market-created stablecoins bring flexibility and innovation.—They are not about one replacing the other, but rather jointly constructing the payment and financial landscape of the next era.
Global CBDC Deployment Progress
Global central bank digital currencies (CBDCs) are undergoing a critical transition from pilot programs to broader rollout. Although early initiatives yielded limited results, new-generation digital currencies are gradually achieving scale, with increasingly diverse designs and objectives.
- The Bahamas · Sand Dollar (launched in 2020)
As the world’s first nationwide CBDC, the “Sand Dollar” aims to enhance financial inclusion, particularly in remote islands with limited banking services. It has reduced transaction costs and maintained payment functionality in the aftermath of natural disasters. However, user adoption has remained persistently low, accounting for a small share of currency in circulation, and privacy concerns persist due to its traceability design.
Similar situations have been observed with Nigeria’s eNaira and Jamaica’s JAM-DEX, where early promotion efforts failed to meet expectations.
- China · Digital Renminbi (e-CNY)
Since its pilot launch in 2020, the Digital Renminbi has recently seen significant growth:
Payment volume surged from RMB 7.3 trillion in July 2024 to RMB 16.7 trillion in November 2025, while the number of wallets increased sharply from 180 million to 2.25 billion.
The People’s Bank of China will implement a new Digital Renminbi management framework in January 2026, promoting its evolution from “digital cash” to “digital deposit money.” Unlike the European approach, which emphasizes privacy, the e-CNY focuses more on efficiency and widespread adoption, and is currently exploring cross-border settlement through projects such as mBridge.
- European Union · Digital Euro
Currently in the preparatory phase, it is intended to serve as a supplement to cash and bank deposits, with the earliest potential launch in 2029 (more likely in early 2030). Its design emphasizes privacy protection and anti-counterfeiting, achieving controlled anonymity by separating identity from payment data, with the aim of reducing reliance on foreign payment systems.
- United Kingdom · Digital Pound
The United Kingdom also places significant emphasis on privacy protection, explicitly prohibiting government access to personal transaction data. The individual holding limit may be set at £10,000–£20,000, which is higher than the EU’s €3,000 threshold, and will be available to both residents and non-residents.
- Kyrgyzstan · Digital Som
It is adopting a pragmatic approach, exploring cooperation with existing crypto infrastructure (such as BNB Chain), and implementing a phased rollout strategy:
1. Connecting the central bank with commercial banks
2. Integrating the treasury for government payments
3. Testing offline payment functionality
The country has also launched a national stablecoin, KGST, and plans to establish crypto asset reserves to promote the international use of its CBDC.
Reviewing global practices, most CBDCs prioritize financial inclusion, payment efficiency, and monetary sovereignty as core objectives, with many also committing to user privacy protection. However, as scale expands, key issues remain unresolved:In actual operation, can privacy-by-design principles be upheld, or will they be overridden by heightened state surveillance requirements?Future CBDCs will seek a long-term balance among efficiency, privacy, and control.
Emerging Trends and Strategic Shifts
The development of digital currencies worldwide is entering a more pragmatic phase. National strategies are no longer merely “trial runs”; instead, countries are advancing targeted initiatives based on their specific needs.
- United States: Prioritizing Stablecoins While Deferring a Digital Dollar
The United States has clarified its direction: prioritizing the regulation of stablecoins rather than rushing to launch a central bank digital currency (CBDC). The Clarity for Payment Stablecoins Act passed by the House of Representatives in 2024 established a federal regulatory framework for the issuance of stablecoins by private entities. Meanwhile, the Federal Reserve has adopted a cautious stance toward a retail digital dollar, stating that it is “not urgent” and must be authorized by Congress. This indicates that the United States has chosen to let market forces drive digital currency innovation, while the state focuses on establishing rules.
- India and Brazil: Making Digital Currencies “Programmable” to Address Practical Issues
Digital currencies are no longer merely “electronic cash”; they have become policy tools for enhancing efficiency.
The pilot program for India’s digital rupee focuses on distributing government subsidies, ensuring that funds reach beneficiaries directly and are not misappropriated.
Brazil’s Drex system, scheduled for launch by the end of 2025, incorporates smart contract functionality that can automatically deduct taxes and enforce contractual terms, thereby transforming the CBDC into an automated efficiency tool.
- Japan: “Wholesale First,” Upgrading from Within the Financial System
Unlike many countries that start directly with public-facing applications, the Bank of Japan has chosen to first introduce a “wholesale CBDC” aimed at banks and financial institutions for interbank settlement. Testing is expected to take place in 2026–2027, while the retail version for the general public has been temporarily shelved. This reflects a pragmatic approach: upgrading the core of financial infrastructure first before considering public applications.
These examples demonstrate that the global digital currency landscape is moving toward differentiation and pragmatism—some countries are strengthening private-sector innovation under regulation, others are leveraging programmability to achieve policy objectives, and still others are initiating change from within the financial system. There will be no single uniform path in the future, only approaches suited to national circumstances.
Conclusion
The core issue for the future of money is straightforward: how can state-issued digital currencies and market-driven stablecoins be effectively coordinated?
Global initiatives are already underway:
- The Bank for International Settlements’ Project Agora is testing interoperability between central bank digital currencies (CBDCs) and bank-issued digital currencies within a unified system.
- Singapore’s Project Guardian has already achieved collaborative settlement among CBDCs, stablecoins, and digital assets in real-world scenarios.
The objective of these efforts is simple:to prevent future forms of money from fragmenting into isolated, non-interoperable silosThe key lies in ensuring that state-led digital currencies can seamlessly interact and operate in concert with widely adopted stablecoins.
Interestingly, as CBDCs develop, an unintended consequence may be emerging: they could instead enhance the legitimacy and stability of decentralized stablecoins, thereby affirming the indispensable role of stablecoins in the future financial system.
The future monetary landscape is unlikely to involve one replacing the other; rather, it will likely featuredistinct roles and collaborative synergy。
Conclusion
Jen Bai, Hong Kong Compliance Advisor at Mankun Law Firm. Dr. Bai Zhen has six years of experience in legal and compliance practice, having previously worked at a major law firm in Hong Kong. With a solid background in international law and extensive practical experience in cross-border compliance, he is dedicated to providing professional and efficient legal services to clients. Practice areas include the establishment of crypto asset funds, compliance services in the fintech sector, applications for financial licenses, dispute resolution in the financial sector, as well as traditional equity investment financing and token financing.
Evan Lee, Hong Kong Intern at Mankun Law Firm. Evan Lee is currently an undergraduate student at Columbia University, majoring in Applied Mathematics, with a strong interest in fintech. He participated in the International Mathematics and Physics Summer Camp (IMPSC) hosted by the Indian Institutes of Technology (IIT) and achieved a high score of 9 in the American Invitational Mathematics Examination (AIME), placing him among the top mathematics students in the United States. Evan previously interned at Wilson Elser LLC, a litigation law firm headquartered in New York.
About Mankun
Mankun Law Firm was established in 2015 as a boutique law firm in China specializing in the Web3 new economy and deeply engaged in the blockchain industry. The Mankun team possesses unique and diverse industry backgrounds, with members hailing from renowned legal service institutions, state judicial organs, internet technology companies, crypto asset institutions, and blockchain industry think tanks.
Leveraging a profound understanding of the new economy, continuous attention to and research on policies and regulations, and rich practical experience, the Mankun team excels in providing comprehensive legal services from the perspectives of business models and legal practice. These services include business structure design, project investment and financing, transaction planning, operational compliance, resolution of complex civil and commercial disputes, prevention and control of criminal risks, and criminal defense for enterprises in the new economy sectors such as Web3, blockchain, AI, NFTs, digital collectibles, crypto funds, crypto payments, DeFi, real-world assets (RWA), and GameFi.
Mankun Law Firm is headquartered in Shanghai, with branch offices in Hong Kong (China), Silicon Valley (USA), Shenzhen, Hangzhou, Zhengzhou, and Chengdu. To meet the global compliance development needs of Web3 industry clients, Mankun has established local offices in major global crypto-financial cities and selected local professional blockchain service partners, providing clients with professional legal and compliance services that combine global breadth with Chinese depth.
