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A retail central bank digital currency (CBDC) could be designed to limit the personal information disclosed during a payment, but “digital cash” does not automatically mean anonymous or breach-proof. The Bank for International Settlements (BIS) identifies two distinct privacy risks: what payment participants learn during ordinary transactions, and the possibility that operators’ or intermediaries’ stored data could be exposed in a large-scale breach. No single CBDC privacy model is settled; protections depend on technical design, data-handling rules and the law in the issuing jurisdiction.
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 be a claim on the central bank. By contrast, ordinary electronic retail money generally represents a claim on an intermediary, such as a commercial bank. That distinction concerns who owes the money; it does not, by itself, determine how private a payment is.
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“Cash-like privacy” is a design objective, not a standard feature guaranteed by the label CBDC. A payment system’s privacy depends on which participants receive identity, balance and transaction information; what data the system collects and retains; and what legal and governance rules permit. The BIS technology paper discusses design choices in the event a central bank decides to issue a CBDC. It does not argue for or against issuance, and it does not establish one model for every country.
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Routine disclosure during a payment
A payment can reveal information even when there is no breach. Depending on the design, a merchant, payment service provider, bank or public authority may learn a user’s identity or transaction details. Financial transactions can expose sensitive personal information. The BIS argues that systems should avoid allowing merchants to link payment data to customer profiles by default.
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Privacy by default means limiting the use of consumer data to what is strictly needed to determine whether a transaction is lawful and, if it is, to execute it. A user should not have to take extra steps just to obtain the system’s ordinary privacy protections.
Exposure of data held by operators or intermediaries
A separate risk arises when transaction or identity data are collected and stored by the organizations running or supporting the system. If a large set of stored data is compromised, the exposure could extend beyond the information one merchant sees in a single payment. The BIS identifies this as a system-level privacy concern and discusses safeguards such as collecting less data, deleting it promptly, aggregating or anonymising it, and keeping offline data in physically separated storage.
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The BIS materials cited here describe a potential risk; they do not document a breach of user records from a live retail CBDC. They also provide no directly applicable statistic quantifying breach rates or resulting harm specifically for CBDC systems. A general banking breach figure would not establish how often a CBDC breach might occur or what its impact would be.
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The BIS describes token-based and account-based access as different design options, not as a simple choice between privacy and surveillance. Either approach involves decisions about identity checks, transaction data, recovery, resilience and lawful oversight.
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| Design question | Token-based access | Account-based access |
|---|---|---|
| How access is tied to the user | Can use cryptographic signatures without personal identification, supporting cash-like access and anonymity. | Is rooted in digital identity and account authentication. |
| What that means for privacy | Can avoid routine identity disclosure, but does not by itself settle what transaction data others can see or retain. | Identity-based access does not automatically give every participant transaction details; authentication can be designed to shield those details from commercial parties and public authorities. |
| Oversight and illicit activity | Effective anti-money-laundering and counter-terrorist-financing (AML/CFT) arrangements can be difficult to provide. | May be more compatible with monitoring illicit activity, depending on the system and its rules. |
| Lost credentials | The BIS paper warns that losing a private key can mean losing funds. | Recovery arrangements depend on the system’s account and identity design; the cited materials do not specify a universal recovery method. |
Neither column describes an inherently anonymous or inherently exposed system. A token model has to address key management, loss and AML/CFT. An account model can limit who sees transaction data, but its privacy depends on how authentication, access and data governance work in practice.
What protections a system would need
Privacy is not delivered by cryptography alone. The BIS design discussion points to a combination of technical controls and rules governing the institutions that operate a system. Relevant safeguards include:
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- Data minimisation: collect only what is necessary to validate and complete lawful payments.
- Limited retention: delete personal data promptly when it is no longer needed.
- Careful data use: prevent payment records from becoming a default source for merchant customer profiling.
- Aggregation or anonymisation: reduce the connection between stored information and identifiable individuals where appropriate.
- Separated offline storage: physically isolate data used for offline functionality where the architecture calls for it.
- Institutional and legal safeguards: define who may access information, for what purpose, and under what oversight.
- Security and resilience: protect the central bank and payment service providers, while planning for cyber threats, offline operation and recovery.
These protections involve competing needs. A system must address privacy alongside security, accessibility, convenience and law enforcement. Concentrating data increases the importance of strong institutional and legal safeguards. The BIS’s 2024 system-design discussion also treats privacy, cybersecurity, offline functionality and point-of-sale considerations as connected issues, with jurisdiction-specific policy choices and open questions still in play.
Why privacy and lawful oversight are in tension
Payment systems must make choices about how to deter illicit activity without exposing more personal information than necessary. BIS Paper 166, published on 3 March 2026, examines how AML/CFT rules affect privacy and choice across cash, bank deposits, cryptoassets and retail CBDCs. Its authors discuss the balance with financial-system integrity; they note that their views do not necessarily represent the BIS or its member central banks.
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That broader comparison does not make cash, bank deposits, cryptoassets and CBDCs interchangeable. A retail CBDC remains central bank money, while private cryptoassets and commercial bank deposits have different legal and institutional characteristics. The relevant lesson for CBDC design is that identity checks and lawful access rules must be specified, rather than assumed from the word “digital.”
What the BIS has—and has not—shown
The BIS Innovation Hub’s Central bank digital currencies: System design, published 26 November 2024, discusses privacy alongside cybersecurity, including quantum computing, offline functionality and point-of-sale considerations. It says these topics are interconnected, highlights jurisdictional legal and policy choices, and leaves open questions; it draws no specific policy conclusions.
A BIS account of Project Tourbillon illustrates one exploration of payer anonymity, not a guarantee about deployed CBDCs. 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.” The project is an experiment exploring a concept, not evidence that every digital currency offers cash-like privacy.
For users, the practical answer to “Who can see my CBDC payment data?” would therefore depend on the eventual system: its access model, the parties that process payments, retention and deletion rules, security controls, and the laws governing access. BIS publications outline the design problem and possible safeguards, not a global privacy standard or a currently universal CBDC experience.
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