The Liability Attributes of Digital Renminbi and the New Landscape of Cross-Border Transactions

CN
3 hours ago

Event Overview

Recently, Lu Lei, the Deputy Governor of the People's Bank of China, clarified in a public article that the future form of the digital renminbi will be institutionally defined as a currency form "with the liability attributes of commercial banks," constructing an issuance and circulation framework based on accounts. Unlike previous descriptions that focused more on functional aspects such as "legal tender" and "non-interest-bearing," this time it is directly anchored to the balance sheets of commercial banks, meaning that the digital renminbi held by the public is closer in accounting and legal relationships to existing deposit currency. Lu Lei also emphasized that the digital renminbi is supported by underlying technology provided by the central bank and is subject to full supervision, adhering to a technical route that prioritizes an account system while being compatible with distributed ledger technology, including integration with domestic alliance chains like "Chang'an Chain." In terms of functionality, the official categorizes it as possessing multiple currency functions such as a measure of value, store of value, payment settlement, and even cross-border payments, pointing to "multi-purpose digital cash" that can operate in both domestic daily payments and cross-border scenarios. In terms of public sentiment, the current market mood is generally neutral, with earlier debates about whether it bears interest or whether refusal to accept it is illegal becoming secondary, and the focus shifting more towards the pace of cross-border payment pilot advancements, the boundaries of regulatory innovation, and the redefinition of its relationship with crypto assets.

Liability Attribute Breakdown

In the traditional monetary system, the deposit currency in public accounts is essentially a liability of commercial banks to the holders, corresponding to income-generating assets such as loans and bonds, while the liabilities of the central bank mainly include cash in circulation and reserves held by commercial banks at the central bank. Defining the digital renminbi as having "the liability attributes of commercial banks" means that in the daily circulation to individuals and enterprises, the digital renminbi resembles a form of digital deposit for which commercial banks bear the responsibility of redemption in the first and second tier systems, while the central bank acts as the provider of technical and regulatory infrastructure and the ultimate clearing entity, thus forming a layered relationship with the central bank's liabilities (base currency) in legal terms. Compared to discussions from 2020 to 2024 surrounding "legal tender," "non-interest-bearing," and "refusal to accept or suspected illegality," this statement not only continues the official attribute of its payment currency but also fills in the critical link of liability attribution, providing clearer bases for accounting treatment and regulatory indicators. The account-based design means that the digital renminbi will be embedded in existing payment and clearing systems in forms such as bank accounts and wallet sub-accounts, which may impact the structure of commercial banks' balance sheets: once the scale of digital renminbi increases its proportion on the liability side of commercial banks, it will create new constraints on interbank liabilities, deposit structures, and liquidity management. Compared to crypto assets and dollar-denominated stablecoins in the market, the legal nature of the digital renminbi is not "token assets" or "contractual rights," but rather a digital form of legal currency at the liability level of commercial banks, with the risk-bearing party clearly defined as the regulated banking system, which neither relies on asset reserve proofs nor faces issues such as "decoupling" and the status of ordinary creditors in bankruptcy liquidation, with distinctly different legal rights boundaries and regulatory penetration levels.

Technical Architecture and Compliance

From this statement, it can be seen that the digital renminbi has formed a three-layer technical and institutional architecture of "central bank technical support + regulatory dominance + compatibility with distributed ledger technology." The first layer is the core technology platform and security system led by the central bank, including key management, core ledgers, and direct connections with financial infrastructure; the second layer is the regulatory and rules layer, where the central bank undertakes responsibilities such as real-name system requirements, anti-money laundering (AML), anti-terrorist financing, and monitoring of cross-border capital flows; the third layer is the application and network layer, with the account system as the main line while also being compatible with distributed ledger technology, integrating alliance chains in necessary business and regional contexts. For example, domestic alliance chains like "Chang'an Chain," frequently mentioned in the industry recently, are seen as providing a traceable, auditable, but controllable ledger environment for local and industry-level digital renminbi applications. The advantage of having both an account system and distributed ledger is that in high-frequency, low-value scenarios that interface with existing clearing systems, the account model has mature risk control and high throughput capabilities; in scenarios involving multiple institutions, jurisdictions, and multilateral cooperation (such as the central bank digital currency bridge), the alliance chain ledger offers higher verifiability and cross-border synchronization capabilities. The downside is that the technology stack is more complex, with higher integration costs and operational requirements, and it sets higher standards for performance, privacy, and compliance. The regulatory authorities have previously emphasized that the digital renminbi is legally distinct from virtual currencies, stablecoins, and other token assets, which do not possess legal tender status and are explicitly restricted to highly compliant pilot or "sandbox" environments, subject to strict foreign exchange management and cross-border capital control frameworks. This architecture sends both opportunity and limitation signals to future compliant blockchain, alliance chain, and financial IT vendors: on one hand, those able to provide links, privacy computing, and identity verification solutions that meet the central bank's security and compliance requirements will gain incremental space in the digital renminbi ecosystem; on the other hand, unauthorized public chains and technical paths that cannot meet regulatory transparency and audit requirements will find it difficult to directly access this system and can only seek limited cooperation in peripheral and interface layers.

Progress in Cross-Border Payments

In the past year, the practice of the digital renminbi in cross-border payments has noticeably accelerated, continuously expanding the pilot scope through bilateral and multilateral cooperation. According to public reports, China is advancing cross-border digital payment pilots with countries such as Laos, Singapore, and Thailand in tourism and trade scenarios, relying on infrastructure like the "central bank digital currency bridge" (multilateral projects like mBridge) to enable tourists to directly use digital renminbi for QR code payments abroad, with merchants settling in local currency without needing to first convert funds into a third-party foreign currency. This model has achieved near real-time small-value settlements in some pilot projects, with reports indicating that a single transaction can be cleared within seconds to tens of seconds, presenting a significant advantage over the traditional cross-border remittance cycle of T+2. Since the establishment of the Shanghai International Operation Center in September 2025, the release of pilot announcements and policy documents related to cross-border business has shown a clear acceleration in the second half of the year, especially towards the end of the year, where the central bank, in conjunction with multiple departments, launched cross-border digital renminbi policy support aimed at regions like the "New Western Land-Sea Corridor," further promoting pilot implementations in surrounding markets such as ASEAN with the participation of commercial banks, Bank of China, and payment institutions. From the perspective of transaction costs, the cross-border model of the digital renminbi is expected to significantly reduce remittance fees, foreign exchange settlement spreads, and intermediary bank fees; in terms of settlement efficiency, cross-border QR code payments and multilateral bridge projects greatly shorten the clearing chain; and in foreign exchange management, the central bank's direct connection to the ledger and traceable transaction data facilitates real-time monitoring of fund flows and strengthens capital account control. The "liability attributes of commercial banks" in cross-border scenarios mean that foreign banks or clearing institutions need to jointly design clearing arrangements with Chinese commercial banks and the central bank: the circulation of digital renminbi on the other side must maintain its unified legal tender status as renminbi while clearly defining which party bears the ultimate redemption and compliance responsibilities under the local regulatory framework, thus promoting the formation of a multi-tiered, accountable cross-border clearing network.

Bull-Bear Game Perspective

Surrounding the promotion of the digital renminbi, market and industry opinions present a distinct bull-bear game pattern. Supporters emphasize that from the perspective of payment efficiency, the digital renminbi can provide lower-cost and higher-reliability infrastructure in scenarios such as retail payments, government fee payments, and cross-border small payments; from the perspective of macroeconomic regulation, under the premise of deep integration of the account system, the central bank can observe currency circulation and credit structure more frequently and accurately, enhancing the directness of monetary policy transmission; from the perspective of international use, through the central bank digital currency bridge and pilot cooperation with countries like Laos, Singapore, and Thailand, the threshold for using renminbi in cross-border payments and trade settlements has been significantly lowered, helping to increase the proportion of renminbi in regional pricing and settlement. Concerns focus on three points: first, the boundaries of data privacy and transaction traceability, worrying that under high-intensity regulation, the financial behaviors of individuals and enterprises may be overly centralized; second, the intermediary functions of commercial banks may be squeezed, especially in scenarios where large-scale digital wallets replace traditional deposits, impacting the stability of banks' liabilities and profit models; third, the indirect spillover effects of regulatory oversight on the crypto asset ecosystem—given the central bank's frequent mentions of global cryptocurrency compliance progress and related explorations in Hong Kong, the market fears that the digital renminbi may be seen as the "official answer," thereby tightening the space for decentralized assets. Some KOLs remind that Lu Lei publicly stated years ago that "Satoshi Nakamoto deserves respect," indicating a certain openness to blockchain-native innovation, while recently emphasizing compliance boundaries and risk prevention, leading to divergent market interpretations. One view holds that this is a regulatory arrangement of "keeping crypto assets and digital renminbi in their respective places"; another worries that there is structural tension between regulatory strengthening and the demands for decentralization in crypto assets, making it difficult to avoid frequent collisions in the future. On potential coexistence paths, a more moderate view is that the digital renminbi undertakes regulated, traceable payment and clearing functions, while some public chains and crypto assets operate at the margins of the system in areas such as cross-border asset allocation, privacy technology, and decentralized financial tools, in a "compliance interface + risk self-bear" manner.

Market and Funding Perspective

From the news front, recent statements from the central bank regarding the compliance of the digital renminbi and crypto assets have appeared with higher density: on one hand, in authoritative documents such as financial stability reports, there are multiple mentions of global cryptocurrency regulatory progress and Hong Kong market explorations, clearly incorporating them into the framework of systemic risk and financial innovation; on the other hand, since the establishment of the digital renminbi international operation center in September 2025, the timeline has shown a rhythm of "infrastructure building first, followed by concentrated release of scenarios and policies" as cross-border pilot policies with Laos, Singapore, and Thailand gradually land by the end of the year. Since the digital renminbi itself is not a crypto asset, the market finds it difficult to directly observe its impact on mainstream coin prices and volumes, and can only assess it indirectly through sentiment and narrative intensity. Currently, the overall sentiment in the community is neutral, with no large-scale panic of "fiat currency replacing crypto," but there is some funding exhibiting moderate FOMO regarding the expectation of a "new plan potentially launching in 2026," betting on policy linkages with compliant blockchains, Hong Kong Web3, and related Hong Kong stock concepts. The central bank's push for compliance and clarity of boundaries has a certain guiding role for domestic and foreign funds: first, institutional funds are more inclined to allocate to compliant and traceable blockchain infrastructure projects, such as alliance chains, privacy computing, and regulatory technology-related targets; second, in the secondary market, companies related to cross-border payments, financial IT, domestic encryption, and security chips in Hong Kong and A-shares may gain trading premiums during policy release windows. Meanwhile, expectations regarding the new plan for 2026 have also brought about significant "policy expectation premiums" and FOMO risks: in the absence of clear institutional designs and quantitative targets, overly amplifying long-term imaginations can easily lead to misaligned allocations. For investors, a more reasonable path is to compare policy news with actual cross-border transaction volumes, the number of cooperating countries, and the depth of commercial bank participation, continuously verifying whether the internationalization of the digital renminbi is truly translating into measurable business increments, rather than merely remaining at the stage of institutional statements and framework construction.

Market Outlook

Looking ahead, the path to the internationalization of the digital renminbi highly depends on the external environment and the coordination of internal and external policies. In a scenario where global regulatory collaboration accelerates and regional economic cooperation deepens, multilateral central bank digital currency bridge projects and bilateral pilots may further expand, with the number and amount of cross-border digital renminbi transactions continuing to rise. Key indicators to monitor in the future include: the number of participating countries and regions, the extent to which pilot scenarios extend from tourism retail to trade and investment financing, and the changes in the proportion of digital renminbi in the total amount of cross-border renminbi payments. In a tightening external financial environment or a scenario of heightened geopolitical risks, there may be a greater emphasis on financial security and capital control functions, leading to a slowdown in the breadth of the internationalization process, but a deepening in specific channels and partnerships.

For the crypto industry, structural impacts will mainly manifest along three main lines: first, the compliance track, including alliance chains, compliant stablecoins, regulatory technology, and identity verification, which are expected to gain clearer development space in synergy with the digital renminbi infrastructure; second, cross-border clearing infrastructure, where technology providers and node-type institutions can build interoperability capabilities around the central bank digital currency bridge, cross-border payment networks, and FX settlement; third, privacy technology and secure computing, which, under the premise of meeting regulatory transparency, can provide "tiered privacy" and minimal data disclosure solutions for institutional assets, enterprise-level applications, and certain personal scenarios.

It is important to emphasize that there is currently no formal institutional text regarding the new plan for 2026; regulatory details, technical standards, and cross-border clearing rules are still evolving, and any projections regarding specific timelines, transaction volumes, and price effects carry significant uncertainty. Investment and industrial decisions should focus on the published regulations, pilot announcements, and transaction data for continuous tracking, rather than amplifying imaginations based on secondary market sentiment.

Overall, the clear definition of the digital renminbi's "commercial bank liability attributes," combined with the "account-based, compatible with distributed ledger" technical architecture, and the accelerated implementation of cross-border practices with Laos, Singapore, and Thailand, are collectively reshaping the issuance and circulation of the renminbi in the digital age, while quietly redrawing the power and responsibility landscape between "central banks—commercial banks—technical infrastructure—cross-border payment networks" in the global monetary system.

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