## Central Bank Digital Currency and Other Digital Payments in Sub‑Saharan Africa: A Regional Survey (ftnea2024001)

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### Survey scope and participation
- Survey launched in February 2023; responses received by April 30, 2023.
- Thirty of the 33 central banks in sub‑Saharan Africa responded to the survey.
- Approximately 90 percent of the central banks (30 out of 33) responded, including Nigeria, which has issued a CBDC.
- Survey respondents include: Angola, Botswana, Burundi, CEMAC, Cape Verde, Comoros, Eswatini, Ethiopia, Gambia, Ghana, Guinea, Kenya, Liberia, Madagascar, Malawi, Mauritius, Mozambique, Namibia, Nigeria, Rwanda, Sao Tome and Principe, Seychelles, Sierra Leone, South Africa, South Sudan, Tanzania, Uganda, WAEMU, Zambia, and Zimbabwe.
- Three non-respondents: Democratic Republic of Congo, Eritrea, and Lesotho.

### Engagement in CBDC work and timelines
- More than 75 percent of surveyed countries are engaged in—or are planning to engage in—CBDC research or pilot activities.
- Of the 30 respondents, 23 indicated their central bank has engaged in or will engage in CBDC research, experiments, or developmental work.
- Of those engaging (23 countries):
  - about 67 percent are undertaking research related to CBDCs.
  - several are experimenting with pilots, sandboxes, and other tests; a few plan to begin a pilot in the coming years.
  - a little over 25 percent (6 out of 23) are planning to launch their own CBDC within the next five years.
- More than a quarter of surveyed countries are actively preparing to launch a CBDC by 2028.
- Nigeria launched the e‑Naira in October 2021.
- Countries not engaging presently cite short‑term priorities or a “wait and see” approach; over half prioritize private mobile money or existing payment systems.

### Motivations for CBDC exploration
- Primary motivations cited:
  - Financial inclusion and domestic payments efficiency: cited by 90 percent of central banks.
  - Payment safety: cited by 70 percent.
  - Cross‑border payment efficiency: cited by 57 percent.
  - Other motivations: reducing cash‑related costs, modernizing G2P and P2G payments, enhancing monetary policy transmission.
- Importance assessments:
  - Financial inclusion and domestic payment efficiency deemed “very important” by about 2/3 of central banks.
  - Cross‑border payments efficiency deemed “very important” by about 1/3 of central banks.
- Cash dynamics:
  - Over 80 percent of respondents have not observed a decrease of cash in circulation.
  - Over two‑thirds do not anticipate a decline of cash use over the next six years.
  - Only 17 percent of central banks (5 out of 30) reported that the amount of cash has been significantly declining.
- Accelerants:
  - About 40 percent noted the COVID‑19 pandemic accelerated CBDC planning.
  - More than 60 percent of respondents noted pandemic and crypto emergence accelerated planning around CBDCs and digital payments.

### CBDC design preferences and considerations
- Type and operation preferences:
  - Nearly 60 percent potentially interested in both retail and wholesale CBDCs.
  - Nearly 40 percent prefer a retail CBDC.
  - Less than 4 percent interested in just a wholesale CBDC.
  - Majority prefer a hybrid operation model (central bank issues CBDC and delegates intermediaries to interact with retail customers).
  - A few prefer a direct operation model.
- Technical and functional choices:
  - CBDC types under consideration include token‑based and account‑based designs.
  - No clear regional preference between account‑based and token‑based designs.
  - No clear regional preference between distributed ledger technology (DLT) and conventional centralized ledger technology (CLT); some countries test offline capability.
  - Some central banks are exploring DLT.
  - More than 80 percent would consider imposing a cap or limits on individual holdings of CBDC.
  - Nearly 90 percent intend to engage with private sector partners for implementation.
  - Most central banks prefer a non‑interest‑bearing CBDC; interest‑bearing CBDCs considered mainly to improve monetary policy transmission.
- Interoperability, privacy, and cybersecurity:
  - Both international and domestic interoperability considered critical (multilateral agreements, shared AML/CFT practices, standards, and integration with mobile money, bank accounts, and instant payment systems).
  - Overwhelming majority count on international collaboration and agreements to safeguard IT/cybersecurity and data privacy.
  - Tiered KYC frameworks commonly discussed to balance inclusion and AML/CFT.

### Legal, governance, and issuance considerations
- Issuance likelihood and timing:
  - About 3/4 of countries said their central banks will very likely or somewhat likely issue a wholesale CBDC.
  - More than 95 percent believe their central bank will very likely or somewhat likely issue a retail CBDC.
  - Most countries expect to issue a CBDC only within four to six years.
- Legal and institutional challenges:
  - At least 55 percent would need to change laws before issuing a CBDC.
  - Key legal challenges: liability (for 1/3 of countries) and chain of custody issues (for half of countries); indemnity cited by 1/3.
  - Other legal concerns: political economy issues, data integrity/confidentiality, and legal tender statutes referencing notes and coins.
  - One‑third of countries indicated their central banks already have the legal authority to issue a CBDC; in one case current law allows the central bank to issue other forms of currency as legal tender.

### Expected benefits: payments efficiency and remittances
- Relationship with mobile money:
  - More than 95 percent view CBDCs as a complement or opportunity to expand mobile money use; less than 5 percent view CBDCs as a potential substitute to mobile money.
  - Expected synergies: CBDC as a bridge for interoperability between mobile money operators; CBDC as a safer store of value (central bank risk‑free liability).
- Expected cost reductions from CBDC creation:
  - 5 to 30 percent: 33 percent of respondents.
  - 30 to 60 percent: 46 percent of respondents.
- Expected time savings for transactions:
  - About half assessed time savings will be very significant (over 60 percent).
- Remittances:
  - Only 19 percent (5 central banks) envisage an independent/unilateral approach for CBDC use in remittances.
  - 80 percent (21 central banks) prefer to participate in a multi‑currency CBDC system.
  - Expected remittance cost reduction from CBDC:
    - A quarter expect it to be “very significant” (over 60 percent).
    - The remainder split between “significant” (30 to 60 percent) and “moderate” (5 to 30 percent).

### Implementation challenges, costs, and capacity needs
- Principal challenges (survey responses):
  - Lack of human resources and technological infrastructure: 96 percent of respondents.
  - Cybersecurity risks: 88 percent.
  - Interoperability and public‑private partnerships: 63 percent.
  - Additional concerns: low internet/technology penetration, low financial literacy, commercial banks’ disintermediation concerns, private sector adoption lag, reputational risk.
- Planned mitigation approaches:
  - Capacity building, stakeholder collaboration, regulatory frameworks (including cybersecurity), enhancing internet penetration, improving financial literacy, modernizing infrastructure, and aligning data protection/cybersecurity with international standards.
- Costs and resourcing expectations:
  - Central banks generally expect to bear at least part of CBDC development and operation costs; two‑thirds indicated they would hire external technical consultants.
  - Preliminary cost figures (from a few central banks; highly indicative):
    - Development: $1 million to $3 million.
    - Annual operating costs: $100,000 to $500,000.
    - Central bank infrastructure: $800,000 to $3 million.
  - National infrastructure cost estimates depend on country size and data center setup.
- Staffing needs:
  - Need to hire or retrain staff in economics, information technology, cybersecurity, legal, payment systems, and risk management.
  - Large central banks envisage possible needs of more than 100 new staff; smaller central banks consider needs of one or two dozen additional staff.

### Fast Payment Systems (FPS), mobile money, and e‑Money
- Fast Payment Systems:
  - Majority of countries already have an FPS or are actively considering one.
  - FPS accessible through mobile phones or internet in more than 80 percent of countries.
  - In more than 70 percent of responding countries, access requires a national ID.
  - FPS platforms maintained/managed by the private sector in two‑thirds of countries; central banks regulate FPS in most jurisdictions.
  - FPS fees: in most countries average fees are below 50 cents per transaction or 2 percent of transaction volume.
  - FPS‑based cross‑border services exist via bilateral or multilateral arrangements.
- Mobile money / e‑Money:
  - Nearly all countries have privately issued e‑money/mobile money circulating.
  - Number of mobile money users reported to exceed 25 million in some major markets (Ghana, Kenya, Tanzania, and Uganda).
  - Mobile money is 100 percent backed by underlying assets in all countries (bank deposits, central bank reserves, government bonds, and other assets) and can be exchanged one‑for‑one for legal tender in all countries.
  - In half of the countries, mobile money can be used for cross‑border payments.
  - Domestic interoperability is often limited; many countries plan measures such as a national switch or regulatory changes to improve interoperability.
  - Reported fees for exchanging e‑money with legal tender (as reported by central banks):
    - 0 to 1 percent: 4 central banks.
    - 1 to 2 percent: 1 central bank.
    - 0 to 4 percent: 1 central bank.
    - 0 to 6 percent: 1 central bank.
  - Security measures include PINs, biometrics, risk‑based supervision, trust accounts, consumer protection, IT security controls, AML/CFT controls, internal controls, and governance oversight.

### Crypto assets: usage, ownership, and regulation
- Usage and market integration:
  - Use of crypto assets is limited and concentrated in a few countries; adoption for payments remains limited and largely centered on speculation and value storage.
  - In all surveyed countries, less than 10 percent of the population uses crypto assets.
  - Crypto assets are not integrated within national payment systems.
  - Primary uses: speculative trading and cross‑border/remittance transactions; some use to circumvent exchange controls and for arbitrage.
- Ownership statistic:
  - "10.3 and 9.44 percent of total population, are reported to own cryptocurrency as of 2021."
- Regulation and legal constraints:
  - About 85 percent of surveyed countries have not established crypto assets regulation.
  - Most central banks do not oversee, supervise, or regulate crypto assets; frequently no national institution is charged with crypto regulation.
  - 80 percent report people are not legally allowed to hold and transact in crypto assets; crypto assets generally cannot be exchanged for legal tender and are not accepted as means of payment in most jurisdictions.
  - Existing mitigation measures in some countries include outright bans.
- Perceived risks:
  - Most central banks have not observed threats to financial stability, monetary policy transmission, or a significant impact on capital flows due to crypto assets; about 85 percent report no increase in dollarization to date.
  - Concerns raised by some central banks: undermining monetary policy effectiveness, circumvention of capital/exchange controls, and contagion risks.

### IMF engagement, capacity building, and policy implications
- IMF engagement:
  - "The IMF has engaged with more than 50 countries on CBDC exploration to date."
  - The IMF provided TA on policy objectives, design, macrofinancial implications, and legal and technology issues; in 2023 the IMF launched a CBDC Virtual Handbook (IMF 2023b).
- Requested TA and analytical support areas:
  - (i) risks associated with the adoption of a CBDC;
  - (ii) the legal regime needed;
  - (iii) ensuring consumer protection;
  - (iv) the needed changes in payment systems;
  - (v) the relationship between CBDCs and other DPS;
  - (vi) infrastructure needs and associated costs;
  - (vii) cross‑country experiences.
- Multilateral collaboration and demand:
  - Strong interest from central banks to participate in a multi‑country pilot network group organized by the IMF African Department for regular meetings, experience sharing, and policy discussion.
- Policy implications and sequencing:
  - Continue developing frameworks to regulate e‑Money, crypto assets, and related private digital instruments to guard against financial and monetary stability risks.
  - Public sector role ranges from enabling private sector engagement (including regulation) to potentially bearing the full cost of a CBDC.
  - Prioritize further progress in mobile payment systems and potentially developing FPS as immediate priorities, while continuing CBDC research and pilots where appropriate.

*Source: Executive Summary and selected conclusions excerpt, “Central Bank Digital Currency and Other Digital Payments in Sub‑Saharan Africa: A Regional Survey” (Fintech Notes).*

### Executive Summary ......................................................................................................

### Executive Summary

### Survey scope and participation
- The “Sub-Saharan Africa CBDC and Digital Payments Survey” was launched in February 2023 and responses were received by April 30, 2023.
- Thirty of the 33 central banks in sub-Saharan Africa responded to the survey.
- Approximately 90 percent of the central banks (30 out of 33) responded, including Nigeria, which has issued a CBDC.
- The survey covers all 33 central banks in the region (including currency unions) with responses from Angola, Botswana, Burundi, CEMAC, Cape Verde, Comoros, Eswatini, Ethiopia, Gambia, Ghana, Guinea, Kenya, Liberia, Madagascar, Malawi, Mauritius, Mozambique, Namibia, Nigeria, Rwanda, Sao Tome and Principe, Seychelles, Sierra Leone, South Africa, South Sudan, Tanzania, Uganda, WAEMU, Zambia, and Zimbabwe. The three non-respondents were Democratic Republic of Congo, Eritrea, and Lesotho.

### Engagement in CBDC work and timelines
- More than 75 percent of surveyed countries are engaged in—or are planning to engage in—CBDC research or pilot activities.
- Of those engaged:
  - Roughly two-thirds are in the research phase.
  - Slightly over one-third are planning to conclude their CBDC pilot programs within the next two years.
- More than a quarter of surveyed countries are actively preparing to launch a CBDC by 2028.
- Countries not engaged in CBDCs are waiting for broader international experience and are relying on existing payment systems.

### Motivations for CBDC exploration
- Financial inclusion and efficiency in domestic payments are the most dominant motivations for CBDC adoption.
- Other cited motivations include:
  - Reducing cash-related costs.
  - Fostering competition within the payment system.
  - Modernizing government-to-person and person-to-government payments.
  - Strengthening the transmission of monetary policy.
- The decline in cash transactions during the pandemic and the emergence of crypto assets have increased concerns about monetary sovereignty.
- More than 60 percent of respondents noted that these factors accelerated planning around CBDCs and development of other digital payment systems.

### CBDC design preferences and considerations
- Most central banks are in the research phase and show strong interest in both retail and wholesale CBDCs.
- A preference for a hybrid operation model was commonly expressed: central banks issue CBDC while delegating intermediaries to interact with retail customers, aiming to balance financial stability and minimize disintermediation risk.
- CBDC types under consideration include token-based and account-based designs.
- Some central banks are exploring distributed ledger technology (DLT) for CBDC implementation.
- Shared concerns include interoperability with existing domestic payment systems and collaboration between jurisdictions.

### Legal and governance challenges
- Legal challenges pose a significant hurdle to CBDC issuance; legislative changes may be necessary in many countries.
- Legal issues most frequently mentioned:
  - CBDC liability and chain of custody.
  - Indemnity concerns.
  - Political and data integrity concerns.
- As a result, most interested central banks have not finalized plans for CBDC issuance; a few are actively analyzing costs and considering legislative amendments.

### Anticipated benefits of CBDCs
- Main expected benefits:
  - Improved payment efficiency.
  - Reduced transaction costs.
  - Promotion of competition within payment systems.
  - Facilitation of remittances with expected cost reductions for users.
- Survey respondents believe CBDCs will complement existing mobile money services, particularly by fostering interoperability across platforms.

### Implementation challenges and resource implications
- Key challenges identified for CBDC development and implementation:
  - Limitations in human capital resources and physical infrastructure.
  - Cybersecurity risks.
  - Interoperability issues.
  - Need for effective public-private partnerships.
  - Trust and reputational risks.
  - Bank disintermediation concerns.
- Central banks anticipate bearing a significant portion of development and operational costs for CBDCs.

### Fast payment systems, mobile money, and e-Money
- Fast payment systems and e-Money (such as mobile money) are considered quick wins in sub-Saharan Africa while CBDCs remain predominantly in exploration stages.
- About two-thirds of countries are in the process of implementing or considering fast payment systems accessible through mobile phones or the internet.
- Mobile money is prevalent and used, including for some cross-border payments.
- Mobile money is primarily backed by bank deposits and regulated by central banks.
- Interoperability across different mobile money providers remains a challenge in many countries.

### Crypto assets: usage and regulation
- Use of crypto assets is limited and concentrated in a few countries; adoption for payments remains limited and largely centered on speculation and value storage.
- Integration of crypto assets into national payment systems is limited.
- Regulatory frameworks for crypto assets are underdeveloped in most countries.
- The intent of regulation is to guard against financial and monetary stability risks rather than to encourage crypto usage.

### Engagement with the IMF and capacity needs
- Country authorities unanimously expressed desire for future engagement with the IMF on CBDC and digital payment issues.
- Central banks expressed interest in IMF technical assistance and analytical support on:
  - Risk assessments.
  - Legal frameworks.
  - Consumer protection.
  - Infrastructure requirements.
  - Sharing cross-country experiences.
- Survey responses indicate enthusiasm for participating in a multi-country pilot network group organized by the IMF.

### Overall synthesis and next steps
- The survey provides a comprehensive understanding of the evolving landscape of digital currencies and payment systems across sub-Saharan Africa.
- It underscores the current role of private digital payment systems and the potential importance of CBDC development in addressing financial inclusion, enhancing payment efficiency, and encouraging competition, while highlighting unique country-specific challenges.
- Findings will guide IMF efforts to support central banks in designing policies related to digital payments and finance and to foster collaboration across nations.
- A forthcoming IMF Departmental Paper will provide a deeper discussion of benefits, costs, and risks and present policy options to enhance financial digital development and inclusion while safeguarding macroeconomic and financial stability.

*Source: Executive Summary, “Central Bank Digital Currency and Other Digital Payments in Sub-Saharan Africa: A Regional Survey” (Fintech Notes).*

### conclusions from the key policy discussions in the paper. Appendix I reports on the country coverage of

### conclusions from the key policy discussions in the paper. Appendix I reports on the country coverage of

### I. CBDC Stage
- Survey sample: 30 respondents; 23 indicated their central bank has already engaged in or will engage in research, experiments, or developmental work related to CBDCs.
- Comparative benchmark: BIS survey found that 93 percent of central banks have considered undertaking CBDC work.
- Of the 23 countries engaging in CBDC work:
  - about 67 percent are undertaking research related to CBDCs.
  - several are experimenting with pilots, sandboxes, and other tests; a few plan to begin a pilot in the coming years.
  - a little over 25 percent (6 out of 23) are planning to launch their own CBDC within the next five years.
  - Nigeria launched the e-Naira in October 2021.
- Countries not engaging in CBDC work now cite other short-term policy priorities or a “wait and see” approach; over half of these prioritize private mobile money or existing payment systems.

### II. Motivation for CBDC Exploration
- Primary motivations:
  - Financial inclusion and domestic payments efficiency: cited by 90 percent of central banks.
  - Payment safety: cited by 70 percent.
  - Cross-border payment efficiency: cited by 57 percent.
  - Other motivations: reducing cash-related costs, modernizing G2P and P2G payments, enhancing monetary policy transmission.
- Importance assessments:
  - Financial inclusion and domestic payment efficiency deemed “very important” by about 2/3 of central banks.
  - Cross-border payments efficiency deemed “very important” by about 1/3 of central banks.
- Cash usage dynamics:
  - Over 80 percent of respondents have not observed a decrease of cash in circulation.
  - Over two-thirds do not anticipate a decline of cash use over the next six years.
  - Only 17 percent of central banks (5 out of 30) reported that the amount of cash has been significantly declining.
- Accelerants to CBDC planning:
  - About 40 percent noted the COVID-19 pandemic accelerated CBDC planning (to complement cash, support social distancing, enable access in emergencies, improve government transfers, and decongest banks).
  - Emergence of crypto assets also accelerated planning for many central banks.
- Preconditions for adoption:
  - More than 90 percent agree that public trust and internet/mobile penetration are key factors.
  - Public awareness and a well-established business case emphasized by some central banks.

### III. CBDC Design
- Stage and type preferences:
  - Research ongoing in most countries; no consensus on preferred design features.
  - Nearly 60 percent are potentially interested in both retail and wholesale CBDCs.
  - Nearly 40 percent prefer a retail CBDC.
  - Less than 4 percent interested in just a wholesale CBDC.
- Operational model preferences:
  - Majority prefer a hybrid operation model (central bank issues CBDC and delegates intermediaries to interact with retail customers).
  - A few prefer a direct operation model to minimize third-party risks.
- Specific design choices:
  - More than 80 percent would consider imposing a cap or limits on individual holdings of CBDC.
  - No clear regional preference between account-based and token-based CBDCs.
  - No clear regional preference between distributed ledger technology (DLT) and conventional centralized ledger technology (CLT); some countries test offline capability.
  - Nearly 90 percent intend to engage with private sector partners for implementation.
  - Most central banks prefer a non-interest-bearing CBDC (to operate like cash and avoid bank disintermediation); interest-bearing CBDCs are considered mainly to improve monetary policy transmission.
  - Both international and domestic interoperability considered critical (multilateral agreements, shared AML/CFT practices, standards, and integration with mobile money, bank accounts, and instant payment systems).
- Privacy and cybersecurity:
  - Overwhelming majority count on international collaboration and agreements to safeguard IT/cybersecurity and data privacy.
  - Tiered KYC frameworks commonly discussed to balance inclusion and AML/CFT.

### IV. CBDC Issuance
- Likelihood and timing:
  - About 3/4 of countries said their central banks will very likely or somewhat likely issue a wholesale CBDC.
  - More than 95 percent believe their central bank will very likely or somewhat likely issue a retail CBDC.
  - Most countries expect to issue a CBDC only within four to six years.
- Legal and institutional challenges:
  - At least 55 percent would need to change laws before issuing a CBDC.
  - Key legal challenges: liability (for 1/3 of countries) and chain of custody issues (for half of countries); indemnity cited by 1/3.
  - Other legal concerns: political economy issues, data integrity/confidentiality, and legal tender statutes referencing notes and coins.
  - One-third of countries indicated their central banks already have the legal authority to issue a CBDC; in one case current law allows the central bank to issue other forms of currency as legal tender.

### V. CBDC Benefits: Efficiency and Remittances
- Domestic payment efficiency:
  - More than 95 percent view CBDCs as a complement or opportunity to expand mobile money use; less than 5 percent view CBDCs as a potential substitute to mobile money.
  - Expected synergies: (1) CBDC as a bridge for interoperability between different mobile money operators, and (2) CBDC as a safer store of value (central bank risk-free liability).
  - Expected cost savings from CBDC creation:
    - 5 to 30 percent: 33 percent of respondents.
    - 30 to 60 percent: 46 percent of respondents.
  - Expected time savings for transactions:
    - About half assessed time savings will be very significant (over 60 percent).
- Remittances:
  - Interest in using CBDCs to reduce remittance costs, driven by cross-border digital money expansion and G20 remittance cost reduction efforts.
  - Only 19 percent (5 central banks) envisage an independent/unilateral approach for CBDC use in remittances (e.g., direct access for foreign money transfer operators).
  - 80 percent (21 central banks) prefer to participate in a multi-currency CBDC system.
  - Expected remittance cost reduction from CBDC:
    - A quarter expect it to be “very significant” (over 60 percent).
    - The remainder split between “significant” (30 to 60 percent) and “moderate” (5 to 30 percent).

### VI. CBDC Challenges
- Principal expected challenges:
  - Lack of human resources and technological infrastructure: 96 percent of respondents.
  - Cybersecurity risks: 88 percent.
  - Interoperability and public-private partnerships: 63 percent.
  - Additional concerns: low internet/technology penetration, low financial literacy, commercial banks’ disintermediation concerns, large human and system resource needs, private sector adoption lag, reputational risk.
- Planned mitigation approaches:
  - Capacity building, stakeholder collaboration, establishment of regulatory frameworks (including cybersecurity), enhancing internet penetration, improving financial literacy, modernizing infrastructure, and aligning data protection/cybersecurity with international standards.
- Costs and resourcing:
  - Central banks generally expect to bear at least part of CBDC development and operation costs; two-thirds indicated they would hire external technical consultants.
  - Preliminary cost figures (from a few central banks; highly indicative):
    - Development: $1 million to $3 million.
    - Annual operating costs: $100,000 to $500,000.
    - Central bank infrastructure: $800,000 to $3 million.
  - National infrastructure cost estimates depend on country size and data center setup.
- Staffing needs:
  - Need to hire or retrain staff in economics, information technology, cybersecurity, legal, payment systems, and risk management.
  - Large central banks envisage possible needs of more than 100 new staff; smaller central banks consider needs of one or two dozen additional staff.

### VII. Fast Payment Systems (FPS)
- Deployment and access:
  - Majority of countries already have an FPS or are actively considering one.
  - FPS can be accessed through mobile phones or internet connections in more than 80 percent of countries.
  - In more than 70 percent of responding countries, access requires a national ID.
- Governance and integration:
  - FPS platforms maintained/managed by the private sector in two-thirds of countries; central banks regulate FPS in most jurisdictions.
  - FPSs integrated with existing digital payment systems via central bank payment systems, APIs, and bilateral/multilateral arrangements with PSPs and financial institutions.
  - Some central banks plan to require participation in a national payment system (generally central bank-managed) to address interoperability.
- Fees and cross-border:
  - FPS fees generally set low for small transactions but not negligible: in most countries average fees are below 50 cents per transaction or 2 percent of transaction volume.
  - FPS-based cross-border services exist via bilateral or multilateral arrangements; some linkages use a common payment corporation or regional arrangements for immediate clearing.

### VIII. Mobile Money (and e-Money)
- Prevalence and scale:
  - Nearly all countries in sub-Saharan Africa have privately issued e-money/mobile money circulating.
  - The number of mobile money users was reported to exceed 25 million in some major markets (Ghana, Kenya, Tanzania, and Uganda).
  - Countries with largest transaction shares of GDP include Cameroon, Ghana, and Uganda.
- Market structure and backing:
  - Mobile money services provided by domestic companies in all countries; about one-third also reported foreign companies’ presence.
  - Platforms typically maintained by the private sector; nearly all countries regulate mobile money via the central bank.
  - Mobile money is 100 percent backed by underlying assets in all countries (bank deposits, central bank reserves, government bonds, and other assets) and can be exchanged one-for-one for legal tender in all countries.
  - In half of the countries, mobile money can be used for cross-border payments.
- Interoperability and fees:
  - Domestic interoperability is often limited; many countries plan measures such as a national switch or regulatory changes to improve interoperability.
  - Transaction/exchange fees vary; several central banks reported no fees for exchanging e-money with legal tender. Reported fee ranges:
    - 0 to 1 percent: 4 central banks.
    - 1 to 2 percent: 1 central bank.
    - 0 to 4 percent: 1 central bank.
    - 0 to 6 percent: 1 central bank.
- Security and regulation:
  - Security measures include PINs, biometrics, risk-based supervision, trust accounts, consumer protection, IT security controls, AML/CFT controls, internal controls, and governance oversight.
  - Central banks monitor issuance of mobile money to ensure trust account parity; PSPs must have risk management frameworks and IT/cybersecurity policies for licensing and ongoing compliance.
- Planned reforms:
  - Reforms include new national payment strategies, regulatory strengthening, allowing nonbank payment service provision without bank partnership, improving interoperability, promoting competition, potential cross-border retail payment systems, integration of mobile money with microfinance accounts, and increased awareness and acceptance among businesses and governments.

### IX. Crypto Assets: Landscape and Regulations
- Usage and risks:
  - In all surveyed countries, less than 10 percent of the population uses crypto assets; crypto assets are not integrated within national payment systems.
  - Primary uses: speculative trading and cross-border/remittance transactions; perceived use to circumvent exchange controls and for arbitrage in some markets.
  - Most central banks have not observed threats to financial stability, monetary policy transmission, or a significant impact on capital flows due to crypto assets; about 85 percent report no increase in dollarization to date.
  - Concerns raised by some central banks: undermining monetary policy effectiveness, circumvention of capital/exchange controls, and contagion risks.
- Regulation:
  - About 85 percent of surveyed countries have not established crypto assets regulation.
  - Most central banks do not oversee, supervise, or regulate crypto assets; frequently no national institution is charged with crypto regulation.
  - Existing mitigation measures in some countries include outright bans.
  - 80 percent report people are not legally allowed to hold and transact in crypto assets; crypto assets generally cannot be exchanged for legal tender and are not accepted as means of payment in most jurisdictions.

*International Monetary Fund — FINTECH NOTES: Central Bank Digital Currency and Other Digital Payments in Sub-Saharan Africa: A Regional Survey (conclusions excerpt)*

### 10.3 and 9.44 percent of total population, are reported to own cryptocurrency as of 2021.

### ftnea2024001 - 10.3 and 9.44 percent of total population, are reported to own cryptocurrency as of 2021.

### Crypto assets: ownership, use, and drivers
- Key statistics:
  - "10.3 and 9.44 percent of total population, are reported to own cryptocurrency as of 2021."
- Use and acceptance:
  - Some merchants do accept payments in crypto assets.
  - In most countries, crypto assets cannot be bought and sold through payments from bank accounts, with some exceptions.
  - Crypto assets constitute a small share of financial transactions and are generally used for speculative purposes and cross-border transactions.
- Main factors driving adoption (survey prompts reported in the landscape figures):
  - Speculative use and cross-border transaction needs.
  - Public interest and curiosity increasing as crypto/CBDC adoption attracts attention.

### Regulation and public communication
- Regulatory status and responses:
  - In most countries, crypto assets are not regulated.
  - Several countries are developing or adjusting existing frameworks to regulate crypto assets to address emerging risks.
  - Countries that have regulations on crypto assets have devised advisory cautionary notes on crypto asset use.
- Public outreach:
  - Some countries are conducting communication campaigns warning the public about evolving risks associated with trading in and using crypto assets.
- Legal and transactional constraints captured by survey questions:
  - Questions asked to authorities included whether people are legally allowed to hold and transact in crypto assets and whether crypto assets can be exchanged with the legal tender.

### IMF engagement and technical assistance (TA)
- Scope of IMF engagement:
  - "The IMF has engaged with more than 50 countries on CBDC exploration to date."
  - The IMF has provided TA on policy objectives, design, macrofinancial implications, and legal and technology issues on CBDC and other digital payment systems (DPS).
  - In 2023, the IMF launched a CBDC Virtual Handbook (IMF 2023b) to support capacity development engagement.
- Country requests and preferred TA areas:
  - Countries generally want TA and analytical work on:
    - (i) risks associated with the adoption of a CBDC;
    - (ii) the legal regime needed;
    - (iii) ensuring consumer protection;
    - (iv) the needed changes in payment systems;
    - (v) the relationship between CBDCs and other DPS;
    - (vi) infrastructure needs and associated costs;
    - (vii) cross-country experiences.
- Multilateral collaboration:
  - Most central banks would like to participate in a multi-country pilot network group organized by the IMF African Department.
  - The proposed network would include regular meetings to discuss policy issues, share preliminary explorations and experiences, and debate potential policy solutions.

### Survey findings: CBDC, private digital money, and payment systems
- Interest and motivations:
  - Most countries are interested in exploring and possibly developing CBDCs.
  - Primary motivations: deepening financial inclusion; enhancing efficiency and competition in the payment system (including cross-border); promoting financial stability, transparency, and safety; and addressing monetary sovereignty concerns stemming from digital assets.
  - "Half of the respondents indicated they expect the transaction cost reduction to be very significant (more than 60 percent)."
- Status of private digital money and fast payment systems (FPS):
  - Almost all countries have some form of mobile money or e-Money, generally offered and operated by domestic companies and mostly backed by bank deposits.
  - In half of the countries, mobile money/e-Money are used for cross-border transactions.
  - Most countries are also interested in further developing private digital money and FPS as potential "low-hanging fruits" or quick wins.
- Constraints and challenges:
  - Technical and human capacity challenges.
  - Infrastructure requirements and costs.
  - Legal barriers.
  - Cybersecurity risks.
  - Need for interoperability domestically and internationally.
- Adoption enablers identified:
  - Trust.
  - Internet and mobile penetration.
  - Financial literacy.

### Policy implications and way forward
- Regulatory and public policy priorities:
  - Continue developing frameworks to regulate e-Money, crypto assets, and related private digital instruments to guard against financial and monetary stability risks.
  - Public sector role ranges from enabling private sector engagement (including regulation) to potentially bearing the full cost of a CBDC.
- Capacity development and collaboration:
  - Need for regional and international cooperation to navigate technical, legal, and operational challenges.
  - Strong demand from central banks for IMF analytical support and participation in multilateral pilot groups.
- Strategic sequencing:
  - Prioritize further progress in mobile payment systems and potentially developing FPS as immediate priorities, while continuing CBDC research and pilots where appropriate.

*International Monetary Fund — FINTECH NOTES: Central Bank Digital Currency and Other Digital Payments in Sub-Saharan Africa: A Regional Survey.*

### 9. Please provide any comments on your motivations for any aspects you

### 9. Please provide any comments on your motivations for any aspects you considered as very important or important.

### Overview
- The content unit is a questionnaire covering motivations, design, issuance, benefits, challenges, and related payment systems for Central Bank Digital Currency (CBDC) and other digital payments in Sub-Saharan Africa.
- The questionnaire records multiple-choice options and open-response prompts for central banks to indicate intentions, expectations, design choices, operational models, risks, costs, and implementation details.

### Motivations, COVID-19, and Crypto-assets
- Questions on motivations for indicating aspects as "very important" or "important."
- Covid-19 pandemic:
  - Question 12: "Has the Covid-19 pandemic accelerated the planning for CBDC development?"
    - Choice: Yes / No
  - If Yes, follow-ups capture reasons (12.1) including:
    - Enable access to central bank money during times of emergency
    - Serve as a payment channel for public funding programs
    - Complement to cash and in-person payment methods
    - Support social distancing
    - Provide alternative to private payment systems in case of a credit crisis
    - Other (please specify)
  - 12.2: Free-text explanation if Yes.
- Crypto-assets:
  - Question 13: "Has the emergence of crypto-assets accelerated the planning for CBDC development?"
    - Choice: Yes / No

### Key Factors for Public Adoption
- Question 14: "What do you expect would be the key factors for a successful CBDC adoption by the public?"
  - Choice options:
    - Trust
    - Financial literacy
    - Internet and mobile penetration
    - Other (please specify)
- Question 15: "Any additional comments." (open response)

### CBDC Design (Section III)
- Question 16: "What type of CBDC are you interested in?"
  - Choice: Wholesale / Retail / Both
- Question 17: Free-text: "Please explain why you are interested in this type of CBDC?"
- Operation model (BIS terminology) — Question 18:
  - Choice options:
    - DIRECT: Central bank issues CBDC & performs all functions
    - HYBRID: Central bank issues CBDC & delegates intermediary to interact with retail
    - TWO TIER: Intermediary issues CBDC (for retail use) backed by central bank's wholesale CBDC issued to them
- Question 20: "Which form of CBDC are you planning to implement?"
  - Choice: Account-based / Token-based / Both / N/A
- Ledger design questions:
  - Question 22: "What ledger design would you consider (like DLT, Centralized Ledger, Hyperledger, etc.)?"
  - Question 23: "Which technology provider are you planning to work with/discuss?"
  - Question 24: "Please explain the reason for your choices."
- Interest-bearing CBDC — Question 25:
  - Choice: Yes / No
  - 25.1: Free-text to explain reason for choice (for both Yes and No).
- Interoperability:
  - Question 26: "Do you intend or anticipate your CBDC to be (or needing to be) interoperable in future with other countries' CBDC?"
    - Choice: Yes / No
  - 26.1: "How can the 'international' interoperability be achieved?" (if Yes)
  - Question 27: "Are you planning to ensure the potential CBDC will be interoperable with existing 'domestic' payment systems? Please elaborate." (open response)
- Private-sector partnerships:
  - Question 28: "Will you be working with private sector partner(s) in implementing CBDC?"
    - Choice: Yes / No
  - 28.1: "What would be the private sector role?" (if Yes)
  - Question 29: "Who will maintain the technical infrastructure and the CBDC data?"
  - Question 30: "What measures to safeguard data privacy do you envisage?"
  - Question 31: "What measures to safeguard IT/cyber security do you envisage?"
  - Question 32: "What measures to safeguard KYC and address anti-money laundering/combating financing of terrorism do you envisage?"
  - Question 33: "What kind of user / transaction data will be collected through your CBDC system?"
  - Question 34: "Who are the owners of CBDC transaction data? Who will be able to use the data, for what purpose, and to what extent?"

### Retail CBDC Operational Questions
- Question 35: "Will people be able to use CBDC without opening bank accounts?"
  - Choice: Yes / No
- Question 36: "Will you consider imposing a cap or limit on individual holding of CBDC?"
  - Choice: Yes / No
- Question 37: "Please explain the reason for your choice." (open response)
- Question 38: "Will a national identification ID card be required to open CBDC wallet for the lowest tier?"
  - Choice: Yes / No
- Question 39: "Will CBDC transactions be made possible using feature phones without internet access (hence just with mobile access)?"
  - Choice: Yes / No
- Question 40: "Will CBDC transactions be made available offline (no internet and no mobile access)?"
  - Choice: Yes / No
- Question 41: "Additional Comments." (open response)

### CBDC Issuance (Section IV)
- Likelihood of issuance:
  - Question 42: "How likely is it that your central bank will issue a 'wholesale' CBDC?"
    - Choice: Very likely / Somewhat likely / Somewhat unlikely / Very unlikely
  - 42.1: "What is the time horizon?" (if Very likely or Somewhat likely)
    - Choice: Short term (within the next three years) / Medium term (four to six years)
  - Question 43: "How likely is it that your central bank will issue a 'retail' CBDC?"
    - Choice: Very likely / Somewhat likely / Somewhat unlikely / Very unlikely
  - 43.1: "What is the time horizon?" (if Very likely or Somewhat likely)
    - Choice: Short term (within the next three years) / Medium term (four to six years)
- Legal and liability issues:
  - Question 44: "What are the key legal challenges you envisage?"
    - Choice: Liability / Indemnity / Chain of custody / Other (please specify)
  - Question 45: "Does your central bank have the legal authority to issue a CBDC?"
    - Choice: Yes / No / Uncertain / Laws need to be changed to allow for it
  - 45.1: "Please explain if plans are underway to provide legal authority." (if No)
  - Question 46: "Any additional comments." (open response)

### CBDC Benefits — Efficiency (Section V.A)
- Relationship with mobile money — Question 47:
  - Choice: Complement (CBDC to support and expand mobile money use) / Substitution (CBDC to compete and reduce mobile money use)
  - 47.1: If Complement, choices for synergy:
    - By using CBDC mainly as a bridge to achieve more effective interoperability between different mobile money operators
    - By using CBDC mainly as a safer store of value integrated in mobile money wallets
    - By doing both
    - Other (please specify)
  - 47.2: Free-text if Substitution selected.
- Expected benefits and impacts:
  - Question 48: "What are the expected benefits from your choice in the previous question (e.g., enhancing competition)." (open response)
  - Question 49: "Please indicate the expected reduction in the customer cost of financial payments from the creation of CBDC."
    - Choice: Very significant (over 60 percent) / Significant (30-60 percent) / Moderate (5-30 percent) / Little (0-5 percent)
  - Question 50: "Please indicate the expected reduction in the time necessary for transactions to clear from the creation of CBDC."
    - Choice: Very significant (over 60 percent) / Significant (30-60 percent) / Moderate (5-30 percent) / Little (0-5 percent)
  - Question 51: "How will CBDC affect competition among traditional players in the financial sector?" (open response)

### CBDC Benefits — Remittances (Section V.B)
- Use for remittances — Question 52:
  - Choice:
    - By giving foreign international money transfer operators (IMTOs) access to the domestic CBDC system
    - By participating in multi-currency CBDC system designed to facilitate cross border payment
    - Other (please specify)
- Expected reduction in remittance costs — Question 53:
  - Choice: Very significant (over 60 percent) / Significant (30-60 percent) / Moderate (5-30 percent) / Little (0-5 percent)
- Cost saving sources — Question 54:
  - Choice:
    - By reducing steps of fund transfers through domestic intermediaries
    - By achieving a better deal on foreign exchange cost (i.e., spread)
    - Other (please specify)
- Question 55: "Any additional comments." (open response)

### CBDC Challenges (Section VI)
- Main challenges — Question 56: Choice list includes:
  - Banking disintermediation and financial instability
  - Changes to monetary policy transmission
  - Central bank capacity (human capital and physical infrastructure)
  - Interoperability
  - Currency substitution and capital account volatility
  - Cybersecurity
  - Rapid obsolescence of existing technological platforms
  - Internet disruptions and low internet and mobile penetration
  - Public / Private partnership and business model
  - Consistency with the global payment strategy
  - Reputational Risk
  - Trust
  - Other (please specify)
- Follow-ups:
  - Question 57: "Please provide details on the challenges." (open response)
  - Question 58: "How are you planning to address these challenges?" (open response)
  - Question 59: "Are you hiring any external consultants or technical advisors to help implement CBDC?"
    - Choice: Yes / No
- Cost and staffing:
  - Question 60: "What are the total expected costs (in $US) of 'developing' a CBDC?" (open numeric)
  - Question 61: "What are the expected costs (in $US) of 'operating' the CBDC?" (open numeric)
  - Question 62: "Who will bear the costs to develop and operate the CBDC program?"
    - Choice: Central Bank / Intermediary / Users
  - Question 63: "In your view, what would be staffing requirement at the central bank for implementing a CBDC?" (open response)
  - Question 64: "In particular, what would be the cost of additional central bank infrastructure in US$ (for example, 0, if you currently have the necessary central bank infrastructure)?" (open numeric)
  - Question 65: "In particular, what would be the cost for additional national infrastructure if needed, like for internet or mobile network (in $US)?" (open numeric)
  - Question 66: "Any additional comments." (open response)

### Fast Payment Systems (Section VII)
- Question 67: "Do you have a Fast Payment System in place or are you actively considering one?"
  - Choice: Yes / No
  - If Yes, follow-ups include:
    - 67.1: Access channels:
      - Choice: Mobile phones (for example via QR code) / Internet connection / Feature phone / Other (please specify)
    - 67.2: "Would people also need the national ID?"
      - Choice: Yes / No
    - 67.3: "How much are average peer-to-peer transfer fees associated with the Fast Payment System?" (open numeric)
    - 67.4: "If you are considering a CBDC (or already have a CBDC in place), do you anticipate that the CBDC will be more efficient (faster and cheaper) than the Fast Payment Systems?" (Yes implied if matched)
    - 67.5: "Are the platforms for Fast Payment Systems maintained and managed by the central bank or by the private sector?"
      - Choice: Private sector / Central bank
    - 67.6: "How are Fast Payment Systems integrated with the existing digital payment systems?" (open response)
    - 67.7: "Are Fast Payment Systems (or will be) regulated by anybody apart from the Central Bank? If yes, by whom?" (open response)
    - 67.8: "Are these payment systems operating outside of the national jurisdiction and being used for cross-border payments?" (Yes/No)
    - 67.9: "How will inter-operability challenges between multiple providers, if any, be addressed?" (open response)
    - 67.10: "What security and risk control systems do you have or anticipate putting in place?" (open response)
- Question 68: "Any additional comments." (open response)

### Mobile Money and eMoney (Section VIII)
- Question 69: "Are there any forms of digital money (e.g, mobile money, m-pesa) circulating in your country?"
  - Choice: Yes / No
  - If Yes, extensive follow-ups include:
    - 69.1: "What are they?" (open response)
    - 69.2: "What are their legal status?" (open response)
    - 69.3: "Are they offered by domestic companies/institutions or foreign ones?"
      - Choice: Domestic companies / institutions / Foreign companies / institutions
    - 69.4: "Are they backed 100 percent?"
      - Choice: Yes / No
    - 69.5: "What are the underlying assets that back their value?"
      - Choice: Central Bank Reserves / Bank Deposits / Government Bonds / Foreign Assets / Deposit Insurance / Other assets
    - 69.6: "What is the size of the market for privately issued money (value of total transactions in local currency, year)?" (open numeric)
    - 69.7: "If possible, pls provide past five years data for the size of the market, via separate file." (file upload)
    - 69.8: "What is the current number of accounts (approximate number, year)." (open numeric)
    - 69.9: "What is the current number of users (approximate number, year)." (open numeric)
    - 69.10: "Can they be exchanged with the legal tender?"
      - Choice: Yes / No
    - 69.11: "Is there any fee for this exchange and if so, how much is it?" (open numeric)
    - 69.12: "Are the platforms for the digital money transactions maintained and managed by the central bank or by the private sector?"
      - Choice: Private sector / Central bank
    - 69.13: "How will inter-operability challenges between multiple providers be addressed?" (open response)
    - 69.14: "Are these forms of digital money regulated?"
      - Choice: Yes / No
      - 69.14.1: "Who is regulating them?" (open response if Yes)
      - 69.14.2: "Is there any plan to regulate them?" (if No)
    - 69.15: "Are these forms of digital money in circulation outside the jurisdiction and being used for cross-border payments?"
      - Choice: Yes / No
    - 69.16: "Are the authorities planning to enhance the mobile money payment system?"
      - Choice: Yes / No
      - 69.16.1: "What steps are being planned to improve efficiency?" (open response if Yes)
    - 69.17: "How will inter-operability challenges between multiple providers be addressed?" (open response)
    - 69.18: "Are mobile money issuers allowed to hold central bank reserves?"
      - Choice: Yes / No
    - 69.19: "What security and risk control systems do you have or anticipate putting in place?" (open response)

*International Monetary Fund — FINTECH NOTES: Central Bank Digital Currency and Other Digital Payments in Sub-Saharan Africa: A Regional Survey*

### 70. Any additional comments.

### 70. Any additional comments.

### IX. Crypto-Assets — A. Landscape
- Questions on prevalence and use
  - 71. To your best guess, what percentage of your population use private sector crypto-assets, such as bitcoin, ethereum, stablecoins?
    - Choice
      - 0-10
      - 11-25
      - 26-50
      - 51-75
      - 76-100
  - 72. What are the main use cases for these assets in your country?
    - Choice
      - Speculative purposes
      - Medium of payments
      - Sending remittances
      - Store of value
      - Other (please specify)
  - 73. What are the main factors driving the adoption of private crypto-assets in your country?
    - Choice
      - Inflation
      - Currency depreciation
      - Exchange rate restrictions
      - Circumvent capital control
      - Speculation
      - Illegal activities
      - Other (please specify)
  - 74. Are you seeing increased dollarization from the usage of crypto-assets?
    - Choice
      - Yes
      - No
  - 75. What do you see as crypto's impact on financial stability and monetary policy transmission?
  - 76. What do you see as the impact of crypto on capital flows?
  - 77. What are the forms of crypto-assets (such as stablecoins, volatile cyrptocurrency like bitcoin, ethereum etc.) circulating in your country?
- Market size and participation
  - 78. What is the size of the market for crypto-assets (value of transactions in local currency, year)?
  - 79. If possible, please provide past five years data for the size of this market.
  - 80. What is the current number of accounts (approximate number, year).
  - 81. What is the current number of users (approximate number, year).
- Domestic issuance and market share
  - 82. Are there any domestically issued crypto-assets (either by the private sector or the government)?
    - Choice
      - Yes
      - No
  - 83. Could you report the approximate market share (in terms of transaction volume) that is issued by domestic (as opposed to foreign) companies/institutions?
  - 84. What types of crypto-related businesses currently exist in your country?
  - 85. What platforms are crypto-assets transacted / traded on?
  - 86. How are crypto-assets integrated with the existing payment systems?

### IX. Crypto-Assets — B. Regulation
- Legal and supervisory framework
  - 87. Are there any regulations in place regarding use and trade of crypto-assets?
    - Choice
      - Yes
      - No
  - 88. What regulations are in place?
  - 89. Which government body is in charge of crypto regulations?
  - 90. Are people legally allowed to hold and transact in crypto-assets?
    - Choice
      - Yes
      - No
  - 91. If issued by domestic institutions, are you requiring underlying assets to back their value?
  - 92. Can crypto-assets be exchanged with the legal tender?
    - Choice
      - Yes
      - No
  - 92.1. Is there any fee for this exchange and if so, how much is it?
    - (Consider it, if any of following answers are matched for "Can crypto-assets be exchanged with the legal tender?" Question:
      - • Yes)
  - 93. Are crypto-assets accepted as means of payment by merchants?
  - 94. Can crypto-assets be bought and sold through payments from bank accounts?
  - 95. Are financial institutions such as banks, insurance and pension funds allowed to hold crypto-assets?
  - 96. Are there specific regulations that prevent people from transferring money abroad using crypto-assets?

### IX. Crypto-Assets — C. Exchanges
- Exchange regulation and activity
  - 97. Are local crypto "exchanges" regulated?
  - 98. How many crypto exchanges currently operate in your country?
  - 99. What are their average daily trading volumes?
  - 100. How many accounts are registered in the crypto exchanges?
  - 101. Additional comments.

### X. IMF Engagement
- Assistance and collaboration with IMF
  - 102. What kind of assistance would you like from the IMF for the development of CBDCs or Private Digital Payment Systems?
  - 103. What kind of analytical work would you like to see from the IMF? And from the African department specifically?
  - 104. Would you like to be part of a multi-country pilot group organized from the IMF African Department, discussing policy issues related to CBDCs and Private Digital Payment Systems?
  - 105. Additional comments.
  - 106. Overall comment
  - 107. Please upload any additional documentation you would like to provide.

*Central Bank Digital Currency and Other Digital Payments in Sub-Saharan Africa: A Regional Survey — FINTECH NOTES NOTE/2024/001*

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_Source: https://www.imf.org/-/media/files/publications/ftn063/2024/english/ftnea2024001.pdf_