海外之声 | CBDC是货币的未来吗？——央行数字货币监管与政策制定

导读

随着金融服务的数字化进程加速，全球的支付系统和金融体系正经历前所未有的变革，主要由金融服务数字化驱动。分布式账本技术（DLT）以及加密市场和去中心化金融（DeFi）引发了广泛关注。然而，更为重要且具变革性的趋势是金融的代币化。

代币化不仅仅是一项单一的创新，更是一个新生态系统的形成，最早出现在支付领域，随后扩展到更广泛的金融领域。这一生态系统仍处于早期阶段，但可能会对金融系统的运作方式产生深远影响，催生新的市场参与者、新的投资和结算资产，以及基于区块链的去中心化金融基础设施。

这种转型带来了巨大的机遇和风险。虽然它可能改善透明度、提高成本效益和提供24/7的可用性，但也可能导致流程的碎片化，特别是当区块链不具互操作性，难以与现有的中央清算、结算和支付系统顺利交互时。此外，过度依赖非欧洲实体可能引发竞争、战略自主和数据保护方面的问题。为了应对这些挑战，法国银行作为金融稳定的维护者，正在采取措施减轻风险，同时确保转型的收益得到充分利用。

法国银行积极参与了支付服务和系统的监管框架发展，并已经在2019年通过PACTE法案（在原本的监管框架基础上增加了对加密资产的审计和税收条例）为数字资产服务提供商（DASP）引入了法律地位。欧洲立法者在此基础上制定了MiCA （加密资产市场监管） 法规，涵盖了加密资产和稳定币的发行以及相关服务的提供。未来，MiCA虽然是一个重要的监管进步，但仍需在未来几年内进一步发展。例如，它仅部分解决了加密资产服务活动集中在加密集团内的问题。法国银行的监管机构ACPR（审慎监管管理局）已经开始识别潜在的监管途径，包括确保公共和私人DLT基础设施的韧性、认证智能合约以及保护投资者免受滥用风险。

法国银行通过两项重大努力来适应央行货币服务的变革。首先，法国银行是首个启动大额支付批发CBDC试验计划的中央银行，支持国内和跨境的代币化金融资产的DVP （净额结算）和PVP （同步交收）结算流程。其次，法国银行参与了由国际清算银行创新中心主导的多个重要国际项目，探索市场基础设施的未来以及传统系统与不同类型DLT之间的互操作性。

在这个快速发展的领域，法国银行致力于在必要时准备好部署CBDC，以满足政策目标。尽管目前尚不确定何时会部署这些CBDC，但市场参与者可以确信，法国银行将随时准备在需要时进行部署。

作者 | 德尼·波（法国央行第一副行长）

Denis Beau: The future of money - regulatory and policy issues related to the introduction of CBDCs

Opening remarks by Mr Denis Beau, First Deputy Governor of the Bank of France, at the European Law Institute Webinar, 3 June 2024.

Ladies and Gentlemen, good evening,

First of all, I thank the European Law Institute for inviting me to this panel discussion on the Future of Money. I am very pleased to share with you a few thoughts on the challenges which have emerged in the field of money and the associated payments systems, as I see them from my central bank and supervisor standpoint, and on the policies we develop given our monetary and financial stability mandates, to help address them. On those topics, within the 5 minutes I have, I would like to make 4 quick points:

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The first one is on the changes which are taking place in our payment system and the wider financial system, driven by the advancing digitalisation of financial services. At this stage, a lot of attention is focused on the use of distributed ledger technologies (DLT), in relation to the speculative crypto market and Decentralised finance (DeFi). However, behind the hype, there is a more discrete and more transformative trend underway: the tokenisation of finance.

However tokenisation is not a single innovation per se but rather a new ecosystem that is building up, which has spawned new activities and services, which first appeared in the payments sector before spreading to the wider financial sphere. The development of this ecosystem is still in an early stage. Nevertheless, it could lead to far-reaching changes in the way our financial system operates, by fostering the emergence of new players, that bridge the gap between IT and Finance, new investment and settlement assets in tokenized form, and new type of financial infrastructures, decentralized, based on DLT, particularly blockchains.

My second point is about the opportunities and risks created by those transformations, for market participants and the payment system as a whole. Here I would like to stress first that this impact is likely to be two sided. To illustrate this for the functioning of the payment system, it is important to recognize that the positive impact those transformations may have in terms of improved transparency, better cost effectiveness and (24/7) availability could come at the price of more fragmented processes. This is particularly relevant if blockchains are non interoperable and unable to interact smoothly with existing central clearing, settlement and payment systems. It could also come at the cost of an excessive reliance on non-European entities, which raises competition, strategic autonomy and data protection concerns. Second, this two sided impact creates specific challenges for an institution like the Banque de France, given its mandate, a major one being the preservation of the critical role played by CeBM in anchoring the stability of our payment and of our financial system more broadly.

In that context, we see our task as being to help mitigate the risks brought by the transformations underway, while ensuring that benefits of those transformations are harnessed.

To deliver on that task, we intend to use and we have actually started to use two policy instruments as levers, on the basis of two convictions. The two levers are our influence in the development of regulations for payment services and systems and the adaptation of our central bank money services. The two convictions are:

First, innovation can bring sustainable benefits for the payment system only if it benefits from the confidence of its users, which requires a regulatory framework that does not stifle innovation but that is sufficiently demanding to ensure the protection of the stakeholders and the stability of the system.

Second, there is a public interest in keeping central bank money at the heart of the settlement processes between financial intermediaries as it is the safest settlement asset and hence the most appropriate to ensure financial stability.

My third point is about the use of our first policy lever, the contribution to the development of regulations. In this field we have in the recent past contributed to the trail blazed in France in crypto assets with the adoption in May 2019 of the PACTE Law, which introduced the legal status of digital asset services provider, or DASP.

Europe's lawmakers have drawn heavily on the French framework, with the adoption of MiCA Regulation, a specific regulatory framework covering the issuance of crypto- assets and stablecoins and the provision of related services.

Looking forward, while MiCA represents a vital regulatory step forward, it will need to be built on in the coming years. For example, it only partially tackles the concentration of crypto-asset service activities within crypto-conglomerates. The challenge here is to ensure that investors are protected, through rules covering notably the segregation of customer funds, rules of conduct and management of intermediary risks, for example by requiring activities to be separated. By virtue of its decentralised nature, the DeFi ecosystem likewise raises regulatory challenges that will need to be addressed.

With this in mind, the ACPR has begun identifying potential avenues of regulation. These were set out in a paper published in October 2023. They include three measures: (1) first preserving the resilience of public and private DLT infrastructure via security standards; (2) second, certifying smart contracts, even if this raises operational questions; and (3) third, regulating DeFi entry points to protect investors against the risks of abuse.

Work is continuing in 2024 with stakeholders on one of the ACPR's key proposals, namely the mandatory certification of smart contracts prior to their use.

My fourth and last point is about the use of our second lever, the adaptation of the services we provide in CeBM. It has taken the form so far of two major endeavours to prepare for such adaptation.

First, the Banque de France was the first central bank to launch an ambitious experimental programme on wholesale central bank digital currency (CBDC) for large- value payments, in 2020, to support DVP and PVP settlement processes of tokenised financial assets, both domestically and cross-border. The experiments are now pursued under the aegis of the ECB. The Banque de France's wholesale CBDC technical solution, based on our own DLT (DL3S), is one of the solutions currently trialed by the Eurosystem.

The Banque de France is also taking part in several important international initiatives, notably those spearheaded by the Bank for International Settlements' Innovation Hubs, to explore the future of market infrastructures and interoperability between traditional systems and different types of DLT. In the latest Project, Agorá, the Banque de France will represent the Eurosystem, and will explore with six other central banks worldwide the tokenisation of cross-border payments using both tokenised central bank money and tokenised commercial bank deposits in an ecosystem that preserves the two-tiered architecture of the financial system based on the concept of unified ledger.

The second major endeavour is our participation as a central bank of the Eurosystem to the preparation of the digital euro, but I do not develop this aspect as my colleague of the ECB will tell you more on this.

If and when we will deploy these CBDCs, wholesale and retail, remains uncertain as we speak. The only certainty we have and market participants should have, is that we will be ready to deploy them if and when we deem it necessary to meet our policy objectives, in line with our mandate. Let me stop there.

编译：浦榕

监制：崔洁

来源｜欧洲中央银行

版面编辑｜傅恒恒

责任编辑｜李锦璇、蒋旭

主编｜朱霜霜

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