INTERNATIONAL MODELS OF STATE REGULATION OF CENTRAL BANK DIGITAL CURRENCIES: LESSONS FOR UKRAINE

Abstract

The article focuses on contemporary international models of state regulation of CBDC
(central bank digital currency) and on governance lessons relevant to Ukraine in the context of the
possible implementation of the e-hryvnia. In 2025-2026, the global debate on CBDC is moving away from
expectations of rapid mass implementation and is increasingly focused on legal regulation, piloting,
institutional coordination, privacy protection and public trust. The limited number of fully launched central
bank digital currencies does not reduce the relevance of this instrument; rather, it shows that CBDC is
moving from the sphere of technological experimentation to the sphere of responsible state regulation.
The study identifies several regulatory logics of CBDC development. The politically restrictive
model is considered through the example of the United States, where CBDC has become the subject of
legislative restriction due to concerns about privacy, financial freedom and excessive state control. The
legally preparatory model is analysed through the case of the European Union, where the digital euro is
moving through legislative coordination, piloting, participation of financial intermediaries, offline
functionality and privacy safeguards. The large-scale institutional model is examined through the example
of China, where e-CNY is gradually being integrated with banking and payment infrastructure. The pilotexperimental approach is characterized through the experience of India and Brazil, which are testing
selected CBDC use cases, including programmability, offline payments, tokenization and smart contracts.
Particular attention is paid to the cross-border / wholesale model represented by mBridge, which
demonstrates the potential of CBDC in the field of international settlements.
For Ukraine, international CBDC experience is important not as a set of ready-made solutions to be
copied, but as a basis for developing its own model of cautious regulatory readiness. The e-hryvnia
should be considered not only as a new payment instrument, but also as a complex object of state
regulation that requires legal definition, institutional coordination, privacy protection, preservation of the
role of the banking sector, limitation of programmability and systematic communication with citizens. The
positive lesson for Ukraine is not the need for a rapid launch of the e-hryvnia, but the opportunity to
prepare its implementation with due regard to international risks, limitations and different models of
regulatory response.