Since 2022, banks seeking to provide access to China’s digital RMB (e-CNY) central bank digital currency were required to route participation through a group of ten designated major banks. This structure has now been significantly expanded, with direct access extended to 22 banks. At the same time, adoption in Hong Kong has accelerated markedly, with digital RMB wallet registrations reaching approximately 80,000 and merchant acceptance increasing from around 300 to more than 5,200.

While the expansion to 22 participating banks has been widely reported, the underlying rationale has received less attention. As of 1 January, the digital RMB initiative has shifted from a pure CBDC model toward a tokenized deposit framework. Although some providers may still offer access to a CBDC format involving direct claims on the central bank, the primary model now operates via commercial bank deposits. In this structure, the digital RMB represents a liability of the issuing commercial bank rather than the central bank, which also enables features such as interest-bearing balances.

This transition explains the broader inclusion of banks, now encompassing most of China’s systemically important institutions, with further expansion likely. Unlike a CBDC accessed through intermediary banks, a tokenized deposit model requires each participating bank to maintain control over its own deposit base and reporting obligations. While banks may be willing to report directly to the central bank, they are less inclined to share sensitive deposit data with competing institutions, making direct participation a structural necessity in this evolving framework.