Kazakhstan’s plans for a central bank digital currency have reached a critical decision point, with the International Monetary Fund warning that legal certainty and tighter risk management must come before any large-scale rollout. In a high-level technical assistance report published in January, the IMF says the Digital Tenge project has made rapid technical progress but still lacks the legal and institutional foundations required for safe, long-term operation.
The assessment, based on IMF missions to Astana and Almaty in mid-2024, reflects a pattern familiar to European policymakers. Like the euro area’s digital euro debate, Kazakhstan’s experience shows that CBDC design is no longer mainly a technology question, but a legal, governance, and financial stability one.
The IMF notes that the National Bank of Kazakhstan and the National Payments Corporation of Kazakhstan are targeting the end of 2025 for an “industrial-grade” Digital Tenge platform. Since 2021, authorities have tested multiple proofs of concept and pilot use cases as part of a broader payments modernisation strategy that also includes fast payments and QR code standardisation.
However, the report identifies a central weakness. Kazakhstan’s current legal framework authorises the central bank to issue only banknotes and coins. According to the IMF, this creates uncertainty over the legal status of a digital currency and could undermine confidence if the Digital Tenge were widely adopted. The Fund recommends clarifying the treatment of digital central bank money across monetary, civil, and payments law before moving beyond pilots.
Financial stability risks also move into focus as authorities consider expanding use cases. While current retail pilots pose limited risk, the IMF warns that future scenarios, including large-value payments or links with crypto-asset ecosystems, could open new channels for systemic stress. These risks, the report argues, should be analysed early through targeted stress testing and coordination with financial regulators.
Governance is another recurring theme. The Digital Tenge project is currently driven by payments specialists, but the IMF calls for broader internal engagement within the central bank and across public authorities. As adoption grows, decisions on design and safeguards could carry macro-financial consequences, making cross-departmental oversight essential.
For European readers, the parallels are striking. The challenges facing Kazakhstan mirror many of the questions confronting the European Central Bank, from legal mandates and privacy guarantees to resilience and crisis readiness. The IMF’s message is clear: CBDCs are not just digital payment tools, but public monetary infrastructure that requires the same legal certainty and institutional backing as cash.
The work was funded by the Government of Japan through the IMF’s capacity development programme, underlining the growing international interest in how emerging and advanced economies navigate the path from CBDC pilots to production.