Sandboxes, Crypto-Asset Rules and Central Bank Digital Currency: A Three-Layer Model of Digital Financial Policy

Аңдатпа

Digital financial policy is usually discussed as a set of separate problems: whether to operate a regulatory sandbox, whether and how to bring crypto-assets within the regulatory perimeter, and whether to issue a central bank digital currency. This article argues that the three are better understood as layers of a single institutional design problem, distinguished by the type of uncertainty each addresses and by the reversibility of the commitment each requires. Sandboxes form an experimentation layer addressing operational uncertainty about novel business models, with low commitment and high reversibility. Codified regimes such as the European Union's Markets in Crypto-Assets Regulation form a rule layer addressing legal uncertainty about asset classification and issuer obligations, with medium commitment. Central bank digital currency forms an infrastructure layer addressing structural uncertainty about the future of the monetary system, with very high commitment and near-irreversibility. Using the innovation-trilemma framework of Brummer and Yadav (2019), the article shows that each layer resolves the trilemma at a different point and that the layers are complements rather than substitutes: a sandbox without a rule layer generates cases that cannot be scaled, and a rule layer without an infrastructure layer regulates private money without providing a public alternative. The argument is developed against the evidence base to January 2025 and applied to the sequencing problem faced by emerging and transition economies. The article concludes that sequencing errors, rather than instrument choice, account for most disappointing outcomes, and proposes readiness conditions for advancing from one layer to the next.