Background. The emergence of central bank digital currencies (CBDCs) and privately issued virtual assets has challenged established assumptions about monetary sovereignty, financial regulation, and cross-border value transfer, particularly across the Global South.
Research problem. Existing scholarship tends to examine sovereign CBDCs and private crypto-assets in isolation, leaving the legal consequences of divergent national strategies insufficiently theorised.
Objectives. This article compares the legal architecture of China’s Digital Yuan (e-CNY) with Pakistan’s evolving virtual-asset regime to establish how each reconciles monetary sovereignty, financial stability, and innovation, and to draw lessons for emerging economies.
Methodology. The study adopts a qualitative, doctrinal, and functional-comparative design, drawing on primary legislation, regulatory instruments, and authoritative international standards, organised through an explicit analytical framework.
Key findings. China operationalises a centralised, sovereignty-driven CBDC embedded in existing monetary law, whereas Pakistan has moved, through the Virtual Assets Ordinance 2025 and the Virtual Assets Act 2026, from prohibition toward a statutory, risk-based licensing regime, while institutional capacity remains the binding constraint.
Policy implications. Regulatory effectiveness depends less on convergence with international norms than on statutory clarity, institutional coordination, and sequenced implementation. These findings are benchmarked against India, Singapore, and the European Union.
Publication Date: 2026-06-15