Offline settlements with a digital pound: Lessons from the BoE’s report

16 June 2025
by Payments Intelligence

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What is this article about?

A Bank of England experiment proving that offline payments with a digital pound are technically feasible, but complex.

Why is it important?

It highlights major trade-offs in security, privacy, and policy that must be addressed before offline CBDC payments can scale.

What’s next?

Policymakers must resolve governance questions while the industry prepares for potential integration and standard-setting.

The Bank of England (BoE) has demonstrated that it is technically feasible to carry out offline payments with a digital pound. The experiment was carried out in partnership with Thales, Secretarium, and Consult Hyperion, demonstrating both the technical plausibility and the layered complexities of enabling a central bank digital currency (CBDC) to function without internet connectivity.

For payments leaders, the findings are not simply a technical footnote. If implemented, offline CBDC capability could introduce new consumer behaviours, shift merchant requirements, and alter the economics of digital payment acceptance. Simultaneously, it would entail trade-offs in security, user experience, and operational design that demand careful scrutiny across the industry.

Despite the success of the experiment, no final decision has been made on whether to implement an offline payment functionality if a digital pound were launched.

Industry Voices

Finality, settlement, and device-based transfers

The project assessed whether it was feasible to enable payments between parties who had no access to the CBDC network at the time of transaction, a scenario often triggered by poor connectivity or service outages. This “device-to-device” approach would allow smartphones or smart cards to store value locally and initiate peer-to-peer (P2P) or person-to-business transactions offline.

All solutions trialled were able to achieve “final and irrevocable offline CBDC payments,” meaning that once funds were transferred, the payee could spend them immediately, without needing to reconnect to the central ledger. These solutions functioned by pre-loading funds onto user devices via an intermediary, creating a separate offline balance within the digital wallet.

However, this structure introduced practical constraints. Offline functionality was contingent on the user having pre-downloaded funds, limiting its spontaneity during unexpected outages. Furthermore, wallets had to manage dual balances (offline and online), requiring users to actively choose between them when transacting. These mechanics underscore the critical role of user interface design in ensuring ease of use does not become a barrier to adoption.

Synchronous vs asynchronous payments

Two distinct payment flows were tested: 

  • Synchronous: where activity is required from both payer and payee in real-time. The payee’s device sends a payment request to the payer’s device, and the payer’s device generates a response (accept or decline) to that request. If the request is accepted, funds are immediately transferred from the payer’s device to the payee’s device. The payee’s device then verifies the payment and sends an acknowledgement to the payer’s device

Asynchronous: where the payer sends funds using the payee’s wallet ID, without the payee being present. The payment does not need to be sent to the payee’s device directly, and could be generated as a QR code, sent via SMS, or over email, for example. As the payment message includes the issuer’s public key, the payee’s device can verify the transaction upon receipt of the payment.

While asynchronous payments may appear more flexible, they introduce a major risk: irrecoverability. Once sent, funds are deducted from the payer’s device regardless of whether the payee ever receives them. In contrast, the synchronous model offered built-in safeguards, allowing for the recovery of funds in failed transactions.

This distinction has real-world implications. Retailers and service providers may favour synchronous models to mitigate payment disputes. In contrast, asynchronous payments could serve niche use cases, such as ticketing or peer-to-peer gifting, if paired with clear user warnings and fallback mechanisms.

Managing double spending and counterfeiting: Secure Elements and system Limits

Offline payments, by definition, occur outside the purview of real-time ledger reconciliation, thus introducing the risk of double spending (attempting to spend the same funds twice). The experiment explored multiple countermeasures, chief among them being the use of Secure Elements: tamper-resistant chips that store cryptographic keys and transaction data on user devices.

The experiment tested two implementation models: one in which the Secure Element contained the entire transaction capability, and another in which only sensitive keys were protected. Both approaches provided a degree of protection, but neither was perfect. The reliance on Secure Elements introduces new dependencies for manufacturers and wallet providers, and if compromised, could open the door to widespread fraud.

Storage limitations within these chips also constrained transaction volumes and the complexity of risk detection algorithms. For instance, smart cards had markedly less capacity than smartphones, affecting their ability to track suspicious behaviours or store chains of transaction history.

As a secondary measure, online reconciliation was used to detect anomalies when users eventually reconnected. While effective for post-transaction monitoring, this retrospective approach cannot prevent losses, a point the BoE explicitly highlighted in its reflections. Preventive mechanisms must therefore strike a balance between protection and practicality.

Transaction records and privacy

To enable double-spend detection and fraud analytics, it is necessary to store a local transaction record. Solutions ranged from full, cryptographically linked transaction histories to minimal or even non-existent record keeping. Each approach carries trade-offs between security, privacy, and device storage constraints.

The experiment showcased privacy-enhancing technologies, including data pseudonymisation, confidential computing, and ephemeral key management. These tools allowed transaction records to be shared with intermediaries for verification, without exposing personally identifiable information to the BoE’s core systems.

In future implementations, privacy controls will likely be tailored to specific use cases, with varying levels of transparency and traceability. The Bank’s commitment to privacy-by-design remains a cornerstone of trust-building, particularly as offline capabilities inherently increase the complexity of data flows.

Key Takeaways for Product Leads
Designing for resilience – Product insights from the BoE's offline digital pound experiment
Introduction – Why Offline Matters
The Bank of England's experiment confirms offline CBDC payments are technically feasible, offering new design possibilities for digital money. Product leads must consider how offline functionality can support resilience, broaden inclusion, and enhance customer experience in edge cases.
Device-Based Value Transfer – A New Paradigm
Offline payments transfer value between devices without internet access, requiring local storage and preloaded balances. This alters the conventional flow of funds, creating dual wallet states that must be clearly presented to users. Intuitive interfaces will be essential for adoption.
Synchronous vs Asynchronous – Usability vs Risk
Real-time (synchronous) and delayed (asynchronous) models each offer advantages. Synchronous enables reliable transfer but requires both parties to be present. Asynchronous supports flexibility but lacks delivery guarantees. Product design must align with the risk profile and customer expectations of each use case.
User Interface Implications
Offline functionality demands deliberate choices around interface simplicity, balance displays, and fallback mechanisms. The ability for users to seamlessly switch between offline and online funds must feel intuitive and safe, particularly in time-sensitive environments.
Communication Standards – Hardware Challenges Ahead
NFC and BLE both support offline transfers but come with trade-offs in reliability, data capacity, and user experience. Devices must support multiple standards, and merchants may need to adapt hardware to remain compatible with evolving CBDC acceptance methods.
Enabling Innovation – Fintech Opportunities
The evolving offline landscape opens space for product innovation—from smart wallets that manage dual balances to enhanced UX solutions for low-literacy users. Early movers can shape market expectations by demonstrating value in constrained environments.
Integration Complexity and Ecosystem Coordination
Offline payments require updated point-of-sale systems, firmware changes, and new backend APIs. Product teams must coordinate closely with terminal providers and acquirers to maintain compatibility and reduce friction during implementation.
Strategic Direction – Prepare for the Next Phase
Although no decision has been made on implementation, the technical viability of offline CBDC is now proven. Product leads should assess how offline readiness aligns with their long-term roadmap, particularly in segments where resilience and inclusion are key differentiators.

Communication protocols: NFC vs BLE

From a hardware integration perspective, the experiment tested several communication technologies to enable offline payments. Near-field communication (NFC) has proven effective for card-based transactions but has revealed ergonomic challenges, such as inconsistent reader placement across smartphones, which can affect ease of use.

Bluetooth Low Energy (BLE) offered more flexibility for phone-to-phone transactions and accommodated larger data transfers, making it better suited for Unspent Transaction Output (UTXO)-based payment models. However, BLE introduced latency and connection issues, particularly during the initial pairing process.

Ultimately, neither protocol emerged as superior; each complements different device types and use cases. This has implications for merchant acceptance infrastructure: payment service providers (PSPs) and terminal vendors will need to support diverse standards and develop hardware-agnostic interfaces.

Policy dependencies

Perhaps the most important finding of the experiment was not technical, but strategic. The feasibility of offline payments is deeply intertwined with policy decisions on liability, fraud thresholds, user protections, and regulatory oversight.

For instance, how much value can a user store offline? What are the obligations of wallet providers if a transaction fails or is fraudulent? Who bears the cost of reconciliation errors or counterfeit detection failures?

These are not engineering questions; they are matters of governance and legal architecture, and they must be resolved before any offline CBDC capability can be deployed at scale. As Diana Carrasco Vime, head of the Digital Pound Project, has reiterated, trust, security, and usability will determine whether the digital pound gains real traction.

Commercial and ecosystem implications

For payments firms, the potential introduction of offline digital pound payments raises both opportunities and operational questions. Retailers could benefit from reduced transaction costs, particularly on low-value payments where card fees remain disproportionately high. Merchants in rural or connectivity-constrained areas may also see value in cash-like functionality delivered via digital means.

The integration effort will not be trivial. As the BoE’s point-of-sale proof-of-concept demonstrated, existing terminals require firmware updates, secure key management, and potentially new back-end APIs to accommodate CBDC payments, particularly in offline mode. The ecosystem will need to coalesce around standards to avoid fragmentation.

Meanwhile, startups and fintechs have a window of opportunity to innovate. From smart wallets that optimise offline balances to fraud detection algorithms and user-friendly interfaces, there is scope to lead the market in enabling trusted offline transactions.

Next steps and strategic considerations

Key Takeaways for Compliance Leads
Trust and controls – Compliance priorities for offline digital pound implementation
Introduction – Policy-Driven Design
Offline payments introduce unique regulatory and compliance questions. The BoE's experiment shows technical feasibility, but legal, privacy, and liability issues must be resolved before wide-scale deployment. Compliance leaders play a critical role in shaping this foundation.
Fraud Risk – Managing Double Spending Without Real-Time Reconciliation
Offline mode breaks real-time ledger visibility, increasing the risk of double spending. Secure Elements offer partial mitigation, but are not infallible. Offline value transfers must be framed within defined risk tolerance levels and fraud detection capabilities.
Liability and Error Handling – Unanswered Governance Questions
The experiment underscores gaps in liability frameworks. Who is responsible if an offline transaction is compromised or never received? Compliance leads must engage in shaping rules around value caps, restitution processes, and failure scenarios.
Privacy and Data Minimisation – Balancing Transparency with Rights
To detect fraud, some transaction data must be stored locally. The BoE explored privacy-enhancing methods such as ephemeral keys and pseudonymisation. Compliance policies will need to reconcile verification needs with GDPR and user rights.
Standards and Certification – Securing the Edge
Offline CBDC shifts the trust anchor from central systems to user devices. Certification standards for Secure Elements, wallet providers, and POS terminals will be critical to ensure consistent security baselines across the ecosystem.
Reconnection Protocols – When and How to Synchronise
Compliance frameworks must define timeframes and procedures for reconciling offline transactions once a device reconnects. The longer the delay, the greater the monitoring burden. Enforcement and fallback rules will be needed to address stale or suspicious activity.
Education and Financial Literacy – A Prerequisite for Safe Use
Offline payments introduce behavioural complexity for end-users. Without proper education on risks and recovery processes, user mistakes could create liability. Compliance strategies should support education and ensure transparency in consumer protections.
Regulatory Engagement – Shaping the Policy Landscape
With key questions on liability, AML, and KYC unresolved, this is a pivotal moment for regulatory engagement. Compliance leads must influence upcoming standards to ensure offline CBDC models are secure, enforceable, and proportionate to the risks they introduce.

The Bank has made clear that no decision has yet been taken on whether the digital pound will include offline functionality. However, this trial confirms it is technically viable, albeit not without cost or complexity. The next phase will require a policy assessment to determine the risk appetite and strategic goals of such a feature.

For industry leaders, this is a crucial moment to engage. As the BoE moves toward a potential build phase by the middle of the decade, the voice of the private sector will shape how user experience, merchant integration, and risk management are operationalised.

Offline payments may never be the default mode of digital pound transactions but their availability could serve as a vital backup option, enhancing resilience, inclusion, and trust in a rapidly digitising economy.

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