Cash Access and Use in China

China is a key part of the discussions about access to cash worldwide. Any financial player interested in the market or touching it, even if tangentially, should understand that the country is advancing in its approach to digital methods of payment but also seeking to maintain its physical cash relevancy and structures.

The country’s legal framework for access to cash and its management is based on three legal instruments: the Law of the People’s Republic of China on the People’s Bank of China, the Regulations on the Administration of Renminbi, and the Regulations on Cash Management. Renminbi, the Chinese yuan, is the sole legal tender within the territory of the People’s Republic of China and its acceptance cannot be refused for the settlement of lawful debts and transactions. Secondly, the Anti-Money Laundering Law of the People’s Republic of China imposes reporting and monitoring obligations on financial institutions with respect to large cash transactions and governs the interaction between cash usage and financial crime prevention.

In recent years, government policy continues to strengthen the ‘anti-refusal-of-cash’ drive, protecting cash as a legitimate means of payment; on the other hand, large-value cash transactions are subject to reporting and registration requirements aimed at anti-money-laundering, anti-corruption and risk-control objectives. The Provisions on Renminbi Cash Receipt, Payment and Services (人民币现金收付及服务规定), effective from 1 February 2026, is the most significant cash-policy document of recent years, reaffirming the official position that cash remains indispensable. At the same time, the 15th Five-Year Plan’s formulation of ‘steadily developing the digital renminbi’ (稳步发展数字人民币) has made the medium-to-long-term relationship between cash and digital currency a central point of policy and discussion.

Mandatory Cash Acceptance

China's most significant recent development is the adoption of the ‘Regulations on Cash Receipt and Payment Services in Renminbi (人民币现金收付及服务规定). They came into force on 1 February 2026 and aim to (i) uphold the legal tender status of the Renminbi; (ii) prevent and rectify cash-refusal behaviour; (iii) meet the diverse payment service needs of the public; and (iv) create an environment in which cash may circulate conveniently alongside multiple payment methods. The People's Bank of China (PBOC) and its branches were given the authority to supervise and inspect any cash-refusal behaviour.

In more detail, the Regulations mandate the acceptance of cash payments for transactions and prohibit refusal or other discriminatory measures. Special provision is made for unmanned or self-service premises, such as unstaffed stores and vending machines, among others, where the Regulations seek to ease the use of cash. Operators must display the accepted payment methods, the cash conversion procedure, a service contact number, and may not charge handling fees for converting cash, nor impose conditions that make conversion inconvenient. In the banking sector, bank branches must handle cash deposit and withdrawal services and maintain sufficient ATM and cash-handling equipment. For one-off exchanges of large quantities of coins or small-denomination notes, banks must offer an appointment-booking or batch-processing service. Finally, in cases of emergency, banks are required to establish cash service emergency mechanisms to guarantee cash supply during natural disasters or system failures, and to strengthen the sorting of returned banknotes to prevent unfit currency re-entering circulation.

The Cashlessness Problem 

The adoption of the Regulations is a response to the rise in popularity of digital payments. With the proliferation of mobile payments via Alipay and WeChat Pay, a growing number of commercial operators had informally eliminated their cash-handling infrastructure. Additionally, banks decided to downsize their operations and closed thousands of branches across the country. This particularly disadvantaged the elderly, rural populations, foreign tourists, and those without smartphones. The official justification for the Regulations, as stated in the PBOC's published explanation, is that whilst mobile payment proliferation has brought convenience, it has simultaneously created a ‘two-tier’ payment environment incompatible with the principle of monetary sovereignty and equal access to legal tender.
IV. Macro Data on Cash in Circulation
According to the PBOC’s monthly/quarterly financial statistics releases, cash in circulation (M0) has been accelerating through 2026 rather than contracting. 
 

Furthermore, cash in circulation had already been growing at roughly 10-13% year-on-year throughout 2025, and even back into late 2024. The 2026 figures are not the result of the regulation, but a continuation of an existing trend. This shows that even as the use of mobile payments continues to expand, the absolute volume of cash in circulation in China has not shrunk. This contrasts with the assumption that ‘cash is being phased out’, and lends support to the regulatory logic behind the measures to reinforce the availability of cash-payment channels.

The Digital Renminbi (e-CNY): From Cash Substitute to Digital Deposit Currency

The PBOC issued the ‘Action Plan for Further Strengthening the Digital Renminbi Management Service System and Related Financial Infrastructure’, which took effect on 1 January 2026. The Action Plan reclassified e-CNY balances held in commercial bank wallets from M0 (physical cash in circulation) to deposit-based liabilities counted within M1 (M0 plus demand deposits) or M2 (M1 plus savings deposits). This means banks no longer remit 100% reserves to the PBOC for e-CNY in circulation; ordinary reserve ratios now apply, reducing the liquidity drag on the banking system and giving commercial banks a genuine financial incentive to promote the currency. From 1 January 2026, banks may pay interest on wallet balances at prevailing demand deposit rates. Bank-held e-CNY deposits are also now covered by China's deposit insurance framework, though non-bank payment institutions must still maintain 100% reserves. Wallets additionally support smart contract functionality, enabling programmable and conditional payments.

Currently, e-CNY adoption still faces challenges. Commercial banks have had limited incentive to promote it; consumer and corporate uptake has been weak; and cross-border payment channels remain underdeveloped. The Action Plan upgrade attempts to address the incentive problem by introducing interest. However, official statements make clear the e-CNY’s role as complementary to cash, and explicitly state that cash and the digital renminbi will coexist rather than one replacing the other.

In Summary 

As of mid-2026, China’s approach to cash access rests on two priorities. First, cash's legal status and everyday accessibility are being strengthened. The ‘Provisions on Renminbi Cash Receipt, Payment and Services’, reaffirms in detail that cash may not be refused, and makes accessibility for the elderly, disabled and foreign visitors a binding requirement. Second, the digital renminbi's positioning is evolving. The 15th Five-Year Plan's phrasing to ‘steadily develop’ it, together with the latest e-CNY framework, points toward a broader monetary role over time. The government is explicit in recognising the usefulness of digital currency and cash, stressing their complementary roles, and seeks a balanced regulatory approach supporting both.

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