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The BIS Critique of Crypto: Why It Backs a Unified Ledger, Not Coins

Quick answer: The Bank for International Settlements (BIS) argues that crypto has structural flaws (no nominal anchor, a tendency to fragment, and congestion-driven fees) and that the useful features people associate with crypto, programmability, composability, and tokenisation, can be built instead on central bank money and fast payment systems. Its proposed alternative is a “unified ledger.” The BIS does not endorse any specific token.

Updated 07/17/2026. By Jake Claver. Educational content, not investment advice.

The BIS is often cited by crypto investors as validating tokenisation. That is only half the story. Across its 2022, 2023, and 2025 Annual Economic Reports, the BIS makes a pointed critique of crypto as a foundation for the monetary system, and then argues the future belongs to tokenised central-bank and commercial-bank money on shared infrastructure. Reading the reports as endorsement misses the argument. Here is what they actually say, quoted directly.

The core critique: crypto lacks a nominal anchor

The BIS 2022 chapter on the future monetary system starts from a structural point: crypto cannot anchor its own value. Stablecoins, in the BIS view, prove the weakness rather than solving it, because they must import the credibility of the central bank’s unit of account to hold their peg. Sound money, the argument goes, needs an anchor that crypto does not natively provide.

Fragmentation and the scalability trilemma

Traditional money benefits from network effects: the more people use one unit, the more useful it becomes. The BIS says crypto shows the opposite tendency, which it memorably calls “the more the sorrier.” The mechanism is the scalability trilemma: permissionless blockchains can achieve only two of three properties among scalability, security, and decentralisation. Limited capacity drives high fees, which incentivises new chains that cut corners, fragmenting the ecosystem instead of consolidating it.

The report is also blunt about incentives and cost. The way validators get paid, it argues, is by keeping blockchain capacity limited so that congestion keeps fees high. That is a structural cost, not a temporary growing pain.

The DeFi centralization paradox

The BIS does not spare decentralized finance. Despite decentralization rhetoric, it points to real concentration: governance tokens clustered among developers, oracles operating off-chain, and centralized exchanges dominating actual trading volume. The claim is that DeFi’s decentralization is often more marketing than mechanism.

BIS website showing the future monetary system and crypto critique report
Close-up of the BIS report on tokenisation, CBDCs, and fast payment systems

The BIS alternative: a unified ledger

Having criticised crypto’s foundations, the BIS makes a constructive move. Its key line from 2022 is that the sought-after capabilities are “not the preserve of crypto, but can instead be built on top of central bank digital currencies (CBDCs), fast payment systems and associated data architectures.”

In 2023 it named the design. The BIS blueprint press release proposes a “unified ledger,” a programmable platform bringing tokenised central bank money, commercial bank deposits, and other assets onto shared infrastructure so they can settle and interact in real time. As the BIS puts it, combining central bank money, commercial money, and different assets on the same tokenised platform “opens up a whole new range of possibilities.” The full argument runs through the 2023 unified-ledger chapter.

The 2025 update: stablecoins fail the three tests

The BIS 2025 chapter sharpens the stablecoin verdict. It assesses stablecoins against three tests for sound money and finds them wanting: singleness (they trade as bearer instruments from different issuers, not reliably at par), elasticity (new issuance requires full upfront backing, so supply cannot flex), and integrity (pseudonymous assets on permissionless chains raise financial-crime concerns). Its summary line: stablecoins “perform poorly when assessed against the three tests for serving as the mainstay of the monetary system.” The prescription is the same, tokenise central-bank and commercial-bank money on trusted infrastructure.

One honest caveat about tokens

It is tempting to attach specific assets like XRP or XLM to the BIS tokenisation story. The BIS reports do not do that. They discuss CBDCs, tokenised deposits, fast payment systems, and a central-bank-anchored unified ledger. Reading a token endorsement into that requires words the BIS did not write. The honest read is a design direction from a central-bank body, kept separate from any investment thesis.

Why this matters

The BIS is the central bank for central banks, so its critique shapes how regulators and monetary authorities think about tokenisation. The practical takeaway is that the institutional path favors tokenised central-bank and bank money on shared ledgers, with crypto’s structural flaws treated as reasons to build differently, not to copy the model. For readers weighing where regulated tokenisation is headed, the reports themselves are the primary source. For U.S. regulatory framing of digital assets, the CFTC digital assets page is a useful companion reference.

Common questions

What is the BIS critique of crypto?

The BIS argues crypto lacks a nominal anchor, tends to fragment because of the scalability trilemma, relies on congestion-driven high fees to pay validators, and that DeFi is more centralized in practice than it claims. It concludes crypto is a weak foundation for the monetary system.

Does the BIS support tokenisation?

Yes, but on its own terms. The BIS supports tokenisation built on central bank digital currencies, tokenised bank deposits, and fast payment systems, combined in a “unified ledger,” rather than on permissionless crypto.

What is the BIS unified ledger?

It is a proposed programmable platform that brings tokenised central bank money, commercial bank deposits, and other assets onto shared infrastructure so they can settle and interact in real time, as described in the BIS 2023 blueprint.

What does the BIS say about stablecoins?

In its 2025 report, the BIS says stablecoins perform poorly against three tests for sound money: singleness, elasticity, and integrity, and are not a suitable mainstay for the monetary system.

Does the BIS endorse XRP or XLM?

No. The BIS reports discuss CBDCs, tokenised deposits, and a unified ledger. They do not name or endorse XRP, XLM, or any specific cryptocurrency.

This content is educational only. It is not tax, legal, or investment advice. Check primary sources and speak with a qualified professional before making financial decisions.


Sources

    Jake Claver

    Written by

    Jake Claver

    Family office professional working on how substantial holdings are held, structured and passed on. Qualified Family Office Professional. Finance degree, University of North Texas. Board member, Arkansas Blockchain Council. Author of Wealth in Numbers and Infinite Banking for Crypto Investors.