Can Chinese Courts Find Money a Judgment Debtor Has Moved Into Digital RMB (e-CNY)?

The short answer

• Digital RMB wallet balances are property subject to enforcement: the People’s Court Case Database already contains a case in which the court had the operating institution freeze and transfer a wallet balance.
• But it isn’t “frozen with a click” like a bank deposit. Published cases and articles by enforcement officials show that wallets are currently traced mainly through in-person enquiries at each operating institution, and the court needs leads first.
• Moving money into digital RMB and hiding it in wallets opened under relatives’ or others’ phone numbers is concealing or transferring assets; in serious cases it may constitute the crime of refusing to enforce a judgment or ruling, and those who help may be pursued as accomplices.
• Category 4 wallets (phone number only, non-real-name) are capped at a RMB 10,000 balance, RMB 5,000 per day and RMB 50,000 per year, and from 1 January 2026 earn no interest — suitable for small anonymous payments, not for hiding large sums.
• Judgment creditors can do three things: demand truthful property reporting, submit specific wallet leads, and push for referral for prosecution if assets are maliciously transferred.

Why the question has become concrete only now

Discussion of enforcing against digital RMB used to be academic: wallets held little and few people used them. From 1 January 2026, the People’s Bank of China’s Action Plan on Further Strengthening the Digital RMB Management and Service System and Related Financial Infrastructure took effect, moving digital RMB from “digital cash” to “digital deposit money”, with real-name wallet balances earning interest at agreed rates. According to the central bank, 230 million personal wallets had been opened through the e-CNY app by the end of November 2025. As wallets hold more and look more like deposits, the enforcement question shifts from “is there anything?” to “how do we find and transfer it?”

Are digital RMB wallet balances enforceable property?

Yes, and there is authoritative support. In A Fund Partnership v. Ding, an enforcement case in the People’s Court Case Database (Database No. 2024-17-5-101-038; enforcement case (2023) Jing 0101 Zhi No. 6666, Beijing Dongcheng District People’s Court), the reasoning states (excerpt): “Digital RMB is legal tender in digital form issued by the People’s Bank of China, equivalent to physical RMB, with value and legal-tender status; designated operating institutions (banks) provide exchange and circulation services, and it is property available for enforcement.” The court served an enforcement ruling and a notice of assistance on the operating bank and had the debtor’s wallet balance transferred to the court’s account.

The legal basis is the Civil Procedure Law. Article 253 (excerpt): “The people’s court has the power to inquire with relevant units about the debtor’s deposits, bonds, stocks, fund shares and other property… Where the people’s court decides to seize, freeze, transfer or sell property, it shall issue a ruling and a notice of assistance in enforcement, and the relevant units must comply.” Article 255 (excerpt): “The people’s court has the power to seal up, seize, freeze, auction or sell the property of the debtor to the extent of the obligation, but shall leave the necessities of life for the debtor and their dependants.” My summary: wallet balances can be traced, frozen and transferred, while leaving the necessities of life for the debtor and family.

“Digital RMB can’t be traced” is only half true

The claim has some basis, because the enforcement route really is more roundabout. In the case above, the court first asked the PBOC’s Digital Currency Research Institute and was told “you can enquire at the operating banks”; enforcement officers then went from bank to bank, enquiring at counters, until they found the debtor had a wallet at one bank. After the branch froze it, the bank reported that “the current system cannot transfer digital RMB”; only after the head office and branch upgraded the system was the transfer completed. The case’s enforcement guidance notes that courts can learn whether the debtor has a wallet by questioning the parties, through property reports and on-site investigation, and enquire offline with operating institutions.

Frontline enforcement officials have publicly acknowledged the limits. Zhu Yixin, head of the enforcement bureau of the Shanghai High People’s Court, wrote in Journal of Law Application (2025, No. 10) that “the current online inquiry and control system cannot directly cover all types of virtual property”, and suggested that the PBOC open a digital RMB wallet interface. So digital RMB wallets are not yet fully covered by online inquiry and control as bank deposits are, and enforcement relies more on leads and offline cooperation (my summary, not legal text).

Hiding money in digital RMB can trigger the crime of refusing to enforce

First, concealing or transferring assets can itself be a crime. Article 313 of the Criminal Law (excerpt): “Whoever is able to enforce a judgment or ruling of a people’s court but refuses to do so, where the circumstances are serious, shall be sentenced to up to three years’ imprisonment, criminal detention or a fine; where especially serious, to three to seven years’ imprisonment and a fine.”

Second, the relevant time starts earlier than many think. Article 6 of the Supreme People’s Court and Supreme People’s Procuratorate Interpretation on Cases of Refusing to Enforce Judgments and Rulings (法释〔2024〕13号, in force from 1 December 2024): “Where a person, to evade enforcement, conceals or transfers property after the lawsuit begins and before the judgment takes effect, and after the judgment takes effect this is verified and they refuse to enforce when required, they may be found able to enforce but refusing to do so, with serious circumstances, and be prosecuted for refusing to enforce a judgment or ruling.” Under the interpretation, the lawsuit generally “begins” when the defendant receives the court’s notice to respond — so “switching wallets” after receiving that notice isn’t safe.

Third, helping someone hide money can create liability. Article 8 (excerpt): “A third party who knows that a person obliged to enforce is able but refuses to enforce a judgment or ruling, conspires with them and helps conceal or transfer property, making the judgment impossible to enforce, shall be treated as an accomplice in the crime of refusing to enforce a judgment or ruling.”

Judicial practice is equally clear. Among the 2025 typical cases on resolving enforcement difficulties published by the Supreme People’s Court in January 2026, a debtor whose own WeChat account was frozen registered a new account using his just-adult son’s identity, controlled it and used it to receive money, and was ultimately convicted of refusing to enforce a judgment. Changing the vehicle or the registered name doesn’t change the logic of “actual control” (my summary).

How much can the four categories of wallet hold?

According to banks’ published wallet classifications, personal wallets are divided into four categories by strength of identity verification: Category 1 requires in-person verification and has no balance cap; Category 2 has a RMB 500,000 cap; Category 3 a RMB 20,000 cap; Category 4 verifies only a phone number and is non-real-name, with a RMB 10,000 balance cap, RMB 2,000 per payment, RMB 5,000 per day and RMB 50,000 per year. The interest arrangements from 1 January 2026 cover only real-name wallets; Category 4 balances earn no interest.

Then phone numbers. The Ministry of Industry and Information Technology’s Implementation Opinions on Further Preventing and Combating Telecom Fraud (工信部网安函〔2016〕452号) require strict verification where “the same user holds five mobile phone cards nationwide with the same basic telecom operator or mobile virtual operator”. Under this “one ID, five numbers” rule, the same ID can hold five cards each with China Mobile, China Unicom and China Telecom — a dozen or more numbers in theory — and each number can open one Category 4 wallet per institution, so one could assemble a batch of small wallets.

But the practical value is limited: balance, daily and annual caps are small, there is no interest, every transaction leaves a trace, and each wallet maps to a phone number and operating institution, so once the court has a lead it can follow the chain. My summary: it only lengthens the time the court needs to find the money; it is not a safe vault.

If you are the judgment debtor

• Report your property truthfully, including digital RMB wallets. Refusing to report or reporting falsely can itself lead to fines or detention, and becomes a factor in finding refusal to enforce.
• Don’t open wallets under relatives’ or employees’ phone numbers or identities — that may drag them into accomplice liability.
• Don’t “empty and move” funds. Article 11 of 法释〔2024〕13号 provides (excerpt) that if all or part of the obligation is performed before prosecution and the circumstances are minor, prosecution may be waived; if performed before first-instance judgment, punishment may be mitigated or exempted.

If you are the judgment creditor

• Ask the court to issue a property-reporting order, and specifically request that the debtor’s digital RMB wallets and balances be ascertained.
• Provide concrete leads: the debtor’s payment habits, the operating institutions they use, and how their wages or business income are paid.
• Apply for an investigation order to obtain the phone numbers linked to wallets, transaction records and counterparties.
• If you find large transfers before or after the judgment took effect, gather the evidence and apply for referral to the police for prosecution for refusing to enforce, or bring a private prosecution.

Limitations

Three notes: first, the database case cited reflects enforcement practice in 2023; its reasoning remains instructive, but the digital RMB system changed after 1 January 2026 and courts’ practices vary. Second, on whether online inquiry and control now covers digital RMB wallets, public information goes only as far as “enforcement officials consider coverage incomplete”; individual cases must be checked. Third, the crime of refusing to enforce also requires the ability to perform and that the judgment became impossible to enforce, among other elements — you can’t conclude guilt just from “opening a wallet”. If you are handling a specific enforcement or refusal-to-enforce matter, contact Wang Xin: phone +86 186-0113-9509, WeChat wang223040.

This is an English edition of Wang Xin’s original Chinese article, 老赖把钱换成数字人民币，法院查得到吗？. It explains the law of the People’s Republic of China in general terms and is not legal advice for any particular case; outcomes depend on the specific facts and on how local authorities apply the rules.