In designing central bank digital currencies (CBDCs), it is imperative that central banks carefully consider its legal foundations. As with any form of money, CBDCs require a solid basis under public and private law to provide it with the necessary legal certainty and political support that will underpin its wide circulation. This Fintech Note examines the private law aspects of token-based CBDC primarily intended for retail use. It follows a previous IMF working paper that examines the legal foundations of CBDC under central bank law and its treatment under monetary law—the main public law aspects of CBDC.