I

Congress enacted the County Currency Act to establish a federal safe harbor for what the statute calls a “county fiscal-credit circuit.” Participation is voluntary. A county may enter the program only when its State has authorized it to do so and the county has adopted a public implementing ordinance.

The Act permits issuance only in connection with a liquidated and lawfully approved county payable. Suppose, for example, that a county has accepted a contractor’s invoice in the face amount of $100,000, payable in 90 days. The county may immediately credit the contractor with a corresponding amount of County Currency, or CC, grossed up to compensate for the demurrage that will accrue before the invoice’s due date.

The contractor may hold the CC, transfer it to another willing participant, or use it in an exchange with another willing participant. A county property owner may acquire CC and tender it at par against that owner’s property-tax liability. Outstanding CC may not exceed the county’s collectible property-tax base, and no CC may be created except against an approved payable.

At the invoice’s due date, the original contractor may present CC for dollars, up to the unpaid face amount of the invoice. That conversion authority is recorded as a personal quota attached to the contractor, not as a property of the circulating CC balance. It cannot be assigned. A shopkeeper who receives 500 CC from the contractor does not thereby acquire a right to demand $500 from the county. The shopkeeper may transfer the balance to another willing person or, if the shopkeeper owes property tax to the issuing county, surrender it in satisfaction of that tax.

The Act expressly provides that CC is not legal tender; that private acceptance must be voluntary; that a county creditor may instead await payment in dollars; and that neither receiving nor transferring CC discharges a private debt without the creditor’s assent.

Fremont County established a certified circuit under the Act. Respondents, an association of financial institutions and several county taxpayers, brought this facial challenge. They alleged that CC is an unconstitutional bill of credit, that accepting it for property tax makes it legal tender, and that Congress exceeded its enumerated powers by facilitating its issuance.

The District Court entered judgment for the County and the United States. The Court of Appeals reversed. In its view, the combination of public issuance, transferability, dollar denomination, and tax acceptability necessarily made CC a bill of credit. The court further concluded that Congress could not authorize a State to do what Article I, §10, forbids.

We agree with the latter proposition. Congress cannot authorize a constitutional violation. We disagree, however, with the premise that the Act authorizes one.

II

We begin with two propositions that narrow the dispute.

First, a State cannot evade Article I, §10, by acting through a political subdivision. A county possesses only the fiscal authority its State has conferred upon it. Were a county to issue an instrument that the Constitution forbids its State to issue, the intervention of the county would not save it. As this Court explained in Briscoe v. Bank of Commonwealth of Kentucky, a State cannot accomplish indirectly what the Constitution prohibits it from doing directly. 11 Pet. 257, 291, 318 (1837).

Second, congressional approval cannot cure an actual violation of the Bills of Credit Clause. Some provisions of Article I, §10, permit state action with the consent of Congress. The prohibition against bills of credit does not. Congress may regulate within the constitutional boundary; it may not erase the boundary.

The question, then, is not whether Congress has excused a prohibited bill of credit. It is whether CC falls within that constitutional category in the first place.

In Craig v. Missouri, this Court described bills of credit as a public medium intended to circulate among government and individuals for the ordinary purposes of society. 4 Pet. 410, 432 (1830). Briscoe refined the definition: the instrument must be issued by sovereign authority, carry a pledge of the sovereign’s faith, and be designed to circulate as money. 11 Pet., at 314. Later cases cautioned that the clause does not encompass every negotiable public obligation, every state promise to pay money, or every instrument that can occasionally be used in place of money. Poindexter v. Greenhow, 114 U. S. 270, 283–284 (1885); Houston & Texas Central R. Co. v. Texas, 177 U. S. 66, 83–86 (1900). The constitutionally relevant circulation is general circulation as a representative and substitute for money in the common transactions of business. (Craig v. Missouri)

Those decisions identify three connected characteristics.

A prohibited bill of credit is issued by the State or its agent. It embodies a debt or promise resting on the public faith and carried by the instrument to its holder. And it is designed, through its legal incidents and practical operation, to pass generally from hand to hand as public money.

The digital form of CC does not remove it from constitutional scrutiny. A State could not escape Article I, §10, merely by moving an otherwise prohibited note from paper to a ledger. Substance controls. But the converse is equally true: describing an entry as “currency,” making it transferable, or storing it electronically cannot supply legal characteristics that the entry does not possess.

Article I, §10, is not a general constitutional prohibition against liquidity.

III

A

The Court of Appeals’ central error was to combine two rights that the Act deliberately and legally separates.

The first is the transferable CC balance. That balance entitles its holder to transfer it voluntarily or to surrender it at par against property tax owed to the issuing county. It does not entitle the holder to demand dollars, coin, federal currency, or any other asset from the county treasury.

The second is the original creditor’s settlement option. That option arises from a particular approved county payable. At the payable’s due date, the named creditor may present CC and receive dollars up to the remaining face amount of that payable. The option is personal, nonassignable, and separately recorded. Transferring CC does not transfer the option.

The circulating balance therefore does not carry the county’s dollar obligation with it.

That distinction is not merely formal. It determines the legal position of every transferee. A person who receives CC from a county contractor does not become a creditor of the county. That person cannot present the balance to the county treasurer and demand money. The person cannot sue upon the contractor’s invoice. The person does not succeed to the contractor’s conversion quota. If the person owes no property tax to the county and finds no willing transferee, the county owes that person nothing.

A bill of credit says, in substance, the State owes the bearer. The transferable component of CC says something materially different: when the holder owes this county a property tax, the county will recognize this credit against that liability.

The direction of the obligation is reversed. In the first case, the holder is the government’s creditor. In the second, the county remains the tax creditor, and the holder possesses a statutory means of reducing what the holder owes.

When CC is tendered for property tax, the county does not redeem a public debt. No dollars leave the treasury. The holder’s tax liability is reduced, and the surrendered CC is retired. That is a tax offset or setoff, not payment upon a circulating promise of public indebtedness.

Respondents answer that the county has nevertheless pledged itself to accept CC for tax, and that this commitment gives CC its value. That is true but insufficient. Every statutory tax credit depends upon the government’s obligation to honor the law creating it. A taxpayer may obtain judicial relief if an official refuses to recognize a lawful deduction, exemption, credit, or prepayment. But a statutory limitation upon what the government may collect is not thereby transformed into a public promise to pay money.

The value of the circulating CC balance rests primarily on the existence of county tax liabilities against which it may be used. It does not rest on the county’s promise to redeem the balance in money for whoever happens to hold it. The county’s dollar obligation rests on an altogether different legal relationship: its account payable to the original creditor.

States and their subdivisions are not prohibited from incurring accounts payable or giving creditors written evidence of those obligations. In Houston, the Court considered treasury warrants issued in payment of existing state debts, transferable by their recipients, and receivable for taxes and other sums due the State. The Court declined to treat those warrants as bills of credit merely because they could sometimes pass in commerce. It emphasized the States’ necessary authority to recognize and arrange payment of their debts. 177 U. S., at 83–87. (Houston & Texas Central R. Co. v. Texas)

The County Currency Act is more restrictive in one constitutionally important respect: even the right to obtain eventual dollar payment does not pass to a transferee. It remains with the creditor to whom the county incurred the underlying payable.

B

There is no denying that CC possesses money-like characteristics. It is denominated by reference to the dollar. It is transferable. The system is intended to facilitate exchanges among participants. And the published description calls it a local means of payment.

Those facts make the question serious. They do not decide it.

The phrase “designed to circulate as money” is a constitutional term informed by the historical object of the Bills of Credit Clause. It does not encompass everything that can be transferred in satisfaction of an obligation. Checks, warehouse receipts, stored-value balances, vouchers, tax credits, negotiable instruments, and contractual setoffs may all mediate exchanges. Their usefulness in commerce does not alone make them sovereign money.

The circulation contemplated by Craig, Briscoe, Poindexter, and Houston is circulation as a generally available representative and substitute for money, resting upon public credit and suited to the ordinary transactions of the community.

CC does not have that legal fitness.

No private person must accept it. It cannot be forced upon a landlord, employee, lender, judgment creditor, merchant, or county contractor. It does not discharge a private debt except by agreement. It cannot be tendered for federal taxes, state taxes, the taxes of another county, judicial judgments, or public charges generally. It carries no transferable right to dollars. It is issued only against an existing approved payable. Its total quantity is bounded by the issuing county’s collectible property-tax base. And its balance is subject to disclosed demurrage rather than guaranteed preservation as a dollar-equivalent store of value.

The Act thus confines CC to a particular fiscal circuit. The county originates a tax offset in connection with an existing payable. Willing persons may assign that offset among themselves. A person owing property tax eventually returns it to the county. The original creditor alone retains a separate route to dollar settlement of the original invoice.

Voluntary assignments may occur several times before the credit reaches a taxpayer. That does not change the nature of what is assigned. A transferable tax offset does not become sovereign paper money merely because the assignment mechanism is efficient.

The Court of Appeals placed considerable weight on the description of CC as “currency” and on the statement that demand at tax time “makes CC money.” But the constitutional question cannot be answered by a project’s chosen vocabulary. Calling an account entry a “coin” does not make it coinage. Calling a tax offset “money” does not make it a bill of credit. And calling a transfer “payment” does not make the transferred asset legal tender.

Labels are evidence of intended use. They are not substitutes for examination of legal incidents.

C

Craig does not require a different result.

The Missouri certificates invalidated there were issued under state authority as standardized public instruments; state funds and the State’s faith were pledged to their redemption; and they were structured to serve as an ordinary circulating medium. The holder possessed the State’s promise embodied in the certificate itself. The public credit traveled with the paper. Craig, 4 Pet., at 425–436. (Craig v. Missouri)

With CC, it does not.

The person-to-person balance contains no dollar promise enforceable by its holder. The only cash-settlement right belongs to a named county creditor and remains attached to that creditor after the associated CC has been transferred. The right that circulates is the tax offset; the right that rests upon the county’s promise to pay dollars does not circulate.

Poindexter is instructive. There, the Court held that even state-issued bearer coupons promising payment and receivable for taxes were not automatically bills of credit. Tax acceptability, negotiability, and a public payment obligation were not alone conclusive; the constitutional inquiry concerned whether the instruments were issued as general paper currency. 114 U. S., at 283–284. Houston likewise held that transferability and tax acceptability fell short without the characteristics of a general substitute for money. 177 U. S., at 84–86. (Poindexter v. Greenhow)

CC presents the converse combination. Its tax-offset component is intended to be transferred, but it lacks the bearer promise of public payment. Its dollar-payment component rests on county credit, but it is personal and does not transfer. Respondents would splice the two components together and attribute every incident of either to both. The statute does not.

Nor is the separation illusory. A transferee bears risks the original creditor need not bear. The transferee has no conversion quota, may incur demurrage, and must either owe county property tax or find another willing participant. Those consequences demonstrate that the county has not placed its dollar credit behind the circulating balance.

A State could not evade the Constitution by pretending that a transferable redemption right was personal while permitting every holder to exercise it in practice. Courts would look through that device. Here, however, the separation is enforced by the ledger, the statute, and the legal rights of the parties. It is the actual substance of the transaction.

We therefore hold that the certified CC balance is not a bill of credit. It is an assignable, demurrage-bearing county-tax offset connected at origination to an existing county payable. The original creditor’s separate and nonassignable settlement option does not convert that offset into circulating public debt.

IV

Respondents next invoke the Tender Clause. They contend that, because the county treasurer must accept CC at par for property tax, the county has made CC “a Tender in Payment of Debts.”

That argument mistakes both “tender” and “debts.”

To make an instrument legal tender is to give a debtor the legal power to compel a creditor to accept it in discharge of an obligation. The County Currency Act gives no private debtor that power. Every private transfer requires assent. A merchant remains free to accept dollars and refuse CC. A lender remains free to demand the contractually specified payment. A county contractor may decline CC and await payment in dollars. Federal legal tender is not displaced.

The county’s obligation to accept CC applies only to a tax imposed by that same county. Taxes, however, are not “debts” in the relevant constitutional sense. They arise from sovereign authority rather than contract.

In Lane County v. Oregon, this Court held that a State retained authority to determine the medium in which its taxes would be collected and that taxes were not debts within the federal legal-tender legislation then before the Court. 7 Wall. 71, 76–78 (1869). Hagar v. Reclamation District No. 108 likewise distinguished taxes and assessments from debts “founded on contracts, express or implied.” 111 U. S. 701, 707 (1884). (Lane County v. Oregon)

The same distinction controls here. Fremont County has not directed one private person to receive CC from another. It has prescribed an additional means by which a taxpayer may satisfy an exaction owed to the County itself. The taxpayer may use CC or sovereign currency. The County is determining what it will recognize in settlement of its own tax claim; it is not imposing a medium upon an unwilling creditor.

Were a county to declare that CC discharged mortgages, wages, judgments, rents, or other private debts over a creditor’s objection, a different case would be presented. The Act expressly forbids that result.

Nor has the County “coined Money.” CC is an entry on an identified ledger, not a metallic coin or token. The project’s use of the verb “mint” is colloquial. Creating a ledger balance is not the constitutional act of coinage.

Finally, accounting for one CC as one dollar when determining a county tax offset does not regulate the value of United States money. It measures the amount of the tax credit. A government does not purport to alter the value of the dollar whenever it denominates a contract, fee, refund, deduction, or tax credit in dollars.

V

Having concluded that the certified arrangement does not violate Article I, §10, we consider whether Congress possessed authority to enact the County Currency Act.

It did.

Congress has authority to coin money and regulate its value, to borrow on the credit of the United States, to regulate interstate commerce, and to enact laws necessary and proper for carrying those powers into execution. This Court has long recognized that those powers permit Congress to establish and protect a national currency.

In Veazie Bank v. Fenno, the Court explained that Congress may issue national obligations, make them receivable by the Government, fit them for voluntary commercial use, and protect the resulting currency system through appropriate legislation. 8 Wall. 533, 548–549 (1869). Juilliard v. Greenman reaffirmed Congress’s broad authority over national paper currency and its circulation. 110 U. S. 421, 448–450 (1884). (Veazie Bank v. Fenno)

The authority to protect a national currency includes authority to regulate instruments that might compete with, imitate, burden, or be confused with it. Congress need not choose only between complete prohibition and complete inattention. It may draw a boundary between prohibited substitutes for national money and limited fiscal instruments that may coexist with it.

The County Currency Act draws such a boundary. It requires disclosure that CC is not legal tender. It prohibits compulsory private acceptance. It denies cash redemption to transferees. It ties issuance to audited public payables. It limits tax acceptance to the issuing county’s property tax. It caps outstanding balances by collectible taxes. And it requires the personal conversion quota to remain distinct from the transferable balance.

Those conditions are plainly adapted to Congress’s legitimate objective of preserving the supremacy and uniformity of the national currency while allowing bounded local fiscal practices that do not purport to replace it.

Congress has not delegated to counties the power to issue United States money. CC is not an obligation of the United States. The Treasury does not redeem it. It is not lawful money, and Congress has not declared it legal tender. Federal certification establishes only that a county program satisfying the Act’s conditions does not conflict with federal monetary law.

Once again, we do not hold that Congress may authorize what Article I, §10, forbids. We independently hold that this Act authorizes an instrument outside the prohibition.

The Act also respects the constitutional division of authority between the Nation and the States. It does not order a State to establish county currency, enact legislation, collect taxes in CC, or administer a federal program. A State remains free to deny its counties authority to participate. A county authorized under state law remains free to decline federal certification.

Printz v. United States and Murphy v. National Collegiate Athletic Assn. prohibit Congress from commanding state legislatures or executive officers to enact or administer federal regulatory programs. They do not prevent Congress from offering an optional federal legal status to a State or subdivision that independently chooses to undertake a regulated activity. 521 U. S. 898, 935 (1997); 584 U. S. 453, 471–480 (2018). (Murphy v. NCAA)

Here, the federal government administers the certification system. The County administers its own payables and its own property tax under authority derived from state law. No government has been commandeered to administer the laws of another.

VI

Our holding is confined to the architecture Congress enacted and Fremont County implemented.

A materially different system might produce a different constitutional result. That would be so if a county allowed the right to dollar conversion to travel with the balance; compelled private creditors to accept the balance; declared it sufficient to discharge judgments or contractual debts; issued it independently of valid county payables; pledged its general faith to cash redemption by every holder; or operated it as a general substitute for United States currency.

Actual operation also matters. A nominal tax-credit system could not escape scrutiny if its supposed limitations were abandoned in practice and the county in substance placed bearer obligations into general circulation as money.

But courts may not invalidate the program before us by attributing to it features the statute prohibits. Under this Act, the bearer does not hold the county’s promise to pay. The original creditor’s promise of dollar settlement does not circulate. Private acceptance is voluntary. County acceptance is confined to the County’s own property tax. The transferable balance is therefore neither a bill of credit nor legal tender in payment of debts.

The Constitution forbids States from emitting public promises as circulating money. It does not forbid a county from making a bounded tax offset assignable, or forbid Congress from regulating the conditions under which that assignment may occur.

The judgment of the Court of Appeals for the Eighth Circuit is reversed, and the case is remanded for proceedings consistent with this opinion.

It is so ordered.