Bitcoin and Digital Assets in El Salvador

The Bitcoin Law after the 2025 reform

• Voluntary acceptance: only individuals and wholly private companies may accept Bitcoin, when it is offered as payment (article 7). Nobody is required to accept it.
• The dollar stays: article 1 applies without prejudice to the Monetary Integration Law, which makes the US dollar legal tender.
• The State: the reform removed the use of Bitcoin for tax payments and the State guarantee of conversion into dollars; State debts are paid in the currency in which they were contracted (article 12).
• Capital gains: Bitcoin exchanges are not subject to capital gains tax (article 5).

Source: Bitcoin Law, Decree No. 57 of 2021, text with the 2025 reforms (Supreme Court legal documentation centre, PDF, in Spanish); Reuters: Lawmakers in El Salvador rush new bitcoin reform after IMF deal (30 January 2025)^1,2

Sources disagree on whether Bitcoin is still legal tender. The text published by the Supreme Court legal documentation centre words article 1 as regulating Bitcoin "como curso legal" with voluntary acceptance, and CEPAL describes it as legal tender with voluntary acceptance. Latin Counsel reports that the references to Bitcoin as legal tender were deleted. Treat Bitcoin as a voluntary means of payment and ask a Salvadoran lawyer how the current text applies to your contracts.^1,3,9

The two registers

Source: Central Reserve Bank: Registered Bitcoin service providers; CNAD: Register of digital asset service providers; CNAD: List of issuers^4,5,6

The BCR register notes that the authorisation to operate is issued by the CNAD. Before you use a provider, check both registers and the status shown.⁴

Chivo, public holdings and the IMF

• Chivo: ownership and operational control of the government e-wallet were transferred to a private operator; the government kept a minority stake and custody duties for customer assets.
• Accumulation: the IMF said in September 2026 that Bitcoin added since the first review came from documented private donations and that no public resources were used. In October 2026 it granted waivers for missed Bitcoin accumulation criteria and said no further accumulation is envisaged beyond the documented donations.
• Next steps: the IMF asks for more disclosure of public crypto holdings, stronger supervision of crypto providers and amendments to the Digital Assets Issuance Law.

Source: IMF: Staff-level agreement on the combined second and third reviews under the EFF (3 September 2026); IMF: Executive Board concludes the second and third reviews under the EFF for El Salvador (1 October 2026)^7,8

The government Bitcoin Office publishes a running balance of the holdings it reports. The IMF counts the additions since its first review as documented private donations rather than purchases with public money.⁷

Where digital assets meet the financial system

• Stock exchange: Digital Exchange (DAX), a subsidiary of the Bolsa de Valores de El Salvador, was authorised by the CNAD in August 2025 as a digital asset service provider.
• Investment banks: under the 2025 Investment Banks Law, an investment bank may seek authorisation as a digital asset or Bitcoin service provider, and clients may count bitcoin and stablecoins towards the USD 250,000 threshold.
• Tax: income and gains on regulated digital assets are exempt from all taxes under the Digital Assets Issuance Law; see the digital assets rules.

Source: Bolsa de Valores de El Salvador: Annual corporate governance report 2025; Diario El Mundo: New banking law for sophisticated investors approved^10,11