The combined second and third reviews of El Salvador’s program with the International Monetary Fund (IMF) left an element that is unusual in this type of document: a chapter devoted to digital assets. According to the Fund’s official press release, published on September 3, 2026, the parties agreed on measures to modernize the legal, regulatory and supervisory framework for digital assets and to strengthen the governance of the public sector’s crypto-asset holdings.
The announcement is a staff-level agreement, not a final decision: it requires approval by the IMF’s Executive Board and the completion of prior actions. If approved, it would enable a disbursement of close to USD 140 million (SDR 101.96 million).
A staff-level agreement with regulatory content
The program in force is a 40-month Extended Fund Facility (EFF). In the end-of-mission statement, the mission chief for El Salvador, Mr. Torres, lists the understandings reached on fiscal, financial, transparency and digital asset matters. The latter appear grouped into two distinct lines of work, and it is worth separating them because they do not mean the same thing.
Legal, regulatory and supervisory framework
The first line targets the sector as a whole: modernizing the legal, regulatory and supervisory framework for digital assets. The release states the commitment without breaking it down. It does not mention which rules would be reformed, which entity would exercise supervision, which activities would be covered or on what timeline. Any reading about licenses, capital requirements or custody regimes would, today, be an extrapolation the document does not support.
Governance and risk management of public crypto-assets
The second line is narrower and targets the state’s balance sheet: strengthening the governance and risk-management mechanisms applicable to the public sector’s crypto-asset holdings. It is the part of the agreement that treats Bitcoin in state hands as an asset that must be subject to internal controls, not as a political position.
Added to this is a transparency objective: the IMF notes that efforts continue to improve the transparency of Bitcoin holdings across the various wallets.
What happens with Chivo
The release describes a change in the structure of the state wallet. The public stake in Chivo was substantially reduced: majority ownership and operational control passed to a private operator, while the government kept a minority stake and custodial responsibility over client assets.
That division matters from a risk standpoint. Management of the service is in private hands, but the custody obligation toward users remains with the public sector. The IMF does not identify the operator or quantify the remaining state stake.
The IMF’s explanation of the BTC accumulation
On the point that draws the most media attention, the Fund is brief. In the Spanish version of the release: “La acumulación de Bitcoin desde la primera revisión refleja donaciones privadas y no ha implicado el uso de recursos públicos” — “Bitcoin accumulation since the first review reflects private donations and has not involved the use of public resources” (our translation). The English version further specifies that documentation was provided verifying that origin.
The release adds a forward-looking condition: no additional Bitcoin accumulation is envisaged beyond the documented donations. In the document’s summary, the IMF sums it up by stating that no public resources have been used for Bitcoin accumulation.
Economic situation and program financing
The macroeconomic context accompanying these decisions is favorable, according to the Fund itself. Real GDP growth exceeded expectations in 2025 and is expected to reach 4.5% in 2026, supported by private investment and consumption and by robust flows of remittances, tourism and capital. The IMF links that performance to improvements in security and greater investor confidence, and states that the program contributes to a significant reduction in poverty.
On the fiscal front, the primary surplus of the Non-Financial Public Sector would rise from 2.9% of GDP this year to 3.7% of GDP in 2027, in line with the Fiscal Responsibility Law’s goal of bringing public debt to 80% of GDP by 2030. Also planned are a parametric pension reform next year, a civil service reform and improvements to the anti-money-laundering and counter-terrorist-financing framework, along with the publication of asset declarations by senior officials.
The financing figures
- Extended Fund Facility approved on February 26, 2025 by the IMF Executive Board.
- Total access: SDR 1,033.92 million, about USD 1.4 billion, equivalent to 360% of quota.
- First review completed on June 27, 2025.
- Disbursed to date: SDR 172.32 million.
- Disbursement pending approval at this stage: approximately USD 140 million (SDR 101.96 million).
What this stage may mean for the Salvadoran ecosystem
With the information available, what the release allows us to state is limited but concrete: there is a policy commitment to review the regulatory and supervisory framework for digital assets, and there is a parallel commitment to bring order to the governance of the crypto-assets held by the state. Both figure among the understandings of a program with conditionality, which means their progress will be assessed in future reviews.
What the document does not allow us to state is just as important. There is no published regulatory text, no timeline, no description of the regime that would replace or complement the current one, and no pronouncement on how it would affect digital asset service providers operating in the country. Until the staff report and the Board’s decision appear, any assessment of market impact is premature.
For the region, the case retains its value as a reference. The Dominican Republic is going through its own discussion on how to frame crypto-assets: scattered rules that reach them already exist, but not a sector-specific law, and the legislative path on digital assets between 2023 and 2026 shows a process that is still open. The Salvadoran file offers a precedent on how a multilateral body translates these matters into program commitments.
Source: International Monetary Fund press release No. 26/285, September 3, 2026.
Image: institutional seal of the International Monetary Fund (IMF), taken from the official publication cited. Source: International Monetary Fund (IMF).
