Why the IMF Accepted El Salvador’s Bitcoin Donations Explanation

The IMF’s conclusion rests on documentation supplied by Salvadoran authorities. In its September 2026 staff-level agreement announcement, the Fund said the documents verified that Bitcoin accumulated since the June 27, 2025 first review of El Salvador’s Extended Fund Facility (EFF) reflected private donations and that no public resources were used. 627

That is significant, but narrow: it is the IMF’s acceptance of the government’s supporting documentation for program-compliance purposes. It is not the same as a public, independently reproducible accounting of every Bitcoin transfer.

What the IMF verified—and what remains opaque

The IMF’s reported finding was that post-review additions were privately donated rather than bought with state money. It also said it expected no further Bitcoin accumulation beyond the donations already documented. 641

However, the available public reporting does not name the donors or quantify each donor’s contribution. It also does not set out a public, transaction-level record showing donation dates, receiving addresses, terms, or the evidence used to link each transfer to a specific donor. 5

As a result, the public can distinguish the IMF’s program finding from a fuller transparency standard:

• Verified for the IMF: authorities provided documentation supporting the conclusion that no public resources funded the accumulation after the first review. 6
• Not publicly detailed: who donated the Bitcoin, how much each donor gave, and the complete path of each donation into state-controlled holdings. 5
• Future accumulation: the Fund said no additions beyond documented donations are expected, but the available material does not describe a publicly auditable framework for how a future private donation would be disclosed or treated. 641

How much did reported Bitcoin holdings rise?

Reported holdings increased from roughly 5,968 BTC around the June 2025 review to about 7,762–7,764 BTC by early September 2026—an increase of approximately 1,794 BTC. 4041

Those figures should be read carefully. They reflect the country’s reported or official-tracker balance as cited in news coverage; the supplied sources do not establish that this balance has been independently audited through a public reserve attestation. 41

The first EFF review itself was completed on June 27, 2025 and enabled an immediate disbursement of SDR 86.16 million, or about $118 million. 19

The policy changes tied to the IMF program

The EFF’s Bitcoin-related conditions focus on reducing public-sector crypto exposure and increasing visibility into state activity.

Chivo Wallet

Program documentation called for public participation in Chivo, the government e-wallet, to be gradually unwound. It also called for stronger transparency around Chivo’s finances, including publication of summary financial statements, liquidity-management policies, and transfers to and from the government. 17

By September 2026, reporting on the staff-level agreement said majority ownership and operational control had moved to a private operator. 616

Bitcoin use and public-sector exposure

The IMF program provides that government purchases of Bitcoin are prohibited during the arrangement. It also made private-sector acceptance of Bitcoin voluntary and required taxes to be paid only in U.S. dollars. 17

Before the first review, authorities had shared with IMF staff a signed statement identifying public-sector hot and cold wallet addresses and the Bitcoin amounts owned or controlled by the public sector. 31

Digital-asset oversight

The program’s broader direction is to strengthen safeguards and transparency around Bitcoin-related public operations. The supplied sources support that general objective, but they do not provide a complete, current list of all enacted digital-asset rules, supervisory requirements, or implementation deadlines. 1731

Where the IMF financing stands

IMF staff and El Salvador reached a staff-level agreement on the combined second and third reviews of the 40-month EFF, which totals roughly $1.4 billion. The agreement could make about $140 million available, equivalent to SDR 101.96 million. 427

It was not, at the time of the announcement, a final disbursement. IMF Executive Board approval and completion of relevant prior actions were still required. 427

Growth and debt goals

The IMF projected 4.5% real GDP growth in 2026. 4

The program’s fiscal strategy is designed to place public debt on a downward path. Earlier EFF documentation pointed to reducing public debt to around 70% of GDP by 2030. The available reporting on the combined second-and-third review does not establish a replacement target. 17

Bottom line

The IMF did not say that every donation had been publicly traced. It said Salvadoran authorities supplied documentation sufficient for the Fund to conclude that Bitcoin accumulated after the June 2025 review came from private donations, not public funds. 6

That distinction matters. The EFF has paired this compliance finding with a wider effort to curb public Bitcoin exposure, shift Chivo away from public control, and improve disclosure. Yet the provenance and terms of the reported donations remain largely outside public view. 517