El Salvador’s President Nayib Bukele speaks during a meeting with more than 30,000 students at the Jorge “El Mágico” González Stadium in San Salvador on August 23, 2026.
MARVIN RECINOS/AFP via Getty Images
The International Monetary Fund cleared El Salvador’s Bitcoin compliance on September 3, 2026, accepting the country’s explanation that every coin added to its sovereign reserve since June 2025 came from private donations — without publicly naming a single donor or disclosing how much any of them gave.
That acceptance is the condition on which the IMF reached a staff-level agreement covering the combined second and third reviews of El Salvador’s 40-month Extended Fund Facility (EFF), potentially unlocking approximately $140 million in additional disbursements pending approval by the IMF Executive Board. But the Fund’s decision to validate an explanation built on documentation it has not released publicly creates a structural tension with its own Fiscal Transparency Code — which requires that public reporting on government finances be comprehensive, reliable, and publicly verifiable, not merely accepted on the basis of privately-held records provided by the party under review.
Who Gave El Salvador Hundreds of Millions in Bitcoin?
Between December 2024, when El Salvador’s EFF program began, and September 4, 2026, the country’s sovereign Bitcoin holdings grew from 5,968 BTC to approximately 7,764 BTC — an increase of roughly 1,796 coins. At current market prices, those holdings are worth approximately $628 million, against a total acquisition cost of around $388.9 million, representing an unrealized gain of roughly $239 million.
The IMF’s compliance condition for the EFF program is unambiguous: a continuous quantitative performance criterion with a zero ceiling on voluntary Bitcoin accumulation by the public sector. When El Salvador’s reserve visibly grew after the program began, that trajectory needed an explanation. The Fund offered the first one in July 2025: the increases reflected the consolidation of Bitcoin previously held in separate government-controlled addresses — most notably from a BANDESAL cold-storage address — into the Strategic Bitcoin Reserve Fund wallet, rather than any net new market purchases.
That explanation closed one gap and opened another. Then came November 2025, when El Salvador announced it had acquired 1,090 BTC worth approximately $100 million, which was harder to attribute to internal wallet shuffling. The IMF declined to comment at the time, saying it would assess compliance “in due course.”
September 3, 2026 is when “in due course” arrived. The Fund’s updated account: every coin added since the first review’s June 27, 2025 cutoff date came from private donations, verified by documentation provided by Salvadoran authorities. Neither the IMF statement nor any supplementary material identifies who those donors are, how many there were, or what specific amounts each contributed. The BTC in El Salvador’s wallet, on-chain, is undeniable. Its origin, off-chain, rests on paperwork the public has not seen.
Why Blockchain Records Alone Cannot Settle This
Here is the technical core of the accountability question. Bitcoin transactions are recorded on a public ledger: every movement of coins between addresses is permanently visible to anyone running a block explorer. That transparency is one of Bitcoin’s defining properties. But it is also limited in a specific way that is directly relevant to this situation.
The blockchain records that coins moved into a government-associated address. It does not record why they moved, or who sent them in a meaningful legal sense. A government purchase on an exchange, a private donation from a wealthy supporter, and an internal transfer from a separate government wallet all look identical on-chain: Bitcoin arrived at Address A from Address B on Date C. Attribution of source — the question of whether this was a government-funded purchase or a private gift — requires off-chain documentation: exchange records, donation agreements, banking correspondence, or similar paperwork.
This is precisely why the IMF needed documentation provided by Salvadoran authorities rather than simply reading the blockchain itself. And it is precisely why the absence of public disclosure matters: the verification the Fund conducted is not independently reproducible by outside observers. An audit whose supporting documentation is visible only to the auditor and the auditee is a less robust audit than one whose underlying evidence can be independently checked.
The discrepancy in reported figures sharpens the point. El Salvador’s Bitcoin Office reports 7,764 BTC as of early September 2026. Blockchain forensics firm Arkham Intelligence’s tracking of known government-associated addresses shows a figure closer to 7,264 BTC. The 500-coin gap between official government reporting and independent on-chain analysis illustrates the difficulty of externally verifying what the IMF has now accepted internally.
Chivo, Privatized: The State’s Exit from Direct Bitcoin Operations
Alongside the compliance finding, the September 3 agreement confirmed that majority ownership and operational control of the Chivo wallet — El Salvador’s state-backed Bitcoin payment application, launched in September 2021 as the flagship of the country’s legal tender experiment — have been transferred to a private operator, while the government retains a minority stake and custodial responsibilities for customer assets.
The identity of that private operator has also not been disclosed.
Chivo launched with $30 in free Bitcoin for every citizen who signed up, government-funded and government-run, as the mechanism by which ordinary Salvadorans were supposed to experience the benefits of Bitcoin as legal tender. By January 2025, surveys found that 92% of Salvadorans had not used Bitcoin in the prior year; family remittances conducted through Chivo and similar digital wallets accounted for less than 1% of total transfers in December 2024. President Nayib Bukele himself later acknowledged that making Bitcoin legal tender had been his government’s “most unpopular” measure. The Legislative Assembly amended El Salvador’s Bitcoin Law in February 2025, removing the legal tender mandate and making private-sector acceptance voluntary — a reform required as a condition of the IMF program.
What Chivo’s privatization represents, then, is the completion of the government’s formal exit from direct Bitcoin operations: it started the experiment, subsidized adoption, and is now transferring ongoing operations to a private entity — while keeping a minority position and custody over the coins its customers deposited. That transition mirrors the broader pattern of the Bukele administration’s approach to public-private technology arrangements. In 2023, the government enacted the Digital Modernization Law, which transferred health and education systems to Google Cloud’s infrastructure. By 2026, Bukele had announced a partnership with Google to introduce AI-powered management into El Salvador’s national health system. In each case, the model is the same: state-initiated, privately operated, with the government retaining a regulatory or oversight position but ceding day-to-day control.
What the IMF Is Not Saying
The IMF has been careful throughout this process not to endorse Bitcoin as a reserve asset or to validate El Salvador’s broader crypto strategy. Its concern, stated consistently since the EFF program began, has been narrower: protecting public finances from direct exposure to Bitcoin’s price volatility and preventing public-sector resources from being used to speculate in crypto markets.
Accepting the private-donations explanation is consistent with that narrow concern. If the donations are real, no public money funded the accumulation, and the fiscal risk has not increased through government action. The IMF has moved on without a formal waiver of the quantitative performance criterion — the compliance mechanism that would otherwise require the program to be suspended.
But the IMF’s acceptance is also a political judgment. The Fund statement says no further accumulation beyond documented donations is expected. Meanwhile, as recently as the week before the September 3 announcement, El Salvador’s Bitcoin Office posted to its public accounts that the country had bought more Bitcoin — attaching a treasury chart showing 31 coins added over the prior 30 days. El Salvador’s own reserve tracker and the IMF’s compliance determination are offering the public two different narratives about the same wallet.
What the $140 Million Means
The $140 million that could be released pending Executive Board approval represents the third tranche of a program that has already disbursed approximately $118 million following the first review in June 2025, and $113 million at the program’s outset in February 2025. Total disbursements under the program would rise to roughly $371 million of the $1.4 billion total access, with the remaining balance to be released through subsequent reviews.
The broader economic picture has genuinely improved. The IMF projects real GDP growth of 4.5% for El Salvador in 2026, building on a 2025 growth rate of 3.9% that already beat earlier forecasts. The non-financial public sector’s primary surplus is expected to widen from 2.9% of GDP in 2026 to 3.7% by 2027, consistent with the program’s Fiscal Responsibility Law target of reducing public debt to 80% of GDP by 2030. El Salvador’s Central Reserve Bank has raised its own 2026 growth forecast range to 4.5%–5%, up from an earlier estimate of 3%–3.5%. The IMF has also noted that the program is contributing to “a significant decline in poverty” tied to improved public service efficiency.
These macroeconomic results are real and significant for a country that five years ago was described as drowning in foreign debt and whose Bitcoin experiment was drawing sustained international skepticism. Whether the EFF’s conditionality produced those results, or whether the security improvements Bukele achieved through his gang-crackdown policies drove growth independently of the IMF program, is a contested analytical question. What is not contested is that the program has survived and the economy has improved.
What El Salvador’s Bitcoin Compliance Could Mean for Other Countries
Several analysts have noted that this arrangement could set an IMF template for how the Fund handles other nations exploring sovereign Bitcoin holdings. Countries that depend on IMF financing but want to maintain Bitcoin reserves may face similar pressure: halt direct state-funded purchases, but accept that private donors can grow the sovereign stash without triggering the performance criterion.
That template has an obvious structural problem. If private donations can grow a sovereign Bitcoin reserve without violating IMF conditionality, and if the donors behind those donations do not need to be named publicly, then the line between “public funds used for crypto speculation” and “private funds used to maintain a government’s crypto reserve” is policed by documentation that only the IMF and the borrowing government can read. A sovereign government with friendly crypto billionaires in its orbit could maintain a growing Bitcoin reserve indefinitely while technically remaining compliant with an IMF no-accumulation condition.
The IMF has emphasized that El Salvador has agreed to strengthen its legal and regulatory framework for digital assets and to improve transparency of Bitcoin holdings across all government wallets. Whether that improved transparency will include public disclosure of the donor documentation used to clear this review remains to be seen. Until it does, the compliance determination on which $140 million rests is built on evidence that the public cannot independently verify — an unusual foundation for an institution whose entire legitimacy rests on the premise that fiscal accountability is visible.
Frequently Asked QuestionsWho donated Bitcoin to El Salvador’s government, and how much?
Neither the IMF nor El Salvador’s government has publicly disclosed the identity of the private donors whose contributions the Fund says funded Bitcoin accumulation since June 27, 2025. No individual names, organizations, or donation amounts have been released in connection with the September 3, 2026 staff-level agreement. The IMF accepted documentation provided by Salvadoran authorities confirming the private-donation origin, but that documentation has not been made public.
Why can’t blockchain records confirm whether El Salvador used public funds?
Bitcoin’s public ledger records that coins moved into government-associated wallet addresses, but it does not record the legal source of those coins. A government purchase, a private donation, and an internal transfer between government wallets all produce identical on-chain records: coins arrived at address X from address Y on date Z. Determining the origin requires off-chain documentation — exchange records, donation agreements, banking correspondence — which is why the IMF needed Salvadoran authorities to supply paperwork, and why the absence of public access to that paperwork means the compliance finding cannot be independently verified.
What happened to the Chivo wallet?
Chivo, El Salvador’s government-launched Bitcoin payment application, has transferred majority ownership and day-to-day operational control to an unnamed private operator, as required under the IMF program. The government retains a minority stake and custodial responsibilities for customer assets. The wallet’s trajectory encapsulates the broader arc of El Salvador’s Bitcoin experiment: state-funded at launch (it distributed $30 in free Bitcoin to every registered user), largely unused in practice (92% of Salvadorans had not used Bitcoin in the prior year as of January 2025), and now privately operated while the state retains a supervisory role.
What does the IMF’s compliance decision mean for El Salvador’s economy?
The staff-level agreement clears the path for approximately $140 million in additional disbursements, pending Executive Board approval. The broader EFF program is on track: the IMF projects 4.5% GDP growth for El Salvador in 2026, driven by investment, remittances, tourism, and improved security conditions. The program also catalyzes multilateral support beyond the IMF’s own funds — the full EFF package was designed to unlock more than $3.5 billion in combined support from the World Bank, Inter-American Development Bank, and other multilateral lenders. For a country that entered the program with public debt at roughly 89% of GDP, continued disbursements and associated institutional credibility matter well beyond the specific dollar amounts involved.