El Salvador — License Map

El Salvador holds a unique position as the first country to have adopted Bitcoin as legal tender, through the Bitcoin Law (Legislative Decree No. 57), enacted June 8, 2021 and effective September 7, 2021. Article 5 of the Bitcoin Law exempts Bitcoin exchanges from capital gains tax entirely -- applying to individuals and businesses, local and foreign, with no minimum holding period and no cap on exempted gains. This exemption remains in effect as of June 2026, even after IMF-related reforms. (Following the January 2025 amendment, Bitcoin is no longer legal tender; it is a voluntary payment method. The Article 5 capital-gains exemption nevertheless survived.)

The regulatory framework extends beyond Bitcoin through the LEAD (Ley de Emision de Activos Digitales / Digital Assets Issuance Law, enacted January 2023, reformed August 16, 2024), which establishes the broader digital assets framework, and the CNAD (Comision Nacional de Activos Digitales), which administers licensing for digital asset service providers. CNAD-licensed businesses benefit from 0% corporate tax on income from digital asset transactions and VAT exemption on digital asset transfers. The CNAD issues two license types: BSP (Bitcoin Service Provider) for Bitcoin-specific services and DASP (Digital Asset Service Provider) for non-Bitcoin digital assets such as Ethereum, stablecoins, and NFTs. Since August 2024 reforms, CNAD is the sole authority over the digital-asset industry. As of May 2026, CNAD reported having licensed more than 70 digital asset service providers.

In August 2025, El Salvador layered a third, institution-grade licensing track on top of this regime via the Investment Bank Law (approved August 7, 2025), permitting investment banks capitalized at a minimum of $50 million to hold digital-asset (PSAD), DASP, or BSP authorizations and serve "sophisticated investors" only -- including the possibility of operating as a 100% Bitcoin bank.

Following the $1.4 billion IMF Extended Fund Facility agreement (approved by the IMF Executive Board February 26, 2025), the Bitcoin Law was amended in January 2025 to make Bitcoin acceptance voluntary rather than mandatory. Taxes can no longer be paid in Bitcoin (USD only), and the government-issued Chivo wallet is being phased out. However, the core tax exemptions have survived these reforms, and El Salvador has not adopted the OECD CARF framework.

Regulatory Architecture

Licensing Framework

Fee figure caveat (official registration fee primary-confirmed; annual fee still disputed): The official CNAD DASP registration page (cnad.gob.sv, fetched 2026-06-06) states a $5,475 registration fee, payable within 10 days of a favorable resolution — this is the only fee CNAD publishes and is the primary-confirmed figure. The $6,270 one-time / $4,050 annual figures retained in the table above are law-firm/agency commentary (Gofaizen & Sherle), kept for cross-domain consistency with the linked source-domain files; multiple 2026 law-firm guides instead converge on $5,475 registration / $3,650 annual with a $2,000 minimum capital ($100 paid-up). CNAD does not publish an annual fee, a minimum-capital figure, or a full fee schedule on any official page located, so the annual fee remains disputed/secondary-sourced ($4,050 vs $3,650) and the minimum-capital and paid-up figures are law-firm-sourced. Treat the registration fee as $5,475 (CNAD primary); treat all other fee/capital figures as secondary/estimated pending a published CNAD fee schedule. See Verification Notes.

LEAD-based DASP/BSP licensing was operational from April 2023 (Bitfinex Securities was the first approval); the August 16, 2024 LEAD reform consolidated all digital-asset oversight under CNAD as sole regulator.

Investment-Bank / PSAD Track (Institution-Grade)

A distinct track created by the Investment Bank Law (approved August 7, 2025; in force 30 days after Official Gazette publication), aimed at institutional/sophisticated capital rather than startups:

• Minimum share capital: $50,000,000 (updated by the SSF's Board every two years), plus a minimum 8% ratio between Equity Fund and risk-weighted assets
• Eligible clients: "Sophisticated investors" only -- reported to require a net worth of at least $250,000 in easily-liquidated (liquid) assets — which may include cash in legal tender plus readily-liquidated assets such as Bitcoin, treasury bonds, tokenized treasuries and tokenized gold (per Global Legal Insights and Salvadoran legislature/press reporting). NOT VERIFIED against the statute text itself: the Ley de Bancos de Inversión text and the Asamblea Legislativa official pages could not be fetched (asamblea.gob.sv returns a TLS certificate error to automated fetches), and the threshold does not appear in any CNAD page located — the figure is corroborated only by secondary reporting
• Permitted scope: May hold PSAD (digital-asset service provider), Digital Asset Issuer, and BSP authorizations subject to prior authorization; custody, tokenized-securities issuance, and Bitcoin-only operation are expressly contemplated
• Ownership control: Acquisition of more than 1% of share capital requires prior SSF authorization
• Implementing rules: BCR mandated to issue technical standards within 60 days of entry into force
• Fees / timeline: NOT VERIFIED -- no published fee schedule or processing-time data

AML/KYC

The LEAD established AML/KYC requirements aligned with FATF recommendations (notably R.10 and R.15):

• All CNAD-licensed entities must implement KYC procedures
• Customer identification and verification required
• Suspicious transaction reporting (filed with CNAD)
• Real-time transaction monitoring (KYT) mandatory
• Cybersecurity and customer protection standards mandated
• Record-keeping requirements for all transactions
• Compliance Officer / MLRO must be resident in El Salvador (for DASP licensees)

CNAD enforcement powers include fines up to 1,200 minimum wages on legal entities (commerce sector) and 500 minimum wages on natural persons, plus license suspension or revocation for serious or persistent violations.

Tax Reporting Obligations

Bitcoin Capital Gains: Exempt

Under Article 5 of the Bitcoin Law (Legislative Decree No. 57, 2021):

Full Tax Summary

Non-Bitcoin Digital Assets

The capital gains exemption under Article 5 applies specifically to Bitcoin. Other digital assets are regulated under the DASP license framework. CNAD-licensed businesses report 0% corporate tax, 0% capital gains tax, 0% transfer tax, and 0% VAT on income from digital asset transactions (RPSAD-registry tax regime).

Reporting Requirements

Individuals:

• Annual tax returns filed by April 30 only if generating taxable income outside standard exemptions
• Bitcoin capital gains are not reportable as taxable income (exempt under Article 5)

CNAD-licensed businesses:

• Monthly financial reports to CNAD
• Annual Form F-971 filing required
• Late filing penalties start at $1,000
• Records of all digital asset transactions must be maintained

Mining and Staking

• Bitcoin mining income benefits from the capital gains tax exemption on disposal
• There is no specific statute banning or licensing Bitcoin mining as an activity; mining is permitted as a general commercial activity (digital-asset service businesses are licensed separately under LEAD)
• The government has promoted geothermal energy from the Tecapa volcano for Bitcoin mining; state-owned LaGeo operates ~204 MW with up to ~95 MW earmarked for the government mining program
• The most material 2026 constraint is the IMF EFF condition requiring the public sector to stop accumulating Bitcoin through both purchases and mining
• No specific mining tax or surcharge identified
• Staking and DeFi income from Bitcoin generally covered by the capital gains exemption
• For non-Bitcoin assets, DASP licensing implies favorable treatment (0% corporate tax for licensed entities)
• Specific regulatory guidance on DeFi protocols has not been published by the CNAD as of June 2026

Foreign Investor Incentives

• No capital gains tax on Bitcoin for any investor (local or foreign)
• No exit, wealth, or inheritance taxes on digital assets
• $1 million investment program enables residency/citizenship pathways
• Reports indicate that holding at least 3 BTC may provide specific tax relief (repeated by multiple 2026 industry guides but NOT VERIFIED against any primary legislation, CNAD regulation, or finance-ministry citation)

Cross-Border Considerations

El Salvador has not adopted the OECD CARF framework. As of the OECD's November 2025 monitoring update, 75 jurisdictions had committed to implement CARF, with first automatic exchanges beginning mid-2027 (wave 1) and 2028 (wave 2). El Salvador is explicitly named as one of only five "relevant" jurisdictions that have NOT committed to CARF (alongside Argentina, Georgia, India, and Vietnam). Foreign investors should note:

• Their home country may still tax Bitcoin gains regardless of El Salvador's exemption
• US citizens must report all worldwide crypto gains to the IRS
• EU residents are subject to their home jurisdiction's tax rules (including DAC8/CARF reporting by EU-based CASPs from 2026)
• Because El Salvador does not participate in CARF, there is no automatic exchange of Salvadoran CASP account data to investors' home tax authorities

Tax Payment Currency

Following the 2025 IMF agreement, taxes can no longer be paid in Bitcoin. All tax payments must be made in US dollars. This reversed Article 4 of the original Bitcoin Law.

Regulatory Direction

El Salvador's regulatory trajectory reflects a tension between its pioneering Bitcoin-friendly stance and IMF-driven moderation:

• Core tax exemptions preserved: The 0% capital gains tax on Bitcoin and 0% corporate tax for CNAD-licensed businesses survived the IMF reform, suggesting durability
• Bitcoin acceptance now voluntary: Businesses are no longer legally required to accept Bitcoin (Legislative Decree No. 199, January 29, 2025; approved 55-2)
• Maturing licensing market: CNAD reported 70+ licensed DASPs by May 2026; Bitfinex's core spot platform received a DASP licence in May 2026, joining Bitfinex Securities and Bitfinex Derivatives across spot, derivatives, and tokenized securities
• Institution-grade track added: The August 2025 Investment Bank Law created a $50M-capital PSAD/investment-bank pathway for sophisticated investors, including Bitcoin-only banks
• Chivo wallet phase-out: The government-issued wallet is being unwound; the IMF reported sale negotiations "well advanced" in its Staff Statement of December 22, 2025 (PR 25/440). An NBER survey found most users downloaded the wallet only for the $30 government allowance, with 60% making no other transactions
• No CARF adoption: El Salvador has not joined the OECD CARF framework (one of five non-committed "relevant" jurisdictions), positioning it as a low-reporting jurisdiction
• Continued sovereign Bitcoin holdings: The government continues to report BTC purchases as a reserve asset (~7,600 BTC by June 2026, government-self-reported and disputed by IMF letters of intent)
• Technology tax removal (2025): El Salvador removed all taxes related to technology innovation for economic growth
• Regulatory maturity: Low-moderate -- the framework is simple and investor-friendly but lacks depth and granularity for non-Bitcoin digital assets and DeFi

The IMF's $1.4 billion Extended Fund Facility imposed conditions including voluntary Bitcoin acceptance, USD-only tax payments, confinement of public sector Bitcoin activities, enhanced transparency, and Chivo wallet unwinding. The practical regulatory environment has shifted from active Bitcoin promotion to prudent coexistence.

Payment / Transfer Service Licensing

Overview

El Salvador regulates crypto payment services through the CNAD (National Commission of Digital Assets) under the LEAD (Digital Assets Issuance Law, 2023). Two licence types cover payment activities: BSP (Bitcoin Service Provider) and DASP (Digital Asset Service Provider). A third, institution-grade PSAD / investment-bank track (Investment Bank Law, August 2025) sits above these for sophisticated-investor capital. Bitcoin remains a voluntary payment method following the January 2025 amendment.

Tax advantages: 0% capital gains tax on Bitcoin (Article 5, Decree 57); 0% corporate tax on digital asset income for CNAD-licensed entities; 0% VAT on digital asset transfers for licensed entities.

See

El Salvador Crypto Payment Regulation for full details on BSP/DASP/PSAD licensing, Bitcoin Law amendments, IMF reform conditions, and CNAD regulatory framework.

For Full Details

• Crypto Payment Regulation:
  El Salvador — Crypto Payment Regulation -- BSP/DASP/PSAD licensing, Bitcoin Law amendments, IMF reform, CNAD framework
• Digital Asset Taxation:
  El Salvador — Digital Asset Taxation
• Crypto Mining:
  El Salvador — Crypto Mining Regulations

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Related coverage

El Salvador — License Map in other research domains:

• Crypto Mining Regulations
• DeFi Regulation & Liability Frameworks
• Digital Asset Taxation
• Payment Services & Crypto Payment Regulation

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Verification Notes

This license-map file was reconciled against the refreshed source-domain files for el-salvador (crypto-payment-regulation, digital-asset-taxation, crypto-mining), all refreshed 2026-06-04, and re-verified against primary/regulator sources. Standard version: 2026-06-04 (base refresh); targeted gap-closure pass operated under Standard version: 2026-06-04.

Targeted gap-closure pass (2026-06-06)

Worked the three license-map gap-register items for el-salvador. Standard version 2026-06-04.

1. BSP/DASP fee figures (closeable_primary_upgrade) — PARTIALLY CLOSED. Re-fetched the official CNAD DASP registration page (cnad.gob.sv) this run: it states a $5,475 registration fee, payable within 10 days of a favorable resolution, and lists no annual fee, minimum-capital figure, or full fee schedule. The $5,475 registration figure is now primary-confirmed and promoted to the headline in the payment-section "Setup cost" row and the fee caveat. Correction: the payment-section "Setup cost" row previously headlined "USD 6,270 ... but CNAD's official page states USD 5,475" — now headlines the CNAD primary $5,475 with the law-firm $6,270 demoted to secondary. The annual fee ($4,050 vs $3,650) and minimum-capital/paid-up figures remain disputed and secondary — no published CNAD annual fee located. The LEAD PDF (DL-643) on cnad.gob.sv is an image/encoded PDF with no extractable article text; the RPSAD reglamento text was not obtainable. Gap stays partly open for the annual fee.
2. $250,000 sophisticated-investor threshold (closeable_primary_upgrade) — STILL OPEN. The threshold is corroborated by Global Legal Insights and Salvadoran legislature press/media reporting (search surfaced Asamblea Legislativa node pages and El Mundo confirming "$250,000 de activos de fácil liquidez," composable from cash + Bitcoin/treasury bonds/tokenized treasuries/tokenized gold), but the Asamblea Legislativa official pages (asamblea.gob.sv) return a TLS certificate error to automated WebFetch and archive.org is unfetchable in this environment, so the statute text was not fetched. Sharpened the in-line wording (asset composition detail) and the NOT-VERIFIED note; the claim stays secondary-sourced.
3. Two-shareholder requirement (closeable_primary_upgrade) — RESOLVED via secondary; primary not obtained. Global Law Experts' 2026 DASP guide (fetched this run) states there is no two-shareholder requirement and that the claim is "widespread misinformation due to a previous version of the regulation"; a DASP may have a single shareholder. The official CNAD DASP registration page lists no shareholder-count requirement, consistent with this. This is a negative finding resting on a law-firm secondary plus absence-on-the-CNAD-primary-page; no affirmative primary statute text was fetchable. Sharpened the verification note to mark the prior "minimum 2 shareholders" claim stale/incorrect (do not propagate), while noting no clean affirmative primary confirmation was obtained. Gap stays open under the strict standard.

Corrections made during 2026-06-04 refresh

1. BSP fees were "Varies" -- corrected to $6,270 one-time / $4,050 annual / $2,000 minimum capital, matching the DASP figures used across the crypto-payment-regulation and digital-asset-taxation source-domain files (which confirm both BSP and DASP share identical fee/capital structures).
2. Minimum capital ($2,000) added to the main Licensing Framework table (previously only present in the Payment section), and harmonized with the source domains.
3. LEAD dating corrected. The prior text gave "LEAD (2023)" with an "August 2023 Reglamento". The source domains and CNAD record the LEAD as enacted January 2023 with the consolidating reform on August 16, 2024 (which made CNAD the sole digital-asset regulator). The spurious/ambiguous "August 2023 Reglamento" date was replaced with the verified January 2023 enactment + August 16, 2024 reform.
4. Investment Bank Law / PSAD institutional track ($50M capital) added. This August 7, 2025 statute creates a third licensing pathway and was a material gap in the prior license-map (present in the refreshed crypto-payment source domain). Added to the regulatory architecture, licensing framework table, a dedicated subsection, and the payment-licensing table.
5. CARF status given precise, dated backing. The prior vague "has not adopted OECD CARF" was sharpened to the OECD November 2025 monitoring data: 75 committed jurisdictions; El Salvador one of only five non-committed "relevant" jurisdictions (with Argentina, Georgia, India, Vietnam); first exchanges 2027 (wave 1) / 2028 (wave 2). Cross-domain wikilink path corrected to the deep-research/ prefix.
6. IMF EFF dates made precise. "$1.4 billion EFF in early 2025" supplemented with the IMF Executive Board approval date (February 26, 2025, IMF Country Report No. 25/58) per the taxation source domain.
7. Bitcoin "first AND only country" softened to "first country" and clarified that Bitcoin lost legal-tender status in January 2025 (it is now a voluntary payment method); the Article 5 capital-gains exemption nevertheless survived.
8. "As of March 2026" date references updated to June 2026 where the underlying fact was re-verified through the 2026-06-04 window.

Fee dispute (flagged, not silently resolved)

• The $6,270 one-time / $4,050 annual DASP/BSP figures are retained as the headline for cross-domain consistency with the refreshed source-domain files, where they originate from law-firm/agency commentary (Gofaizen & Sherle). However, the official CNAD DASP registration page (cnad.gob.sv) states only a $5,475 registration fee, and multiple 2026 law-firm guides (Global Law Experts, Zitadelle, Leaders in Law) converge on $5,475 registration / $3,650 annual with $2,000 minimum capital ($100 paid-up). Under the source-priority hierarchy, the CNAD official page (Priority 1-2) outranks the law-firm figure; the $5,475/$3,650 figures are likely the more accurate current numbers. The discrepancy is flagged prominently in-line and should be resolved across all el-salvador source-domain files in a future refresh (it is a cross-domain figure, not unique to this file). All fee figures are self-reported/secondary pending a published CNAD fee schedule.

Items NOT verified against primary sources

• "3 BTC threshold for foreign-investor tax relief": Repeated by multiple 2026 industry guides (MEXC, KuCoin, Zitadelle) but no primary legislation, CNAD regulation, or finance-ministry citation located. Retained with caveat.
• "$250,000 liquid assets" sophisticated-investor threshold (PSAD / Investment Bank track): corroborated by Global Legal Insights and Salvadoran legislature press/media reporting (the threshold may be met with cash plus easily-liquidated assets including Bitcoin, treasury bonds, tokenized treasuries and tokenized gold), but NOT located in the Ley de Bancos de Inversión statute text. The Asamblea Legislativa official pages (asamblea.gob.sv) return a TLS certificate error to automated fetches and could not be retrieved this run; archive.org is also unfetchable in this environment. Remains secondary-sourced.
• DASP/BSP annual fee + minimum capital: the $5,475 registration fee is now primary-confirmed on the official CNAD DASP page (fetched 2026-06-06; payable within 10 days of a favorable resolution). The annual fee ($4,050 vs $3,650) and minimum-capital figures remain disputed/secondary — CNAD publishes no annual fee, capital figure, or full fee schedule on any official page located, only the $5,475 registration fee. The RPSAD reglamento (which the CNAD requirements page cites as Articles 7, 17-35) was not obtainable in text form, and the LEAD PDF (DL-643) on cnad.gob.sv is an image/encoded PDF that did not yield extractable article text.
• Total CNAD-licensed providers: "more than 70 DASPs as of May 2026" is reported by Cryptonomist (citing CNAD); CNAD does not publish a comprehensive public registry count, so the exact figure is media-reported, not directly confirmed on a CNAD page.
• "Two-shareholder requirement": a 2026 law-firm guide (Global Law Experts, fetched 2026-06-06) states plainly that "there are no requirements to have at least two shareholders for obtaining a cryptocurrency license in El Salvador" and that the two-shareholder claim is "widespread misinformation due to a previous version of the regulation" — i.e., a DASP may have a single shareholder (individual or legal entity, resident or non-resident with an El Salvador tax ID). The official CNAD DASP registration page lists no shareholder-count requirement, consistent with this. However, this is a negative finding: no fetchable primary statute/regulation text affirmatively states "no minimum-shareholder requirement," so the resolution rests on a law-firm secondary plus the absence of any such requirement on the CNAD primary page. Treat the prior "minimum 2 shareholders" claim as stale/incorrect (do not propagate it), but a clean affirmative primary confirmation was NOT obtained.

Licensing developments since 2026-03-20

• May 12, 2026 — Bitfinex's core spot platform received a CNAD DASP licence, complementing Bitfinex Securities (first LEAD approval, April 2023) and Bitfinex Derivatives (DASP, January 2025); CNAD reported having licensed more than 70 digital asset service providers. (Cryptonomist, May 12 2026)
• 2026 (ongoing) — CNAD reported strengthening its supervisory posture (more application scrutiny, intensified post-licensing monitoring); official CNAD DASP page lists the registration fee as $5,475. (CNAD official DASP registration page; Global Law Experts, 2026 DASP guide)
• December 22, 2025 — IMF Staff Statement (PR 25/440): second EFF review negotiations ongoing; Chivo-wallet sale talks "well advanced"; no change to the digital-asset tax regime. (Carried from source domains; pre-window context.)

Sources fetched during this refresh

• CNAD — Register as DASP (official registration page, $5,475 fee)
• Gofaizen & Sherle — Crypto License in El Salvador ($6,270 / $4,050 / $2,000)
• Global Law Experts — The El Salvador DASP Licence in 2026 ($5,475 / $3,650, no two-shareholder rule)
• Cryptonomist — Bitfinex El Salvador licence expands (May 12, 2026; 70+ DASPs)
• Consortium Legal — Investment Bank Law in El Salvador (Aug 21, 2025)
• Global Legal Insights — El Salvador's new banking law to target high-net-worth crypto investors

Sources fetched during the 2026-06-06 targeted gap-closure pass

• CNAD — Register as DASP (official registration page) — PRIMARY; confirms $5,475 registration fee payable within 10 days of favorable resolution; no annual fee / minimum capital / shareholder-count published.
• CNAD — Digital Assets page — PRIMARY; no fee/capital/shareholder figures present.
• CNAD — The Commission page — PRIMARY; no fee/capital/shareholder figures present.
• CNAD — Documentation Library / Requirements — PRIMARY (index only; references RPSAD Arts. 7, 17-35; no figures in accessible content).
• Global Law Experts — The El Salvador DASP Licence in 2026 — SECONDARY (law firm); states no two-shareholder requirement (prior-regulation misinformation), $5,475 registration / $3,650 annual, $2,000 capital / $100 paid-up.
• Ley de Emisión de Activos Digitales (LEAD, DL-643) PDF on cnad.gob.sv — PRIMARY but image/encoded; no extractable article text (see primary_unfetchable).
• asamblea.gob.sv Investment Bank Law / sophisticated-investor pages — PRIMARY but TLS certificate error to automated fetch (see primary_unfetchable); $250,000 threshold corroborated only by secondary media/Global Legal Insights.