The International Monetary Fund cleared El Salvador's Bitcoin compliance on Sept. 3, 2026, accepting the country's explanation for its growing sovereign reserve. This acceptance was a condition for reaching a staff-level agreement on the combined second and third reviews of El Salvador's 40-month Extended Fund Facility.
The agreement could unlock approximately $140 million in additional disbursements for El Salvador, pending approval by the IMF Executive Board. The EFF program, valued at $1.4 billion, began in December 2024.
El Salvador's sovereign Bitcoin holdings increased from 5,968 BTC in December 2024 to approximately 7,764 BTC by Sept. 4, 2026—an increase of 1,796 coins during the program period. At market prices on Sept. 4, those holdings were valued at approximately $628 million. The total acquisition cost for these coins was around $388.9 million, resulting in an unrealized gain of roughly $239 million.
The IMF's compliance condition for the EFF program includes a continuous quantitative performance criterion: a zero ceiling on voluntary Bitcoin accumulation by the public sector. The visible growth in El Salvador's reserve after the program started required an explanation.
In July 2025, the Fund accepted an explanation that increases reflected consolidation of Bitcoin previously held in separate government-controlled addresses into the Strategic Bitcoin Reserve Fund wallet. That account suggested no net new market purchases.
However, in November 2025, El Salvador announced it had acquired 1,090 BTC, then valued at approximately $100 million. This acquisition proved difficult to attribute solely to internal wallet shuffling. The IMF declined to comment, stating it would assess compliance "in due course."
That assessment arrived on Sept. 3, 2026. The Fund's updated position states that every coin added since the first review's cutoff date of June 27, 2025, came from private donations. Salvadoran authorities provided documentation to verify these claims.
Neither the IMF statement nor any supplementary material publicly identifies the donors, the number of donors, or the amounts each contributed. This lack of public disclosure creates structural tension with the IMF's own Fiscal Transparency Code, which requires that public reporting on government finances be comprehensive, reliable, and publicly verifiable.
On-chain data confirms the Bitcoin in El Salvador's wallet, with every movement between addresses permanently visible on the public ledger. The off-chain origin of these coins rests on documentation the public has not seen.
