The International Monetary Fund said El Salvador has not used public funds to buy bitcoin since June 27, 2025, when the lender completed its first review of the country’s $1.4 billion Extended Fund Facility.
In a report published September 4, the IMF said El Salvador provided documentation showing that all bitcoin accumulated since the first EFF review came from private donations, not public resources. The confirmation resolves months of speculation about whether President Nayib Bukele’s government was meeting its commitments under the loan program.
El Salvador’s bitcoin treasury currently holds 7,764 BTC, worth roughly $620 million at current prices. The holdings have grown steadily from a baseline of approximately 5,968 BTC in December 2024, when the IMF programme was formalized. On-chain trackers recorded the balance rising from 6,101 BTC in early March 2025 to about 6,189 BTC by late May, before accelerating further through the summer months.
The EFF Conditions
The Extended Fund Facility, approved by the IMF Executive Board on February 26, 2025, included a continuous quantitative performance criterion with a zero ceiling on voluntary bitcoin accumulation by the public sector. The condition was designed to prevent El Salvador from using borrowed money to expand its crypto holdings while operating under the program. IMF staff had flagged minor breaches in earlier reviews but treated them as contained, establishing a corrective buffer for future compliance.
The restrictions went beyond the accumulation ceiling. The government was required to unwind its public participation in the Chivo wallet by end-July 2025, liquidate the Fidebitcoin trust, and publish audited financial statements for all bitcoin-linked public entities. The 40-month arrangement covers total access of SDR 1,033.92 million, equivalent to roughly $1.4 billion or 360% of El Salvador’s quota.
El Salvador has received approximately $231 million in disbursements so far across two reviews. An additional $140 million awaits approval by the IMF Executive Board, subject to completion of agreed prior actions. The bitcoin compliance question was the most politically sensitive condition standing between the government and the next tranche of funding.
The Chivo Wind-Down
Chivo was the state-created digital wallet launched in 2021 as part of Bukele’s original bitcoin experiment. It allowed citizens to hold bitcoin and dollars, with the government distributing $30 in free bitcoin to every adult who downloaded the app. Downloads were initially widespread, but active usage never matched the policy ambition.
The IMF programme required the public-sector role in Chivo to be phased out by end-July 2025. That meant the state could no longer operate or subsidize the wallet as a public bitcoin service. By December 2025, the IMF reported that negotiations for the sale of Chivo were “well advanced,” though details of the transaction were not disclosed.
The retreat from Chivo was a central concession in the December 2024 IMF agreement. It moved bitcoin promotion out of direct state operations and left private platforms to serve the dwindling number of citizens still using the cryptocurrency for everyday transactions.
The November Question
In November 2025, El Salvador reported acquiring 1,090 BTC worth roughly $100 million. The announcement raised immediate questions about compliance, given the zero-ceiling criterion on public-sector accumulation. At the time, El Salvador’s Bitcoin Office continued to promote a “one bitcoin per day” strategy on social media, maintaining the appearance of active government buying.
President Bukele reinforced the message in March 2025, telling reporters the government would continue its bitcoin investment strategy regardless of the IMF deal. “It’s not stopping,” he said at the time.
The IMF’s latest report suggests the November acquisitions were funded through private donations rather than public money, which would keep the government in compliance. The distinction rests on a specific reading of the EFF conditions: the zero ceiling applies to “voluntary” accumulation by the “public sector.” If the bitcoin arrived as unsolicited private gifts, the government argues it did not actively purchase the assets.
Critics have pushed back on this framing. If the government solicited donations or structured transactions to route private money into bitcoin purchases, the line between “public” and “private” funding becomes difficult to maintain. The IMF report does not address whether El Salvador actively sought the donations or simply received them.
A Carefully Managed Balance
The arrangement reflects a broader tension at the heart of El Salvador’s bitcoin experiment. Bukele made the cryptocurrency legal tender in 2021, drawing international attention and domestic popularity. The IMF has consistently criticized the policy, saying bitcoin’s price volatility poses risks to fiscal stability and financial integrity.
The EFF conditions represent a compromise that other IMF member states are watching closely. The Fund allowed El Salvador to keep its existing holdings but prohibited further government purchases. The Chivo wallet was required to wind down its public-sector operations. The Fidebitcoin trust was ordered liquidated.
For other countries considering bitcoin reserves or legal tender frameworks, the outcome sends a clear but complicated signal. IMF financing and crypto adoption are not mutually exclusive, but the strings attached, particularly the restrictions on public purchasing, set a firm boundary on how far governments can go while remaining in the Fund’s good graces.
By confirming compliance, the IMF clears the path for the next $140 million disbursement. The confirmation also reinforces the broader message: El Salvador can hold bitcoin, but it cannot use IMF-supported public funds to buy more. Whether the “private donations” framing survives deeper scrutiny as the treasury grows remains an open question.
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