IMF: El Salvador’s Bitcoin Reserve Growth Was Donor-Funded, With $140M Tranche on Deck

El Salvador just cleared a key hurdle with the IMF—and the fine print reframes its Bitcoin story. IMF staff reached a preliminary deal on the country’s combined second and third program reviews, setting up roughly $140 million (SDR 101.96 million) for disbursement once the executive board signs off and prior actions are completed. Buried in the review: Bitcoin added to the national reserve since mid‑2025 came via private donations, with no public money used. Staff also said they do not expect further additions beyond those documented donations.

Why this matters is straightforward. The government has often presented accumulation as active buying. President Nayib Bukele has reiterated a “one Bitcoin a day” policy, and officials touted a 1,090 BTC purchase—about $100 million—last November. As recently as August 28, the Bitcoin Office posted a treasury chart showing 31 BTC added over the prior 30 days and wrote that the country had just acquired more coins. Meanwhile, the reserve stood at 5,968 BTC when the IMF program began in December 2024 and is now 7,764 BTC, according to the Bitcoin Office.

The IMF’s position today also departs from what its communications team conveyed in September 2025, when it said the state’s Bitcoin total had not increased and that reported growth reflected internal wallet shuffling. Taken together, the three narratives—no net increase (2025), donor‑funded increases (now), and “we’re buying daily” (official messaging)—pull in different directions.

Here’s the core issue I’m focused on: provenance and accountability of sovereign Bitcoin reserves. Donation‑funded accumulation skirts the IMF’s prohibition on public‑sector BTC purchases under El Salvador’s 40‑month, $1.4 billion Extended Fund Facility (approved February 2025), which also required making merchant acceptance voluntary and collecting taxes in dollars. That may be compliant on paper, but it invites three practical questions:

- Incentives: Anonymous or undisclosed donors can shape a public balance sheet without voter scrutiny. Even well‑intentioned gifts create signaling risk if the state markets them as taxpayer‑funded “buys.” - Controls: If donations arrive via OTC transfers or on‑chain gifts, the state needs ironclad chain‑of‑custody, AML/KYC screening, and audit trails. Without public addresses, independent verification remains out of reach. - Policy clarity: If staff now “expect no further additions” beyond documented gifts, the country should align communications with that guidance. Markets tend to penalize opacity more than they reward bravado.

On operations, the country is moving risk off the state’s books. Majority ownership and operational control of Chivo—the wallet launched with the 2021 Bitcoin Law—have shifted to a private operator (unnamed by the IMF). The government retains a minority stake and responsibility for safeguarding customer assets. In parallel, staff reached understandings to modernize digital asset regulation and to tighten governance and risk management for public‑sector crypto holdings. This is consistent with gradually professionalizing infrastructure while keeping the sovereign role focused on oversight and custody.

Macro context helps. The IMF projects 4.5% growth this year, supported by investment, remittances, and tourism, and wants public debt trending toward 80% of GDP by 2030. Against that backdrop, clear reserve accounting isn’t cosmetic—it affects borrowing costs, investor confidence, and the durability of the Bitcoin policy itself.

Market snapshot for reference: Bitcoin traded near $79,390 at publication, down about 1.92% over 24 hours, with a range of $78,706 to $82,108 and roughly $1.8 billion in 24‑hour volume. A prediction market assigned a 64% probability to BTC finishing the week below $80,000. Volatility often magnifies the reputational cost of mixed signals.

What I’d watch next: - On‑chain disclosure of reserve addresses or third‑party attestations to reconcile donations with holdings - Any shift in official language away from “daily buys” if future additions are indeed not anticipated - The private operator’s roadmap for Chivo and how customer asset safeguards are evidenced - The text of forthcoming digital asset rules and the scope of public‑sector crypto risk limits

If El Salvador wants credit for discipline while keeping Bitcoin central to its brand, aligning narrative, policy, and verifiable data will do more heavy lifting than meme‑ready slogans.