El Salvador Bitcoin & Digital Asset License: CNAD Registration Guide

El Salvador's crypto licensing regime is run by CNAD, the Comisión Nacional de Activos Digitales, under the 2023 Digital Assets Issuance Law. Providers register on one of two tracks: a broad DASP license for digital-asset services and a BSP track for Bitcoin-specific services. The published DASP registration fee is USD 5,475, with a review of up to 20 business days.

That regime is very much alive, even though El Salvador's relationship with Bitcoin changed in January 2025. A reform tied to an International Monetary Fund (IMF) arrangement ended Bitcoin's mandatory acceptance, but it left the licensing framework intact. This guide explains who regulates digital assets, what the 2025 reform actually changed, how the DASP and BSP tracks differ, the CNAD registration process and fee, the tax treatment, and the AML obligations that follow. Numbers come from CNAD's own pages, the law itself, and IMF reporting, with each claim cited to its source.

What is El Salvador's crypto license and who regulates it?

A crypto license in El Salvador is a registration with CNAD, the national digital-asset authority, that authorizes a company to provide digital-asset or Bitcoin services. CNAD was created by the Digital Assets Issuance Law (LEAD), Legislative Decree No. 643, issued on 11 January 2023 and in force since 1 February 2023. Operating without CNAD approval is illegal and penalized under the law.

The regime is purpose-built for digital assets, not bolted onto older financial statutes. That gives applicants a single national authority, a defined registration path, and a public registry where authorized providers appear. Below we set out the authority, the law that created it, and the supporting bodies that sit alongside CNAD.

CNAD: the national digital-asset authority

CNAD (Comisión Nacional de Activos Digitales) is the public-law regulator and national authority for digital assets. It authorizes and supervises issuers, issuances, certifiers, Digital Asset Service Providers (DASP, also called PSAD) and Bitcoin Service Providers (BSP), and it notifies the Financial Investigation Unit (UIF) on registration. CNAD also maintains a public registry of authorized providers and issuers, which is the simplest way to confirm a provider's status.

The Digital Assets Issuance Law (LEAD), Decree 643

The legal basis for the whole regime is the Digital Assets Issuance Law (Ley de Emisión de Activos Digitales), enacted as Legislative Decree No. 643. It was issued on 11 January 2023 and entered into force on 1 February 2023. The LEAD created CNAD and the Bitcoin Funds Administration Agency (AAFB), and it makes operating without CNAD approval an illegal, penalized activity. The law also sets the tax framework for registered providers, which we cover later under Article 36.

Supporting bodies: BCR, AAFB and the UIF

CNAD is the central authority, but three other bodies play a part. The Banco Central de Reserva (BCR) retains a role authorizing DASPs to access payment and settlement systems. The AAFB (Bitcoin Funds Administration Agency) handles the state's own digital-asset offerings. The Financial Investigation Unit (UIF) is the AML/CFT counterpart that CNAD notifies and coordinates with once a provider is registered. Together they round out the institutional picture, but the registration relationship for a private provider runs through CNAD.

Is Bitcoin still legal tender in El Salvador in 2026?

Bitcoin is no longer a mandatory means of payment in El Salvador. Under the January 2025 reform, acceptance is voluntary, the government does not accept Bitcoin for taxes, and the US dollar is the country's currency. Bitcoin remains legal to hold and trade privately. It was not banned, and it is not still mandatory legal tender. This is the single most common point of confusion, so it is worth setting out precisely.

The reform was made through an amending decree reported as Decree No. 199, published in the Official Gazette around 30 January 2025, which modified six articles and repealed three articles of the 2021 Bitcoin Law. Note that sources differ on whether the reform formally removed Bitcoin's "legal tender" label or kept the label while making use optional. What every source agrees on is the practical result: acceptance is no longer mandatory and the dollar is the currency.

What the January 2025 reform changed

The Legislative Assembly approved the reform on 29 to 30 January 2025 (reported as 55 votes in favour, 2 against). The repealed provisions include the State's obligation to provide automatic Bitcoin-to-dollar convertibility. In practice this meant three changes for everyday use:

• Acceptance of Bitcoin by businesses and individuals became voluntary rather than legally required.
• The government stopped accepting taxes and government payments in Bitcoin, and began winding down the Chivo wallet.
• The US dollar remained the sole reference and legal currency, with Bitcoin still legal to use, hold and trade privately.

Crucially, the licensing regime under the LEAD was untouched by this monetary reform. The government has also continued to accumulate Bitcoin reserves, with around 6,050 BTC reported as held.

Why the IMF arrangement triggered the change

The reform was a condition of a roughly USD 1.4 billion IMF arrangement (an Extended Fund Facility), with the deal reached in December 2024. The IMF program sought to reduce fiscal and monetary risks linked to Bitcoin's forced-currency role, which is why the reform focused on payment status rather than on whether crypto businesses could operate.

What did NOT change: the CNAD licensing regime

This is the key point for anyone weighing El Salvador as a licensing base: the IMF deal did not end crypto licensing. The reform changed Bitcoin's payment status, not the regulatory framework. CNAD's DASP and BSP registration tracks under the LEAD remain fully active. If anything, the separation is now cleaner: monetary policy moved one way, while the digital-asset licensing regime continued on its own statutory footing.

DASP vs BSP: the two CNAD registration tracks

CNAD runs separate registration tracks for digital-asset services and Bitcoin-specific services. Choosing the right one is the first substantive decision in any application, because it shapes the documentation and the scope you are authorized to provide. The table below summarizes the split, and the sections that follow explain each track.

DASP / PSAD (broad digital-asset services)

The DASP, or PSAD (Proveedor de Servicios de Activos Digitales), is the broad license. It covers any non-Bitcoin digital-asset service: exchanges, custody and wallets, brokerage, on-ramps and off-ramps, tokenization of real-world assets, token-issuance support, trading platforms and DeFi services. Most exchange and custody businesses will register on this track. It is also the track for which CNAD publishes the fee and the timeline, so its requirements are the best documented.

BSP (Bitcoin Service Provider)

The BSP track covers Bitcoin-specific services such as BTC exchange, custody, wallets and payment processing. Historically Bitcoin services sat under the 2021 Bitcoin Law with the Banco Central de Reserva involved; reforms across 2024 and 2025 consolidated registry authority over BSPs into CNAD. One practical caution: CNAD's published fee, capital and documentation details on the DASP page do not cover the BSP track, so BSP-specific figures are not confirmed from the primary source and should be verified with an adviser before you budget.

Which track does your business need?

If your service touches assets beyond Bitcoin, or you run an exchange, custody offering or tokenization platform, the DASP track is almost always the right route. If your business is purely Bitcoin-facing, the BSP track applies. Many operators choose the broad DASP because it future-proofs a product roadmap that may add tokens, stablecoins or RWA features. If you also plan to issue a stablecoin, factor in stablecoin issuer licensing considerations alongside your DASP registration.

How to register a DASP with CNAD: step-by-step

CNAD documents a clear, staged process for the DASP track: a pre-registration screening, a definitive registration with full documentation, a maximum 20-business-day review, the fee, and notification to the UIF. The steps below follow CNAD's published process.

Step 1 - Incorporate or qualify as a foreign provider

You first need standing to apply. The regime covers providers domiciled in El Salvador as well as those actively marketing digital-asset services to clients in the country, so a foreign company can register. In most cases an applicant will either incorporate a Salvadoran legal entity or establish the qualifying nexus before approaching CNAD.

Step 2 - Pre-registration and the "no objection" stage

Pre-registration is a screening step. You submit a form with applicant information and your intended operating area; CNAD evaluates it and may request more information, then issues either an "objection" or a "no objection." A "no objection" clears you to move to the definitive registration stage. This early filter lets you confirm scope before committing to a full documentation package.

Step 3 - Definitive registration and the 20-business-day review

For definitive registration you submit full documentation, both digital and physical, to CNAD's offices. CNAD evaluates the file within a maximum of 20 business days. If the submission is incomplete, you have 10 business days to cure it. The review ends in a favourable or unfavourable resolution.

Step 4 - Pay the fee and receive your authorization

On a favourable resolution, you pay the USD 5,475 registration fee within 10 days. CNAD then issues the registration certificate and authorization, and notifies the Financial Investigation Unit (UIF). From the notification of your definitive registration number, the Article 36 tax benefits begin to apply.

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How much does CNAD registration cost?

The published initial DASP registration fee is USD 5,475, payable within 10 days of a favourable CNAD resolution. CNAD does not publish a separate renewal fee or a BSP fee on its DASP page. If you have seen older figures such as a "USD 6,270 application plus USD 4,050 renewal" or a "USD 2,000 minimum capital," treat those as unverified advisory numbers rather than the official CNAD figure, which is the USD 5,475 above.

The USD 5,475 DASP registration fee

The USD 5,475 fee is the primary CNAD figure for the DASP track. It is an initial registration fee, due within 10 days of the favourable resolution. Pay it on time, and the certificate and authorization follow, with CNAD notifying the UIF as part of the same step.

Capital, renewal and BSP fees: what CNAD does and does not state

Transparency matters in a YMYL area, so it is worth being explicit about the gaps. CNAD's DASP page does not state a minimum share capital, so the old "USD 2,000 minimum" figure is not official and should not be relied on. CNAD shows only the initial USD 5,475, so any recurring or renewal fee is unconfirmed from the primary source. The BSP track's fee, capital and documentation are likewise not published on the DASP page. Confirm these directly with CNAD or an adviser before budgeting.

Tax treatment of registered DASPs

El Salvador's digital-asset law is unusually favourable on tax. Registered DASPs receive the tax benefits of Article 36 of the LEAD from the notification of their definitive registration number. The law broadly exempts the nominal value and the income or earnings from digital assets from taxes, duties and fees. This tax footing is one of the reasons providers consider El Salvador despite the change in Bitcoin's payment status.

Article 36 LEAD tax benefits

The Article 36 benefits attach to registered providers rather than to anyone holding digital assets, which is why registration is the gateway. The exemption reaches both the nominal value and the income or earnings tied to digital assets, as set out in the LEAD and its analysis. Because tax outcomes depend on your structure and activities, confirm the specifics for your business model before relying on them.

AML, KYC and ongoing compliance obligations

Registration is not the finish line. DASPs must meet AML/CFT obligations consistent with Salvadoran statute and international conventions, and CNAD supervises providers on an ongoing basis. The compliance framework is referenced to the RPSAD regulation, with articles cited on CNAD's page (Arts. 20, 7, 17 to 35). Exact thresholds and compliance-officer mandates are not set out verbatim in the public material, so build your program against the cited articles and confirm details during the process. For the broader picture, see our guide to AML and KYC requirements.

CNAD supervision and UIF reporting

On registration, CNAD notifies the Financial Investigation Unit (UIF), and the coordination with the UIF is the central AML/CFT relationship for a registered provider. Expect to maintain AML policies, customer due-diligence procedures and reporting consistent with Salvadoran law. A registered DASP should treat AML as a standing operational obligation, not a one-time filing.

El Salvador vs other crypto-license jurisdictions

El Salvador's appeal is a purpose-built digital-asset law, a single national authority in CNAD, a favourable Article 36 tax footing, and a documented registration path with a known DASP fee. The regime is demonstrably live: Tether is registered in CNAD's public registry as a DASP and stablecoin issuer, with entries including "Tether NA El Salvador" and "Tether International El Salvador." That is concrete proof that serious operators can and do register.

When El Salvador makes sense (and when it does not)

El Salvador makes sense when you want a dedicated digital-asset law, a clear tax exemption for registered providers, and a defined CNAD process. It makes less sense if your strategy depended on Bitcoin's mandatory legal-tender status, which the 2025 reform removed. Weigh it against peers: US crypto licensing for market access, Brazil's VASP framework for Latin-America scale, and Dubai VARA licensing for a Gulf base. To see the full picture, compare crypto-license jurisdictions side by side.

From our practice, the most common mistake we see is treating the 2025 Bitcoin reform as if it ended crypto licensing in El Salvador. It did not. We routinely guide founders through the distinction so their business case rests on the CNAD regime rather than on Bitcoin's old payment status, and so their documentation matches the track they actually need.