The IMF completed the second and third reviews of El Salvador's $1.4 billion loan program on October 1, unlocking an immediate disbursement of SDR 101.96 million — about $138 million. The reviews were held up by performance criteria tied to Bitcoin accumulation, and the fund only cleared them after Salvadoran authorities took corrective measures and renewed commitments to limit further state purchases. That's the trade: money now, restraint on the reserve.
The waivers, and what they don't cover
The IMF granted waivers for unmet performance criteria linked to Bitcoin accumulation. In plain terms, El Salvador missed a target and the fund looked past it. What it didn't do is drop the constraint itself. Under the program, no further Bitcoin accumulation is envisaged beyond documented donations, which preserves the bar that stops the government from resuming publicly funded purchases. The IMF is drawing a hard line between coins bought with public money and coins received through documented donations. Reserve balances can rise without that meaning the government has restarted buying. That distinction matters, because it's the difference between a donation landing in a wallet and a policy reversal.
El Salvador currently holds roughly 7,794.37 Bitcoin, valued at about $666.1 million.
Chivo is off the public books — mostly
The government has transferred majority ownership and control of the government-backed Chivo wallet to a private operator. That's a step the IMF wanted. But it isn't finished. The fund said remaining public-sector exposure should still be fully unwound. Chivo has been the program's most visible loose end, and a majority stake sale doesn't close it out if the state retains exposure. The IMF's language leaves room for the remaining piece to be smaller than the whole but still material.
What the fund wants before the next review
Three things sit on the to-do list. Better disclosure of public-sector crypto holdings. Stronger regulation and governance for digital-asset providers. And amendments to the Digital Asset Issuance Law where necessary. The disclosure item is the one that ties directly to the waivers. Future reviews will hinge partly on whether El Salvador can document how its Bitcoin balance changes while completing the Chivo unwind and the transparency reforms. If the balance moves and the paperwork doesn't explain it, the government could be back asking for another waiver before it touches more program financing.
The rest of the program is on track, per the fund. Fiscal consolidation is advancing broadly in line with objectives, and reserve and liquidity targets have been comfortably met. The 40-month Extended Fund Facility was approved in February 2025 and is built around fiscal adjustment, stronger reserves, and financial-sector reforms. On those measures, El Salvador is doing what it said it would.
The next checkpoint
The disbursement buys time, not immunity. The next reviews will test whether the government can account for every change in its Bitcoin balance — donations included — while finishing the Chivo unwind and pushing the disclosure and regulatory changes the IMF asked for. Any accumulation the government can't explain puts it back in waiver territory. That's the specific thing to watch between now and the next review.
