Invest2 publishers2 min readPublished
IMF waiver limits growth in El Salvador's $666 million Bitcoin reserve to donations
El Salvador drew $138 million from its $1.4 billion IMF loan after the Fund waived missed Bitcoin targets and kept state purchases barred. From here the reserve grows only through documented donations, so its dollar value now depends mostly on the Bitcoin price.
The Investor · Invest desk
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What happened
- The IMF board completed the second and third reviews of El Salvador's 40-month Extended Fund Facility on Oct. 1; the facility was approved in February 2025.
- Outside Bitcoin, the IMF said fiscal consolidation was broadly in line with programme objectives and that reserve and liquidity targets were comfortably met.
- Majority ownership and control of the state-backed Chivo wallet moved to a private operator, with the government keeping a minority stake and custodial duties.
- The Fund wants fuller disclosure of public-sector crypto holdings, tighter rules for digital-asset providers and changes to the Digital Asset Issuance Law where needed.
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Why it matters
- constraint While El Salvador stays in the programme, the government cannot use its own balance sheet to add coins, even on price dips, so only the pace of donations can grow the coin count.
- exposure A 10% move in Bitcoin shifts the reserve's mark by about $66.6 million, close to half the tranche just paid, and the government cannot buy more in response.
- precedent Each later tranche now depends on wallet paperwork, because CryptoSlate notes that an unexplained addition could send El Salvador back for another waiver before it can draw more money.
Divide the mark by the coin count. El Salvador's 7,794.37 coins, valued at roughly $666.1 million in CryptoSlate's tally [4], come to about $85,460 a coin [1]. At that price the holding is worth about 4.8 times the tranche just released [2] and close to half of the whole $1.4 billion facility [3]. The tranche is about a tenth of the facility [7], and its use is set by the programme's design: fiscal adjustment, stronger reserves and financial-sector reform [17].
The board waived the missed Bitcoin criteria "based on strong corrective measures and renewed commitments," the IMF said [2]. It then restated the limit in one sentence: "No further Bitcoin accumulation is envisaged beyond the documented donations." [3] According to CryptoSlate, the Fund treats coins bought with public money and coins received as documented gifts as different things, so the balance can rise without meaning that purchases have restarted [16].
That distinction has already been tested once. In November 2025 the government said it had acquired 1,090 BTC worth $100 million [13], about $91,700 a coin [5] and roughly 14% of today's holdings [6]. The IMF later said documents supplied by Salvadoran authorities verified that Bitcoin added after the June 2025 first review came from private donations, and that the increase did not reflect purchases financed with government resources [12]. CryptoSlate still wrote that additions to government-linked wallets appear inconsistent with the agreement [14]. Neither source says which period the missed criteria covered.
Donations that keep arriving with paperwork the Fund accepts would let the coin count drift up inside the rules. Should they dry up, the reserve becomes a fixed stack of coins whose dollar value the government can watch but cannot add to. On a third path, wallets grow faster than documented gifts can explain, and the Fund then has to decide whether to accept the paperwork a second time.
I think the second path is what the IMF is paying for. The first is closer to what has actually happened, given that a reported acquisition of 1,090 coins ended up booked as donated [13][12]. The counter-case is that the donation channel is wide enough to carry accumulation under another label. The next review settles it. If that review shows additions near the November pace with donor documents accepted again, the limit applies only to who pays for the coins, and the count stays free to rise.
What to watch
- The next IMF review of the facility, and whether any rise in the coin count again comes with donor documents the Fund accepts.
- Whether El Salvador fully unwinds its remaining Chivo stake and custodial role, as the IMF asked.