On September 17, according to on-chain data compiled by crypto KOL Ember, the bitcoin held on El Salvador’s sovereign balance sheet had risen to 7,777 BTC, with unrealized gains of $162 million—up 37%.

If you remember the news from a year ago, this may seem odd: didn’t El Salvador sign an agreement with the International Monetary Fund (IMF), promising not to use public funds to buy more bitcoin? So why is the bitcoin balance in that account still increasing?

A Halt on the Surface

Go back to December 2024. The IMF reached a deal with the government of El Salvador’s president, Nayib Bukele, for a $1.4 billion 40-month loan under the Extended Fund Facility. The conditions were explicit: bitcoin would no longer be mandatory legal tender, and private businesses could choose whether to accept it; on the public-sector side, “bitcoin-related transactions and purchases would be limited.”

In January 2025, El Salvador’s legislature swiftly amended the Bitcoin Law—the 2021 law that made the country the first in the world to adopt bitcoin as legal tender. In February, the IMF Executive Board formally approved the loan. An IMF country report in March was more specific: the cap on additional bitcoin purchases by the public sector was zero; the Fidebitcoin trust was to be liquidated by July 2025; and the government was to withdraw from operating Chivo, the national e-wallet.

Under that agreement, El Salvador’s treasury should have stopped adding to its holdings from 2025 onward.

Money Took on a Different Identity

In reality, the pace of “one bitcoin a day” never stopped. That rhythm had actually begun in November 2022, earlier than many people realize. Bukele announced the plan at bitcoin’s darkest moment—after FTX collapsed and the price fell below $16,000—on the rationale of “buying the dip.” Three years later, it has survived a bear market, a reelection, and a direct confrontation with the IMF. The only thing that changed was how the money was described.

In November 2025, El Salvador’s “Bitcoin Office” announced a one-day addition of 1,090 BTC, worth nearly $100 million. The figure did not align with the IMF’s monitoring framework, briefly prompting questions over whether the agreement had already fallen apart.

By September 2026, the IMF had published the results of its second and third reviews, offering an explanation: all bitcoin added after June 2025 came from “private donations” and consolidation of wallets within the treasury, rather than fiscal appropriations. The majority stake and operating rights in Chivo, the national e-wallet, had also been transferred to a private operator. The government retained only a minority stake and responsibility for safeguarding users’ assets. In literal terms, the agreement’s red line of “zero purchases with public funds” had been observed.

A Loophole in the Rules

The IMF’s terms govern who spends the money, not who receives the bitcoin. So long as purchases are moved from fiscal accounts to private donations, trust consolidation, or Chivo after privatization, bitcoin in the treasury can continue to rise—and the narrative of “one bitcoin a day” can continue to be told.

For Bukele, the calculation works: he retains both the political banner of building a “bitcoin nation” and a national reserve with paper gains of more than 37%, while securing an additional $140 million in IMF lending. More than $3.5 billion in accompanying commitments from institutions such as the World Bank and the Inter-American Development Bank is still in the pipeline.

For the IMF, the ledger also shows a win. Audits confirm that public funds have made no additional bitcoin purchases; the process is compliant, the conditions are met, and disbursements can continue. Whether the total amount of bitcoin in the treasury has truly stopped growing as a result of the agreement is outside the scope of its verification.

What has really been diluted is the force of the “zero purchases with public funds” restriction itself. It can constrain only one route—direct purchases by the finance ministry. It cannot prevent purchasing activity from continuing once the accounting entity changes.

This outcome leaves an unresolved question: if “private donations” and wallet consolidation continue to expand in scale, even beyond the amount that the original “zero purchases” red line was intended to restrain, will the IMF redefine what counts as “public funds” in its next review?

For now, the 37% paper gain is defensible on the books. Whether it can remain so depends on whether the IMF is willing—and able—to move the boundary of its review one step further.

  • This content is for reference only and does not constitute investment advice. Markets involve risk; invest with caution.