The IMF released a statement this morning saying El Salvador has not used public funds to accumulate bitcoin since June 2025. According to the Fund, the country provided documentation showing that everything added to the stack since then came from private donations. The statement landed alongside news that IMF staff reached an agreement with Salvadoran authorities on the combined second and third reviews of the country’s 40-month Extended Fund Facility. Subject to Executive Board approval and the completion of agreed prior actions, that deal would release roughly $140 million.

Here is why this is worth sitting with for a minute.

Last year the IMF said it would work to ensure the government’s bitcoin holdings remained unchanged under the program. Shortly after that announcement in May, Bukele’s government added 8 BTC anyway, bringing holdings to 6,190.18 BTC according to the country’s Bitcoin Office at the time. Then in November, El Salvador disclosed a 1,090 BTC acquisition worth about $100 million, its largest single-day addition at that point, taking total holdings to 7,474 BTC.

So the public timeline shows a country loudly stacking through a program that was supposed to freeze the stack. The IMF’s position today is that none of it came out of the treasury. Both things are now on the record at the same time, and the Fund did not publish a total for how much bitcoin arrived through donations since June 2025. It only said no further accumulation beyond the documented donations is expected.

The rest of the statement is arguably the more consequential part for anyone who cares about how sovereign bitcoin gets held. The IMF said El Salvador is working to improve transparency around holdings across its various wallets, and to strengthen governance and risk management for public-sector crypto assets. Separately, the government has unwound its role in the Chivo wallet: majority ownership and operational control have gone to a private operator, with the state keeping a minority stake and custodial responsibilities for customer assets.

For context on the backdrop, bitcoin was approaching $81,000 on Friday, up 4.5% over 24 hours, with a market cap near $1.6 trillion.

The legal question I keep coming back to is definitional. “Public funds” is a term with edges, and a lender can only test what the borrower documents. If a state can grow a sovereign reserve through donations while formally complying with a commitment not to buy, then the commitment constrains the accounting entry rather than the balance.

So, question for this sub: does a bitcoin reserve built from private donations still count as a national reserve in any meaningful sense, or is it just a wallet the state happens to hold the keys to?

Source: The Block, Brian Danga, September 4, 2026, reporting on the IMF staff-level agreement announcement.

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