Yes, companies are choosing El Salvador, and some are doing more than adding a licence to a website. Tether moved its group headquarters there and Bitfinex has built three separately licensed businesses in the country. The more useful question is what they get from the move and whether a smaller business would get the same benefits.

 

What the registry shows, and what it does not

The CNAD is El Salvador’s digital-asset regulator. Its website listed 94 registered digital asset service providers as of November 2026. It also listed 56 issuers, 266 issuances and seven certifiers.

Those totals are real, but they are not 94 independent exchanges. Bitfinex describes its position in the country as three licensed entities. Bitfinex Securities was licensed in April 2023 and was the first platform approved under the law. Bitfinex Derivatives followed in January 2025, and the core Bitfinex platform received its own licence in May 2026. One group accounts for three entries in a registry like this.

The register also does not tell us how much business each provider does. A company can hold a registration and serve few customers. Before using the number to argue that El Salvador is popular, a founder should ask how many of those entries are operating businesses and how many are group entities or newly formed companies.

What the numbers do show is that the framework is in use. Companies have formed local entities, passed the CNAD process and obtained registration. The regulator’s own website also warns that operating without CNAD approval is illegal and that violators face sanctions under the Digital Assets Issuance Law. Under Article 38, failing to register as a provider can draw a fine of up to 114 monthly minimum wages for each infringement.

 

What Tether and Bitfinex each chose

Tether did something close to a full relocation. In January 2025 it announced that it had obtained a DASP authorisation and approval as a stablecoin issuer, and that it was completing the move of the group’s headquarters. Its later assurance report records that Tether International, S.A. de C.V. relocated from the British Virgin Islands to El Salvador in January 2025. The report also says the company is supervised by the CNAD as a stablecoin issuer and digital asset service provider.

Bitfinex’s choice looks different. It did not move the whole group. It added licensed entities one at a time for trading, derivatives and tokenised securities, and it describes El Salvador as a regional base for its derivatives business.

Neither case shows what a company with a handful of employees and one product would experience. Tether’s decision concerns where an issuer is domiciled and supervised. Bitfinex’s decisions concern which regulated activities it can run from one jurisdiction. A founder reading these announcements should work out which of the two stories is closer to their own plan.

The law helps explain why both companies could find a place in it. It covers more than exchange services. Its list of regulated activities includes exchanging assets, operating trading platforms (including derivatives), placing assets, promoting and structuring investment products, custody, transfers and order handling for third parties. It also contains a separate procedure for public offerings of digital assets. An issuer prepares a relevant information document, an authorised certifier reviews it, and the CNAD decides whether to enable the offering.

 

What a business has to bring with it

Suppose a trading business wants to offer spot and derivatives products to professional clients from El Salvador. The founders live in several countries and have a trading engine they built themselves. They expect to appoint a local director and register a company.

The law asks a foreign company to form a Salvadoran company or a branch registered in the national registry. The same obligation reaches a provider that is not based in the country but actively markets its services to potential clients there. Registration therefore attaches to a local legal entity, not to the foreign brand.

The next questions concern the people. The CNAD’s guide asks applicants to say whether each position is based in El Salvador or remote, and in which country. It also states that compliance officers must live in El Salvador. At the registration stage the applicant must show the appointment of a principal and an alternate compliance officer, their experience and qualifications, and employment contracts showing a direct employment relationship with the applicant. A consultant engaged part-time from another country would not meet that description.

Then comes the platform. In the first pre-registration phase the CNAD reviews the business model and the platform. Its guide lists, among the reasons for archiving an application, a statement that the technology platform is not yet developed or is still being developed. It also lists answers that promise information later and forms left blank without justification. Our trading business could not apply while its engine was still unfinished and expect to complete it during review.

The business plan has a cap as well. The summary supplied in phase one must not exceed ten pages, and the guide limits the plan itself to fifteen. It asks for each requested service to match the activities in Article 19 and the supporting documents. It also asks for coherence between the services requested and the assets the applicant intends to trade. Asking for derivatives, custody and token placement all at once means documenting each one.

 

How the review works in practice

The process has more stages than the word registration suggests. The CNAD’s guide describes two pre-registration phases followed by registration itself. Phase one is a quick assessment of the business model and platform. Phase two looks at the anti-money-laundering system and risk management.

Our trading business would be asked for a good deal of paper by phase two. That includes a current shareholder list and, where a shareholder is a company, the beneficial owners with identity documents. It also includes a three-year business plan with projections and audited financial statements for the last three years, or as many as exist. The guide asks for CVs of the key staff shown on the organisation chart, which must match the people named.

Deadlines run against the applicant. If the CNAD’s technical team has observations, the applicant has ten working days to correct them, with an extension of up to five more. An uncorrected application is archived. The same guide lets the CNAD request a technical meeting. If the applicant does not confirm its availability within five working days, or the meeting does not take place within ten working days of the form being filed, the application can be archived. An applicant whose founders are travelling or whose technical lead is unavailable could lose its place in the queue.

The law gives the CNAD up to 20 working days to issue a favourable or unfavourable resolution once the required information is in. That figure is not a promise that the whole process takes four weeks. It does not include the time the applicant spends building the platform, hiring the compliance officers or answering observations.

The regulation also gives the regulator some room. It says the CNAD’s resolution considers the economic needs of the market and the applicant’s reputation. A founder should not treat meeting the listed documents as a guarantee of approval.

 

What the tax benefits cover

Tax is often the first reason founders raise. Article 36 of the law exempts registered providers, issuers and certifiers from VAT, income tax and municipal taxes on the digital-asset activity they carry out. It also extends the benefit to shareholders in respect of profits and dividends from those activities. The US International Trade Administration describes the same framework in similar terms.

The exemption is tied to activity, not to the company. Article 36 says the benefits do not apply when digital assets are exchanged for goods or services outside the activities listed in Article 19. If our trading business also sold consulting services or software licences unrelated to digital-asset services, the exemption would not obviously cover that income.

Timing matters too. The provider regulation says the benefits start once the provider receives its registration number. It also says the tax authority issues a formal exemption qualification after the CNAD sends it the approved registration. The company should confirm when the exemption takes effect before building a financial model around it.

The exemption also has to be kept. The renewal fee is due in the first quarter of each year, and failing to pay it cancels the registration. The regulation adds that the provider then loses the tax benefits automatically. At the time of the regulation the fees were US$5,475 for initial registration and US$3,650 for annual renewal. The law sets them as 15 and ten monthly minimum wages, so the dollar figures can change.

Salvadoran law cannot decide the group’s overall tax position. The founders’ home countries, the place where the business is managed and the location of the entity that earns the revenue may produce tax consequences elsewhere. An exemption in one country does not remove those questions.

 

What a registered provider must keep doing

Registration is the start of the obligations, not the end. The law requires providers to keep adequate financial and non-financial resources as the CNAD sets, to protect clients’ digital assets and fiat money held in custody, and to have a contingency plan for an orderly and solvent wind-down. It also requires providers to report their prices and charges to the CNAD every quarter. Quarterly confidential reports on the issuances and stablecoins traded on the platform are due in the first 20 days of April, July, October and January.

The technology rules are specific. A provider’s systems must be able to resume critical operations within six hours of a cyberattack and complete any unsettled transactions within 24 hours. The regulation also calls for independent external cybersecurity audits and periodic testing that covers failures of confidentiality, availability and integrity. At the registration stage the CNAD asks for the person responsible for cybersecurity, with direct access to the board, and for copies of contracts with key technology providers.

There is also a conduct requirement. Each provider must draw up a code of ethics within six months of definitive registration, covering conflicts of interest, fair treatment of clients and the prevention of money laundering. For our trading business, these obligations would shape its budget for years, not only its first application.

 

What the licence does not cover

A Salvadoran registration does not by itself allow a company to serve customers in other regulated markets. Take the European Union. Under MiCA, third-country firms may serve EU clients only where the client approaches the firm at its own exclusive initiative. ESMA says the exemption must be read very narrowly and cannot be used to circumvent MiCA. Its guidelines treat solicitation broadly, including through anyone acting on the firm’s behalf or having close links with it. A trading business that planned to market actively to EU customers from El Salvador would have a problem that no Salvadoran licence can solve.

Fiat access raises a separate question. The CNAD guide expects applicants to describe their liquidity providers and their connection to the traditional financial system. Registration does not oblige a bank or payment provider to open an account. The founders should test those relationships before committing.

The rules around the framework are also still moving. The IMF’s October 2026 review calls for stronger regulation and supervision of crypto-asset providers and for amendments to the Digital Asset Issuance Law as appropriate. The IMF’s earlier work on the Bitcoin legal-tender policy found that it had not improved financial inclusion and that private use remained minimal. A company that expects a large domestic customer base should not rely on the country’s Bitcoin profile as evidence of demand.

Finally, the central bank’s Bitcoin register is a different thing from the CNAD’s. Entries on the BCR list carry a note saying that registration with the central bank is not authorisation to operate, and that authorisation comes from the CNAD. A company that holds only a BCR entry has not been authorised under the digital-asset framework.

 

Who this suits

El Salvador suits a business that already has a finished platform, a compliance officer who will live in the country, and a clear account of which Article 19 activities it performs. It may also suit an issuer that wants a defined offering procedure, or a group, like Bitfinex, that wants a regulated base for one product line. Those are the cases the evidence supports.

It suits a project less well if the platform is unfinished or the compliance function is meant to stay entirely abroad. The same goes for a business whose revenue depends on soliciting customers in markets where El Salvador’s authorisation carries no weight. The registrations show that companies are choosing the country. They do not show that its advantages transfer to every business.

 

El Salvador at a glance 

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