An El Salvador crypto licence is not one licence: it is two separate registers. Digital asset service providers (PSAD/DASP) register with the National Commission of Digital Assets, CNAD. Bitcoin service providers register with the central bank, the BCR. Which applies follows three things: the activities you carry on, the asset involved, and whether you market into the country.
Four numbers that decide this
Three things to carry away
- Two registers, two regulators: CNAD under the Digital Assets Issuance Law, the BCR under the Bitcoin Law regulation. Neither covers the other.
- A foreign company cannot register with CNAD in its own name — it must first form a Salvadoran corporation or branch, registered with the National Registry Center (LEAD Art. 18(d)).
- The CNAD fee is written in the law as a multiple — fifteen minimum wages — not a fixed sum, so the cash figure moves when the minimum wage does. CNAD's page currently puts it at $5,475.
On this page9 sections
Which El Salvador register does your business need?
A digital asset service provider registration is a permission to carry on named activities, not a general licence to operate: the answer turns on what you do and for whom, not on the label an intermediary puts on the offer. Each row below comes from the text of one of the two instruments, both linked in the sections that follow. A model can sit in more than one row, and then each regime is tested on its own.
Business model to register: which one applies
| What the business does | Which register |
|---|---|
| Buys and sells its own goods and services in bitcoin | Outside the bitcoin provider definition (Reglamento Art. 2(e)) |
| Non-custodial software; never holds client bitcoin or private keys | Outside the bitcoin definition, but Art. 19(f)(2) reaches "the means to access or control" assets, so the CNAD side still needs analysis |
| Custody of client bitcoin, bitcoin exchange, bitcoin payment processing or wallets | BCR bitcoin service provider register (Reglamento Arts. 2(e), 3) |
| Exchanges tokens other than bitcoin — stablecoins such as USDT, ETH, tokenised assets — for fiat, on its own or a client's capital | CNAD DASP registration (LEAD Art. 19(a)) |
| Runs a multi-asset platform including bitcoin | Both sides need testing — Art. 4(b) carves the Art. 19 services back in |
| Issues its own token or stablecoin to the public | A different route again: the issuer requirements in Art. 22, not the DASP register |
| No Salvadoran entity, but markets to clients in the country | Caught by the DASP test (LEAD Art. 5(v)) |
The last row is the one most often missed, and the issuer row is the other: a company that issues its own token to the public is not registering as a service provider at all. Article 22 of the LEAD puts the issuer through its own requirements — among them a certifier's favourable opinion on the white paper and registration of the issuance — and Article 12(2)(a) prices that route as 0.01% of the authorized public offering rather than as the provider's flat fee.
Send us your model, where your clients are and who holds the keys — Telegram @fever23. For how El Salvador compares with the other main routes, see Swiss SRO vs EU MiCA vs El Salvador.
Who counts as a DASP, and can a foreign company register?
These are two different questions and conflating them is the common mistake. A DASP — PSAD in CNAD's Spanish documents — is a business that provides one or more of the Article 19 services as its ordinary line of business. Article 5(v) decides whether you are caught. Article 18(d) decides whether you are registrable as you stand.
Article 5(v) of the Law for the Issuance of Digital Assets (CNAD's own English text, marked a non-official translation) adds a second limb to that definition: the provider is either domiciled in El Salvador, or not domiciled there but actively promoting or marketing services to potential clients in the country. CNAD puts the second limb on its own registration page in the same words:
It is not domiciled in El Salvador, but actively promotes or markets its services to potential clients in the country.
Article 18(d) then sets the form: a foreign legal entity domiciled in another country, jurisdiction or territory must form a corporation or branch "domiciled in El Salvador and duly registered with the National Registry Center", and Article 18(a) allows regulated providers to offer digital asset services only once registered with CNAD. CNAD's guide does contemplate an applicant that has not yet done so: the pre-registration form asks for an exact physical address and, failing one, a statement that the applicant has no domicile in El Salvador. Where CNAD objects at the second pre-registration review, the stated ground is lack of territorial and material competence under Articles 2 and 4. See also local substance requirements.
What does a DASP registration permit?
A DASP registration covers the activities listed in Article 19 of the law that you declared and CNAD accepted — not the list as a whole. The statute says providers "may carry out the following activities", and the public register then publishes, provider by provider, which of them each one holds. Here is the list in full:
The digital asset services listed in Article 19
| Art. 19 | Activity |
|---|---|
| (a) | Exchange of digital assets for fiduciary money or equivalent, or for other digital assets, on own or third-party capital |
| (b) | Operating a platform for the exchange or commercialization of digital assets or their derivatives |
| (c) | Risk and price evaluation, and subscription to digital asset issuances |
| (d) | Placing digital assets on digital platforms or wallets |
| (e) | Promoting, structuring and managing investment products in digital assets |
| (f) | Four operations on behalf of and for the benefit of third parties: transferring digital assets or the means to access or control them; safeguarding, custodying or managing them; receiving and transmitting buy or sell orders; executing derivative orders |
Article 20(a) requires an applicant to "demonstrate the ability to offer the digital services indicated in its registration form", and CNAD's guide adds that where capacity and services do not match the business plan, the file may continue only for the activities that do. The authorisation is also national in reach: Article 2 states that the law "is applicable to public offerings of digital assets in the territory of El Salvador", so whether you may serve clients in another country is decided by that country's rules, not by this registration. On custody, see when a wallet needs a custody licence.
Who must register with the BCR as a Bitcoin Service Provider?
The bitcoin side is a filing, not a supervisory application. Article 3 of the Reglamento de la Ley Bitcoin creates the Registro de Proveedores de Servicios de Bitcoin, places it with the Banco Central de Reserva, and requires a provider, before operating, to submit only the form, a digital copy of its incorporation deed and its shareholders' identity documents.
Article 2(e) of the Reglamento (Decreto No. 27, text as issued 27 August 2021) defines the provider as a natural or legal person providing bitcoin-related services for itself or for third parties, and names custodians, exchanges, payment processors and wallets as examples — the Spanish frames that list as illustrative and not limiting. Article 3 likewise says the register covers those providers among others. The same article excludes three groups:
- people who use bitcoin for their own purposes;
- businesses that transact in bitcoin only as a means of payment for the purchase and sale of their own goods and services;
- technology providers that do not hold custody of clients' bitcoin or private keys.
Article 4 sets nine conduct standards in all; the three that bear on this decision are an AML programme meeting the Ley contra el Lavado de Dinero and FATF practice, the safeguarding of client assets, and publishing the SSF's contact details on the website and in the user terms so unresolved complaints can reach it. Article 5 gives supervision and sanctions to the Superintendencia del Sistema Financiero. Article 6 sets banking expectations:
Banks may, but are not obliged to, provide their financial services to a bitcoin service provider or open bitcoin accounts for users. (our translation from the Spanish)
One timing point to raise with the BCR rather than assume: the only deadline Article 3 attaches to that filing ran 20 business days from the Regulation's own entry into force — that is, from its 2021 commencement — so a business entering today should confirm current filing practice with the BCR. What the banking position means in practice is in can a licensed crypto business open a bank account.
Could a business need both?
Yes. Article 4(b) of the LEAD takes an asset that is legal tender somewhere out of the law when it is used to exchange goods and services — and then, in the same sentence, puts back the goods categorised as digital assets and "the services set forth in Articles 19 and 26" of the law. Legal-tender status therefore does not settle the question on its own.
The usual shortcut — bitcoin to the BCR, everything else (stablecoins, ETH, tokenised assets) to CNAD — holds for a single-asset business and breaks as soon as what you do for third parties with bitcoin sits in the Article 19 list. Separate the actions: who holds access, for whose benefit, what sits on each side of an exchange. One thing this page does not resolve is the current status of the Bitcoin Law's legal-tender provisions; what we verified first-hand is narrower — the Reglamento quoted here is the decree as issued on 27 August 2021, and the BCR's register was live when we read it on 18 October 2026 — so check the statute as it now stands before relying on that limb.
How does the CNAD registration run?
CNAD's PSAD requirements guide names its basis as Articles 9(d), 18, 20 and 21 of the LEAD plus Articles 7 and 17 to 35 of the digital asset service providers regulation, and sets out two pre-registration phases and a registration stage. The timings come from CNAD's registration page and Article 20 of the law, not from the guide:
- Pre-registration Phase 1 (guide) — an expedited assessment of the business model and platform.
- Pre-registration Phase 2 (guide) — the AML/CFT prevention system and the risk management of the proposed activities.
- Registration (guide) — the full documentation, in digital and physical form, at CNAD's offices.
- Resolution (CNAD registration page) — a maximum of 20 business days for a favorable or unfavorable resolution, or notice to complete an incomplete file. CNAD's page gives 10 business days to complete it; Article 20 of the law itself says five, so confirm the current period with CNAD.
- Seat (CNAD registration page) — the registration certificate and authorization to operate, with the Financial Investigation Unit notified.
Three requirements that need lead time
- Audited accounts. Audited financial statements for the last three years, or for as long as the company has existed, plus a three-year business plan with projections.
- Compliance officers must be your employees. The board act creating the compliance office, a principal and a deputy officer, CVs meeting Articles 64 and 84-B of the UIF instruction, and an employment contract proving a direct employment relationship with the applicant company. An outsourced arrangement does not satisfy it.
- A board-appointed security lead. The OSI/CISO's name, role, certifications and experience, and a board act appointing them with direct access to the board — plus contracts with key technology providers (KYT, KYC, custody, cybersecurity, geofencing) and public wallet addresses in editable format.
The AML pack also includes a Travel Rule policy under Article 84-B(1)(e) of the UIF instruction, keeping records that show where a transaction came from and went to — see what must travel with a crypto transfer. The guide publishes four grounds on which a file is archived rather than decided:
- unanswered form sections with no valid justification;
- statements that information is still in development or will follow;
- blank documents;
- a technical meeting that does not happen for reasons attributable to the applicant.
An archived file can be presented again under Article 72 of the administrative procedure law; after a negative outcome, see what happens if your application is rejected.
What does an El Salvador DASP registration cost to get and to keep?
The law fixes the fee as a multiple of the minimum wage rather than a sum, so the cash figure moves when the wage does. Article 12 of the LEAD sets the one-time fee and the annual renewal; CNAD's registration page carries the current cash figure. Confirm it with CNAD before budgeting.
Fee and annual renewal: what the law says, what the page says
| Item | What the source says |
|---|---|
| One-time registration fee | Fifteen minimum wages in the commerce and services sector (LEAD Art. 12) |
| Current cash figure | "Payment of the initial registration fee ($5,475) within 10 days from the notification of the resolution" (CNAD registration page) |
| Annual renewal | Ten minimum wages in the same sector, during the first quarter of the year (LEAD Art. 12) |
| If renewal is not paid | "If payment is not verified during this period, the registration will be canceled" (LEAD Art. 20) |
| Issuer of a public offering | A separate basis: 0.01% of the authorized public offering (LEAD Art. 12(2)(a)) |
Article 36 runs the other way: registered providers, issuers and certifiers are exempt from the tax on the transfer of movable goods and rendering of services, income tax and municipal tax on their digital asset activity, and for a company the same benefit extends to partners and shareholders on dividends from that activity. Read it with its own limit — Article 36(e) says the benefits "shall not apply when transactions of exchange of digital assets for goods or services that are not detailed in Article 19" are carried out. For year two, see annual obligations after the licence.
How do you check an El Salvador registration yourself?
Both registers are public, so a counterparty's claim can be checked at source rather than taken from a screenshot. CNAD's register lists each provider's website, registration number, registration date and the activities it is registered for, in the words of Article 19 — which is what makes scope checkable rather than assumed.
Read on 18 October 2026, CNAD's public register of digital asset service providers listed 87 providers, numbered PSAD-0001 to PSAD-0098, the highest number being PSAD-0098, registered 25/09/2026. Eleven numbers in that range do not appear in the published list, and the register does not say why. Recognisable names are there to check against: Binance Services El Salvador, OKX Fintech (PSAD-0052, registered 23/05/2025), Bitfinex Derivatives El Salvador and WEEX GLOBAL. On a CNAD entry the number matters less than the activity lines under it: do they cover what that company proposes to do for you? On the bitcoin side the BCR publishes its register under the heading Registro de Proveedores de Servicios Bitcoin, still live when we checked the same day. The general method is in how to check a crypto licence is real.
FAQ
What happens if we stop operating as a bitcoin service provider?
You tell the BCR and you come off the register quickly. Article 3 of the Reglamento requires a provider that decides to discontinue to inform the BCR immediately, and the BCR removes it from the register within 72 hours at the latest. Removal there follows the provider's own notice rather than a decision of the central bank's.
Do proprietary traders need a DASP registration in El Salvador?
Own-account trading is inside the Article 19(a) wording, which describes exchange carried out "either using their own capital or that of a third party". Only the four operations in Article 19(f) are premised on acting for third parties, so not touching client assets rules out (f), not (a).
Do non-custodial wallet providers need a licence in El Salvador?
The two definitions land differently. The bitcoin regulation's Article 2(e) expressly excludes technology providers that do not hold custody of clients' bitcoin or private keys. The LEAD's Article 19(f)(2) reaches safeguarding, custodying or managing digital assets or the means to access or control them — a step further out. The same product can be excluded on one side and still need analysis on the other.
Can you buy a ready-made PSAD company instead of applying?
Check which activities you are buying. The register publishes them, and they may not cover what you intend to do; widening them means a modification request to CNAD, where the same business-plan-match test applies. The checklist is in is buying a ready-made licence worth it.
Next step
El Salvador BSP and DASP is one of CryptoLicense's four named licensing lines, alongside Switzerland SRO membership, New Zealand FSP registration and Latvia EMI/CASP, across 10+ jurisdictions and 100+ companies served. We draft the documents and assemble what the application requires — bank account, local address, local personnel.
Send your business model and where your clients are to Telegram @fever23 for a view on which Article 19 activities your actions fall under, whether the bitcoin side needs assessing too, and which document to start on first.
This page is general information, not legal advice. CryptoLicense is an advisory firm, not a regulator and not a law firm. No approval or registration can be guaranteed: regulators retain full discretion over the outcome.
Part of a guide series: the full guide is licence selection.