El Salvador — CNAD licence.
El Salvador's Comisión Nacional de Activos Digitales issues licences under the Bitcoin Law framework — unique globally for BTC-legal-tender recognition.
A considered route,
not a shortcut.
This jurisdiction rewards operators who treat the application as the start of a supervisory relationship.
When this is the right choice
When to consider an alternative
Permissions under
one Act.
Choosing the right tier and scope is the most consequential decision in the application.
Digital Asset Service Provider (DASP)
The primary authorisation under the Digital Assets Law for entities providing exchange, custody, transfer, or advisory services for digital assets. Requires demonstrated AML programme, capital adequacy, and technical infrastructure aligned with CNAD standards.
Bitcoin Service Provider
Entities providing Bitcoin-specific services (custody, payments, merchant acceptance, Lightning Network operations) may qualify under the Bitcoin Law framework — distinct from the broader DASP category and with lighter initial requirements.
Digital Asset Issuer
Entities issuing tokenised assets, stablecoins, or security tokens in El Salvador require a Digital Asset Issuer authorisation from the CNAD. This covers initial offerings, secondary trading facilitation, and ongoing token management obligations.
Phases to licence grant.
Structure & pre-application
Weeks 1—6El Salvador corporate vehicle incorporated. CNAD pre-application meeting secured. Business model mapped to the applicable DASP or Bitcoin Service Provider category. AML programme and governance framework drafted.
Application filing
Months 2—3Application submitted to the CNAD — entity documentation, UBO disclosures, AML manual, technical infrastructure overview, financial projections, and evidence of capital adequacy.
CNAD review
Months 3—5CNAD review period. Q&A rounds on business model, AML programme quality, and beneficial ownership chain. CNAD has a proactive engagement style and typically provides constructive feedback during the process.
Authorisation & operations
Months 5—6Authorisation granted. Banking and payment relationships activated. Ongoing AML reporting, annual renewal, and CNAD supervisory obligations commence.
Cost and regulatory
burden.
Year-one spend is dominated by substance — resident director, office, compliance officer, external audit — not the licence fee itself.
| Cost item | Amount |
|---|---|
| CNAD application fee | USD 1,500—5,000 |
| Annual supervisory fee | USD 2,000—8,000 |
| Minimum operational capital | USD 50,000 |
| El Salvador corporate incorporation | USD 2,000—4,000 |
| AML programme & compliance officer | USD 10,000—20,000 / yr |
| Legal & advisory (setup) | USD 15,000—30,000 |
| Year-1 total | ~USD 30—60K (yr 1, ex. USD 50K capital) |
El Salvador offers one of the lowest-cost credible crypto licensing frameworks globally. Bitcoin and foreign-sourced crypto gains may be exempt from income tax under the current regime — specialist tax advice is required to confirm applicability to your specific structure.
What founders
ask before filing.
The questions we get on every diagnostic call. If yours isn't here, raise it in the consultation.
Tell us where
you want to
operate.
Forty-five minutes with a partner. Jurisdiction memo within seven days. No retainer required to start.
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