El Salvador DASP License: Complete Tokenization Guide 2026

A DASP (Digital Asset Service Provider) registration with El Salvador's National Digital Assets Commission (CNAD) lets a company provide digital asset services under the Digital Assets Issuance Law (Ley de Emisión de Activos Digitales, "LEAD"). Issuers making public offers of digital assets, including tokenized real-world assets, need CNAD approval of the offer. The statute fixes registration fees in multiples of the minimum wage and grants broad tax exemptions for digital-asset activity. The practical constraints are banking access and a young regulator.

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What is the El Salvador Digital Assets Issuance Law?

The Legislative Assembly approved the Digital Assets Issuance Law as Decree No. 643 on 11 January 2023, and the President signed it on 23 January 2023. It was amended by Decree No. 781 of 27 June 2023. The law followed the 2021 Bitcoin Law but sets up a separate framework for public offers of digital assets and for digital asset service providers.

The law created the CNAD (Comisión Nacional de Activos Digitales), a decentralized public institution with its own budget, attached to the Ministry of Economy. CNAD applies the law, approves public offers, and keeps the registers of issuers, certifiers and digital asset service providers (LEAD Articles 6, 7 and 9). It also created the Bitcoin Fund Administration Agency, which handles state offerings.

Key provisions of the law include:

• A definition of digital assets as digital representations stored and transferred using distributed ledger or similar technology (Art. 3)
• Digital assets are not treated as securities ("títulos valores") under Salvadoran law; the Securities Market Law and related securities statutes do not apply to them (Art. 3)
• A Register of Digital Asset Service Providers run by CNAD (Art. 18)
• CNAD approval of public offers, supported by an information document certified by a CNAD-registered certifier (Arts. 26 and 32)
• Market-integrity and anti-manipulation duties (Arts. 34–35)
• Private offers are excluded from the public-offer rules (Art. 31)

2025 update: In January 2025 El Salvador amended its Bitcoin Law. The IMF lists the changes, made as prior actions for its programme: Bitcoin acceptance became voluntary, taxes are payable only in US dollars, and Bitcoin is no longer classed as currency. The IMF Executive Board approved a 40-month Extended Fund Facility of SDR 1,033.92 million (about US$1.4 billion) on 26 February 2025. The Digital Assets Issuance Law remains the framework for DASP registration and public digital-asset offers.

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What Activities Can a Registered DASP Perform?

Article 19 of the law lists the services a registered DASP may provide:

Relevance for tokenization: the issuer of a public offer is regulated as an issuer, and the service providers around it (placement, platform, custody) need DASP registration. Under Article 19-A, the Central Reserve Bank (BCR) may also authorize DASPs to access payment and securities settlement systems.

Example: Bitfinex Securities El Salvador, a registered DASP, announced in May 2024 a tokenized debt offering of up to US$6.25 million on the Liquid Network to finance a Hampton by Hilton hotel at El Salvador International Airport. The offering was announced by the platform and the developer; we have not independently verified its final outcome.

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Requirements and Process for DASP Registration

Who Can Apply

Natural and legal persons may register. A foreign legal entity must form a Salvadoran company (sociedad anónima) or branch, domiciled in El Salvador and registered with the Centro Nacional de Registros, and present its documents to CNAD (Art. 18(d)).

Application Requirements

Article 20 sets the core requirements, including showing the capacity to provide the services listed in the registration form. CNAD's regulations and forms set the detail. Expect to provide:

Application Process

1. Pre-application: engage local counsel; form the local entity; prepare corporate and AML documentation
2. Submit to CNAD: file the registration application and pay the registration fee
3. Review: respond to CNAD's requests for further information
4. Registration: CNAD enters the provider in the register

CNAD does not publish a guaranteed processing time.

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Fees and Costs

Statutory Fees (LEAD Article 12)

The fees are set in minimum wages, so their dollar value moves when El Salvador raises the minimum wage. Check the current minimum wage before budgeting.

Other Costs

Local counsel, AML programme design, a local entity and compliance staff usually cost far more than the statutory fees and depend on the services you register for. We do not publish all-in estimates for El Salvador. If CNAD sets capital requirements for your services in its regulations, they come on top.

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Tax Treatment

• General corporate income tax: 30%, or 25% for companies with taxable income of up to US$150,000 (Income Tax Law, as reported by the Ministry of Finance).
• Digital-asset exemptions: LEAD Article 36 exempts the nominal value of, and income from, digital assets covered by the law from taxes, and exempts capital gains on their transfer. Registered issuers, certifiers and DASPs are exempt from VAT, income tax and municipal taxes on their digital-asset activity. The benefits extend to shareholders for dividends from those activities, but do not apply to exchanges of digital assets for goods or services outside Article 19.

How these exemptions apply to a specific structure, and how investors' home countries treat the same income, needs Salvadoran and home-country tax advice.

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Limitations and Risks: An Honest Assessment

Banking and Correspondent Access

This is often the most significant operational challenge. El Salvador has used the US dollar as its official currency since 2001, which simplifies domestic USD transactions. However:

• Correspondent banking caution: international banks apply enhanced due diligence to flows linked to digital-asset businesses in emerging markets
• Limited domestic banking options: few Salvadoran banks actively serve DASPs
• Institutional wire friction: large investor subscriptions into a Salvadoran account will attract enhanced due diligence from the sending bank

Practical impact: for institutional deals with US, EU or UAE investors, banking friction adds cost and delay.

Regulatory Maturity

CNAD has operated since 2023, and its secondary regulations are still developing. There is limited precedent compared with older financial centres.

Securities Characterization Abroad

Article 3 says digital assets are not securities under Salvadoran law. That does not change how investors' home jurisdictions classify the same token. A token sold to US or EU investors can still be a security under their laws, so the offering analysis in each investor market still applies.

FATF Status

El Salvador is not on the FATF list of jurisdictions under increased monitoring published on 19 June 2026. The British Virgin Islands is on that list, which matters if you are choosing between offshore vehicles.

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Who Should Consider El Salvador for Tokenization?

El Salvador's DASP framework is not the right choice for every tokenization business. The strongest fit cases are:

LATAM-focused operations: companies targeting Latin American investors or structuring around LATAM assets may find the USD economy and dedicated digital-asset law practical.

Digital-asset-native products: the LEAD tax exemptions and a dedicated regulator suit products that are digital assets under Salvadoran law, subject to tax advice.

Regulatory optionality: a company licensed elsewhere may add a Salvadoran DASP for LATAM reach. Weigh the banking constraints before relying on it.

What El Salvador is NOT suited for:

• Primary licensing for institutional deals whose investors expect a mainstream securities regime and fund domicile
• Operations that need immediate access to global correspondent banking

For how El Salvador compares with other issuer domiciles, see our best jurisdiction for tokenized asset issuance guide. Our legal setup coordination maps the issuer, service-provider and investor-market questions with qualified counsel.

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Frequently Asked Questions

What does CNAD stand for in El Salvador?

CNAD stands for Comisión Nacional de Activos Digitales, the National Digital Assets Commission. The Digital Assets Issuance Law of January 2023 created it as a decentralized public institution attached to the Ministry of Economy. It approves public offers of digital assets and keeps the registers of issuers, certifiers and digital asset service providers.

How much does a DASP license cost in El Salvador?

The statutory fees are a one-time registration fee of 15 monthly minimum wages (commerce and services sector) and an annual renewal of 10 minimum wages, under Article 12 of the Digital Assets Issuance Law. Issuers also pay 0.01% of an approved public offer. Professional, staffing and banking costs come on top and depend on the business.

Is El Salvador FATF grey-listed?

No. El Salvador is not on the FATF list of jurisdictions under increased monitoring published on 19 June 2026. Check the latest FATF statement before relying on this, as the list is updated after each plenary.

Can I issue security tokens under El Salvador law?

You can make public offers of digital assets, including tokens that give rights to debt or asset income, with CNAD approval. Under Article 3, those digital assets are not securities under Salvadoran law, and the Securities Market Law does not apply to them. Investors' home jurisdictions may still treat the same tokens as securities, so the offering analysis in each investor market still applies. Engage qualified local counsel before structuring.

What is the relationship between El Salvador's DASP framework and the Bitcoin Law?

They are separate regimes. The Bitcoin Law (2021) made Bitcoin legal tender. The Digital Assets Issuance Law (2023) created CNAD and the framework for public digital-asset offers and service providers. The January 2025 amendments to the Bitcoin Law made Bitcoin acceptance voluntary and ended its status as currency; they did not replace the Digital Assets Issuance Law.

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Sources

• Ley de Emisión de Activos Digitales, Decree No. 643 (opens in a new tab) (as amended by Decree No. 781 of 27 June 2023), Articles 3, 6, 12, 18–20, 31 and 36
• IMF: Executive Board approves 40-month Extended Fund Facility for El Salvador, 26 February 2025 (opens in a new tab); IMF Country Report No. 25/58 (opens in a new tab)
• FATF: Jurisdictions under Increased Monitoring, 19 June 2026 (opens in a new tab)
• Ministerio de Hacienda: Income Tax Law corporate rates (30%; 25% up to US$150,000 of taxable income)
• Liquid Network: Bitfinex Securities tokenized debt for the El Salvador airport Hilton hotel, 22 May 2024 (opens in a new tab)

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This article is informational and does not constitute legal, tax or investment advice. Asset Haus provides tokenization infrastructure and structuring support, including for multi-jurisdiction structures that involve El Salvador as part of work across 9+ jurisdictions; legal setup is coordinated with qualified counsel. See our legal setup workflow, client case studies, or start with the legal perimeter memo.