El Salvador DASP License

What is an El Salvador DASP licence?

A DASP licence is the registration that lets a company provide digital asset services from El Salvador. Spanish-language filings and the CNAD register use the term PSAD, Proveedor de Servicios de Activos Digitales. The legal basis is the Ley de Emisión de Activos Digitales (LEAD), Legislative Decree 643 of 2023, amended in October 2024.

CNAD publishes every registered provider in its Registro Público, together with the operations each one may carry out. The register listed 81 providers on 21 August 2026, among them Tether International, two Bitfinex entities, Binance Services El Salvador and OKX Fintech. Anyone can check a counterparty there before signing.

Verify any provider yourself in the CNAD public register at cnad.gob.sv/public-registry.

Who regulates digital assets in El Salvador?

CNAD registers and supervises digital asset service providers and Bitcoin service providers, and it applies sanctions. Around it sit three more bodies. The Unidad de Investigación Financiera (UIF) receives suspicious activity reports and registers compliance officers. The Banco Central de Reserva (BCR) and the Superintendencia del Sistema Financiero (SSF) supervise private investment funds, which CNAD does not.

One state body is easy to mistake for a regulator. The Agencia Administradora de Fondos Bitcoin (AAB) issues digital assets for the Salvadoran state and its autonomous institutions under LEAD and manages the proceeds. The AAB supervises nobody, and a private applicant deals with CNAD.

Supervision volume is unusual for a jurisdiction this size. CNAD oversaw more than $300 billion in digital assets as of January 2026, around 61% of it held by Tether. That figure counts activity regulated from El Salvador rather than activity inside the country.

Plan the launch calendar around one number. LEAD gives CNAD 20 business days to issue a favourable or unfavourable resolution on a complete registration application. Where a filing is incomplete, CNAD notifies the applicant, who then has 10 business days to supply what is missing.

What does the DASP licence cover?

Article 19 of LEAD lists the digital asset services a registered provider may offer, and CNAD authorises each provider for named operations from that list. The table below uses the regulator's own wording rather than marketing labels, because those authorised operations are what appears in the public register.

Vendor labels map onto that list rather than replacing it. A crypto exchange, an OTC desk, a custodial wallet, a DeFi front end, an NFT marketplace and a tokenisation platform each match their operations to named Article 19 services in the application, because CNAD registers the operations and not the label.

The Article 19 list carries two limits. Article 36 withdraws the tax benefits where a provider exchanges digital assets for goods or services that Article 19 does not list. Bitcoin-specific services fall outside the DASP registration altogether and need a separate PSB registration.

DASP or BSP: which registration do you need?

Bitcoin services need a Proveedor de Servicios Bitcoin (PSB) registration, called BSP in English. The October 2024 reform of LEAD excluded PSB from the tax benefits that Article 36 grants to PSAD. An operator holding both registrations therefore runs a taxed Bitcoin business next to an exempt digital assets business.

Most guides get this wrong. They present 0% tax as a blanket feature of El Salvador. Then they tell readers to apply for both registrations at once, which reads as though the exemption covers both layers. It does not.

Plan the split before you file. Where Bitcoin services are a side line, keeping them in a separate entity keeps the tax analysis clean. Where they are the core product, the exemption argument for the whole group is weaker than the marketing suggests.

How do DASP and BSP registrations compare?

Both registrations sit with CNAD, and both carry the AML, cybersecurity and reporting duties tightened by the October 2024 reform. Tax treatment is where the two part company.

Who is the El Salvador DASP licence for?

• The DASP suits crypto and fintech companies that need a regulated base for global operations, not access to a domestic market. Applications come from three profiles, and each one reaches CNAD for a different reason: proving regulated status, adding a service line, or moving a platform outside the EU perimeter.

• Exchanges and wallets that need regulated status to open banking and PSP accounts.

• Established operators adding a B2B white-label or payments layer.

• DeFi and NFT platforms that want a base outside the EU.

Applicants must be companies. A natural person cannot hold a PSAD or PSB registration.

The DASP gives no EU passporting. Serving EU retail customers requires authorisation under the EU Markets in Crypto-Assets Regulation (MiCA), so operators whose plan is EU retail should weigh a European authorisation instead.

What are the requirements for an El Salvador DASP licence?

Most applications turn on four requirements: the corporate form, the compliance officers, a working bank account, and an AML framework that already runs. Documents on shareholders and directors sit under those four. CNAD assesses the framework operationally, so a policy manual written for the filing rarely survives review.

Corporate form: sociedad anónima, and why SAS fails

PSAD and PSB registrations go only to companies entered in the Registro de Comercio at the Centro Nacional de Registros (CNR). The eligible forms are a sociedad anónima (S.A. de C.V.) and a branch of a foreign company. The LEAD reform set that limit. That amendment was introduced in August 2024 and took effect in October 2024. The limit excludes the Sociedad por Acciones Simplificada (SAS), added to the Commercial Code in December 2023.

Salvadoran counsel often defaults to SAS for a new subsidiary because it forms faster. CNAD will not accept a DASP application from an SAS entity, so the structure has to be checked before incorporation rather than after.

Minimum share capital for a sociedad anónima is $2,000, of which 5% is paid at incorporation and the balance within one year. CNAD may require more capital depending on the volume and nature of the planned operations.

Compliance officers: a named officer and an alternate

The October 2024 reform of LEAD placed enhanced anti-money-laundering, counter-terrorist-financing and proliferation-financing programmes on both PSAD and PSB. The Ley Especial contra el Lavado de Activos (Legislative Decree 426) then came into force on 17 October 2025. Every obligated subject appoints a compliance officer and an alternate and registers both with the UIF, and Bitcoin service providers are named among the obligated subjects. A prevention committee and a documented risk-based programme come with the appointment.

Qualified candidates with crypto experience are scarce in El Salvador, so recruitment belongs at the start of a project rather than at filing. In our practice, retaining a local firm to cover the alternate function costs more than an employed officer.

Banking before CNAD registration, not after

A working corporate bank account should be in place before the definitive CNAD filing. In our experience accounts get harder to open once a registration number is public, and operators who file first commonly lose eight to sixteen weeks. Salvadoran banks that accept registered providers usually want an in-person visit, and licensed European electronic money institutions (EMIs) cover part of the need.

Documents for each shareholder and director

Foreign documents need an apostille and a certified Spanish translation. One incomplete personal file holds up the whole application, because CNAD reviews the set rather than the average.

How long does an El Salvador DASP licence take?

Three to six months is realistic from engagement to an operating registration. The CNAD review window is 20 business days on a complete definitive filing. Corporate and banking steps set the calendar, not the regulator. Applications with a live bank account and a working AML framework land near the bottom of that range.

Missing the banking sequence is the most expensive scheduling mistake on this route. In our practice, operators who file with CNAD before the account works lose eight to sixteen weeks.

What taxes apply to an El Salvador DASP?

Registered digital asset service providers, issuers and certifiers pay no tax on their digital asset activity under Article 36 of LEAD. The exemption covers income tax, VAT, municipal taxes and any other levy on that activity, and it extends to shareholders on dividends from it.

Three limits apply to the Article 36 exemption. Article 36 does not cover PSB, which the October 2024 reform removed from the benefits. Where a company earns both digital asset and fiat income, only the digital asset portion is exempt, so confirm the split with Salvadoran tax counsel before you structure. Where digital assets are exchanged for goods or services outside Article 19, the benefits do not apply.

The January 2025 Bitcoin Law amendment did not touch any of this. That change removed mandatory merchant acceptance of Bitcoin, and Article 36 stands as of August 2026.

PAIF: the fund layer above the licence

The Ley de Fondos de Inversión Privados Alternativos (Legislative Decree 430) was published on 17 October 2025. The law created the fondo de inversion privado alternativo (PAIF), a private fund vehicle for sophisticated investors, and a PAIF may invest in digital assets under LEAD. The BCR issues the technical norms and the SSF verifies compliance, so a PAIF sits outside CNAD supervision.

Access is narrower than most write-ups suggest. A sophisticated investor is a person who invests at least $250,000 and holds $50 million in assets, and the Sociedad Administradora that runs the fund needs $10 million in paid-up capital. For most DASP applicants a PAIF is not a realistic treasury layer, and quoting the $250,000 figure on its own gives the wrong impression.

How does El Salvador compare with other crypto licence jurisdictions?

Four regulated routes come up most often. El Salvador registers a PSAD with CNAD; Lithuania authorises a crypto-asset service provider (CASP) under MiCA; Cayman and the British Virgin Islands register a virtual asset service provider (VASP) with the Cayman Islands Monetary Authority (CIMA) and the BVI Financial Services Commission. Detail on each sits at /license.

El Salvador combines the lowest statutory capital floor in this group with a zero rate on digital asset activity. That matters most to operators who do not need EU retail access. The EU route is the choice when passporting decides the business model, and it costs more capital and more tax to get there.

What are the advantages of the El Salvador DASP licence?

The decision usually rests on five points: a zero rate on digital asset activity, a $2,000 statutory capital floor, B2B provision under Article 19, a public register of real licensees, and no FATF increased-monitoring listing. Each one is checkable against LEAD or the CNAD register rather than against a brochure.

• Zero tax on digital asset activity under Article 36 of LEAD, for a registered PSAD.

• Statutory share capital from $2,000, the lowest floor among the jurisdictions compared on this page, though CNAD may require more once it sees the planned volume.

• B2B provision under Article 19, which lists transfer, custody and order execution carried out on behalf of third parties.

• A verifiable register rather than a claim: CNAD listed 81 providers on 21 August 2026, among them Tether International, Bitfinex entities, Binance Services El Salvador, OKX Fintech and BG El Salvador, the Bitget entity.

• No FATF increased-monitoring listing, which is narrower than calling the country FATF compliant.

The wording of that last point matters. The mutual evaluation by GAFILAT, the Latin American financial action task force, adopted in August 2024, rated El Salvador non-compliant on nine Recommendations, and compliant or largely compliant on 11 of the 16 Core and Key Recommendations. Absence from the FATF monitoring list is not the same as FATF compliance.

What are the disadvantages and non-obvious pitfalls?

Seven issues cost applicants real money on this route, and none of them appears in a brochure. Corporate form, the tax gap between DASP and BSP, the banking sequence, a live compliance framework and a thin pool of compliance officers decide most of them. CNAD's capital discretion and annual tariff-setting decide the rest.

• SAS is not eligible. Local counsel often forms an SAS by default. CNAD will not accept the application, and the fix is a restructuring into a sociedad anónima before any filing.

• BSP carries no tax relief. The October 2024 reform took Bitcoin service providers out of Article 36. Treating 0% as a blanket feature of the jurisdiction produces a tax bill nobody budgeted for.

• Banking comes before registration. The account has to work before the definitive filing, and reversing the order typically costs eight to sixteen weeks.

• The compliance framework must run at filing. CNAD stopped accepting "will implement after registration" language. Monitoring, KYC and appointed officers all need to be live.

• Compliance officers are scarce. Every obligated subject appoints an officer and an alternate and registers both with the UIF, and candidates with crypto experience are thin on the ground in El Salvador, so recruitment belongs at the front of the project.

• CNAD can raise the capital requirement. The $2,000 floor is statutory, not final. Volume and the nature of your operations can push it up.

• CNAD sets its own tariffs, and annual costs are staff-heavy. The Commission fixes registration and renewal fees each fourth quarter for the following year. Running costs land between $53,000 and $110,000 a year on our estimates, and compliance staffing rather than anything CNAD charges drives that figure.

• The DASP also gives no EU passporting, so EU retail plans need a separate European authorisation.

What ongoing compliance applies after licensing?

Reporting to CNAD runs monthly and quarterly, financial statements are audited annually, and the renewal fee falls due in the first quarter of each year. Non-payment cancels the registration under LEAD, which makes the calendar entry as important as the payment.

AML duties sit on top of the reporting.

• Customer due diligence starts at $1,000.

• Enhanced due diligence applies to politically exposed persons and to customers from high-risk jurisdictions.

• Travel Rule information accompanies every transfer, with no minimum amount.

• Staff with customer or transaction exposure need annual AML training.

• A change of compliance officer or alternate goes to CNAD and is re-registered with the UIF.

Data protection adds a second supervisor. The Ley para la Protección de Datos Personales (Legislative Decree 144) was published on 15 November 2024. A personal data breach is reported within 72 hours. Recipients are the Agencia de Ciberseguridad del Estado, the Fiscalía General de la República and the affected individuals.

Cybersecurity duties for a licensee come from LEAD itself. Article 20 requires appropriate cybersecurity standards on the platform, as defined by CNAD, and the October 2024 reform tightened them.

Why work with MGL on an El Salvador DASP application?

Banking access and AML documentation sink most applications. MGL covers both. We form the entity and open the corporate account before the CNAD filing. Our AML and CFT framework runs at submission rather than after it. We introduce vetted local compliance officers and run the CNAD correspondence from pre-registration to certificate.

300+ licences obtained. We tell you before you engage where your structure will fail, and we do not take on applicants seeking licences for restricted markets.

Most clients take the middle scope, because it covers the two failure points rather than the paperwork alone. Scope and fee are quoted per applicant profile.

Written by the MGL Solutions digital asset licensing team, 300+ licences obtained across gaming and digital assets. Regulatory positions on this page are sourced to CNAD and to the text of LEAD, and none of it is legal advice on your structure. Talk to a licensing specialist.