Regulatory and compliance support for businesses seeking registration with the National Commission of Digital Assets (CNAD) to provide digital-asset services in or into El Salvador.
The regulatory route is defined by the activities performed and how the business targets the Salvadoran market. Support covers pre-registration, applicant structuring, AML/CFT, governance, registration documentation and operational readiness; issuance, stablecoin and Bitcoin-payment requirements are assessed separately where applicable.
The CNAD route has two distinct stages: pre-registration to confirm the proposed activity falls within the Commission’s remit, followed by definitive registration with the full PSAD documentation set. The statutory review period and official fee apply at the formal-registration stage, not to the entire project timeline.
The applicant submits information on the business and the area in which it intends to operate. CNAD may request additional information and then issues an objection or no-objection position on whether the proposed activity can proceed into the definitive registration process.
After the pre-registration stage, the applicant submits the documentation required under Article 20 of the Digital Asset Issuance Law and the relevant PSAD Regulation provisions, including the applicant, governance, compliance and operating information required for the selected activities.
CNAD currently states a maximum period of 20 business days to evaluate the definitive registration file and issue a favourable or unfavourable resolution. If the application is incomplete, CNAD may require the missing information to be completed within 10 business days.
Following a favourable resolution, the current initial registration fee is USD 5,475 and is payable within 10 days of notification. CNAD then issues the registration certificate and authorisation to operate as a Digital Asset Service Provider.
CNAD’s current definition is unusually important for structuring: a PSAD can be domiciled in El Salvador or can be non-domiciled while actively marketing or promoting digital-asset services to potential clients in the country.
CNAD describes a PSAD as a natural or legal person that provides covered digital-asset services and is either domiciled in El Salvador or, if not domiciled, actively promotes or markets those services to potential clients in the country.
El Salvador’s Commercial Registry states that one or more Salvadoran or foreign persons may form a commercial company. Foreign individuals and legal entities require a Salvadoran tax identification number for the incorporation process.
The reviewed PSAD materials do not identify a blanket Salvadoran-nationality requirement for all management. Foreign directors and managers may therefore be possible, subject to CNAD due diligence and applicable immigration and labour rules; El Salvador’s investment guidance also treats a limited number of foreign directors/managers separately from the general foreign-worker quota.
A locally domiciled applicant needs the corporate and operating presence required for its Salvadoran structure. A non-domiciled PSAD should not be presented as if a Salvadoran office were automatically mandatory, but its CNAD registration, contacts, compliance arrangements and local-service model still require project-specific confirmation.
CNAD’s current public registration page does not publish one universal minimum-capital number for every PSAD. After the pre-registration “no objection”, CNAD specifies the requirements for the area in which the applicant intends to operate.
Financial-resource and capital requirements should be confirmed against the LEAD, the PSAD regulations and the requirements CNAD identifies for the selected activity. A generic USD 2,000 “PSAD capital” should not be presented as a regulatory floor.
CNAD states that, following a favourable registration decision, the initial registration fee is payable within 10 days of notification.
CNAD expressly covers both a person domiciled in El Salvador and a non-domiciled provider that actively promotes or markets covered services to potential clients in the country.
Support can begin with regulatory perimeter and readiness analysis, continue through preparation of the CNAD registration file, and extend to implementation of the governance, AML/CFT and operating arrangements required for launch. Additional regulatory workstreams are scoped only where the proposed activity requires them.
Focused assessment before material spend on incorporation, staffing or application preparation.
Preparation and coordination of the core CNAD registration file together with the AML/CFT, governance and operating documentation required for the agreed service model.
Extended support for applicants that require implementation of local functions, providers and launch-readiness controls in addition to the registration file.
Separate analysis for Bitcoin-payment services, digital-asset issuance, stablecoin activity or other regulatory overlays that sit outside the core PSAD registration scope.
The PSAD framework covers a broad range of digital-asset services. The registration strategy should therefore start with the activities actually performed, while Bitcoin-payment, issuance and other overlays are separated where they require an additional regulatory workstream.
The actual exchange, custody, transfer, platform and order-flow functions are mapped to the current CNAD service-provider regime.
Risk assessment, KYC/CDD, sanctions, monitoring, safeguarding and governance are built as part of the registration file.
Corporate, compliance, accounting and local professional workstreams are coordinated with Salvadoran providers where needed.
Government fees, tax advice, bank accounts, local staff and third-party costs are separated from the LEX ARTA professional fee unless expressly included.
Identify PSAD/DASP services, Bitcoin functions and any issuance/token overlap.
Review entity, ownership, local functions, compliance and financial readiness.
Build pre-registration, application, AML/CFT and governance documentation.
Align compliance roles, providers, accounting and implementation evidence.
Support CNAD queries, launch dependencies and ongoing compliance.
Published starting prices are LEX ARTA professional fees. The current CNAD initial registration fee of USD 5,475, together with company formation, local professional fees, compliance appointments, office, accounting, technology, banking and other third-party costs, is separate unless expressly included in the engagement proposal.
It is a digital-asset service provider under the CNAD-administered regime. CNAD’s public register shows activities including exchange, platforms, transfer, custody and order-related services.
CNAD currently states a maximum 20-business-day evaluation period for a complete application, with a cure period where information is missing. Total project time is longer because preparation and local implementation come first.
CNAD currently states an initial registration fee of USD 5,475 after a favourable resolution. Official fees can change and should be rechecked at filing.
Not as a standard package on this page. Bitcoin-specific payment/service requirements are scoped separately and confirmed with Salvadoran counsel and current regulator practice before quoting.
No. CNAD refers to fiscal benefits under Article 36 for qualifying registered providers, but the actual tax treatment depends on the activities and structure and should be confirmed by a Salvadoran tax adviser.
Start with PSAD/DASP activity mapping and confirm any Bitcoin-specific overlap before committing to the application package.
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