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What an IMF country review does—and does not—do
In an Article IV consultation, IMF economists typically visit the country, collect and analyze data, and discuss policies with government and central-bank officials. The Fund’s 2022 Guidance Note for Surveillance Under Article IV Consultations identifies crypto assets and stablecoins as relevant where their adoption could affect monetary sovereignty, capital flows, capital-flow management measures, financial stability and integrity, or external stability.
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That is not the same as a dedicated Bitcoin audit. Whether the IMF examines a country’s crypto activity, and how closely, depends on the country’s circumstances and any applicable IMF program commitments. The cited IMF materials establish no universal audit procedure or global count of countries whose Bitcoin holdings are reviewed.
What counts as a country’s Bitcoin?
“The country’s Bitcoin” can refer to assets held by different institutions, with different legal and economic consequences. IMF staff need to identify ownership and control before a reported total can be interpreted. A central bank’s official reserve assets are not the same category as Bitcoin held by a treasury, public fund, state-owned enterprise or other government-controlled body.
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The distinction matters because IMF policy guidance says central banks should not hold unbacked crypto assets or privately issued stablecoins as official reserve assets. That reserve-policy position does not mean Bitcoin held elsewhere in the public sector is irrelevant: it can still affect public finances, liquidity needs, policy credibility or stability.
Questions about ownership and control
- Which public institution owns or controls the wallets or assets?
- Are balances held for the government, or are they customer funds held by a public wallet provider?
- Does the country’s monitoring definition include state enterprises or public funds?
- Is the Bitcoin classified as an official reserve asset, or reported separately as a public-sector holding?
For reserve classification, the IMF’s reserve guidance emphasizes factors including availability, control and use for balance-of-payments purposes. Calling Bitcoin “foreign-exchange reserves” without supporting official classification and data can therefore blur a consequential distinction.
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How the IMF assesses the reported amount
Staff need usable data, but a wallet balance is not automatically a complete or verified measure of a public sector’s economic exposure. They must understand which addresses are included, whether the government controls them, what reporting period applies, and whether apparent changes reflect transactions or transfers between wallets. Public disclosure, audited accounts, program-monitoring statements, IMF estimates and third-party wallet estimates are different kinds of evidence and should not be treated as interchangeable.
El Salvador’s 2025 IMF program documents illustrate how a country-specific monitoring perimeter can be defined. They describe public-sector Bitcoin holdings as Bitcoin in wallets owned or controlled by public-sector entities, while netting out Bitcoin deposits belonging to Chivo clients. The documents also set out a non-accumulation policy and transparency steps, including publication of Bitcoin financial statements for specified entities and reporting operations in macroeconomic and fiscal statistics. This is a program-specific definition, not a universal IMF formula.
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What risks does the IMF consider?
Fiscal exposure and falling prices
Bitcoin’s market price can change sharply, so a government’s reported dollar valuation is time-sensitive even if the number of coins is unchanged. Market and liquidity risks can affect fiscal buffers and a government’s ability to meet obligations. The IMF’s 2023 Board summing-up on crypto assets says fiscal risks, including contingent liabilities to government, should be disclosed in fiscal risk statements. The relevant question is not only whether a government holds Bitcoin, but also what public obligations, support arrangements or liquidity needs may arise if its value falls or assets cannot be readily used.
Monetary, financial and external stability
The IMF’s surveillance guidance treats crypto activity as relevant when it could weaken monetary sovereignty or the effectiveness of policy, affect capital flows, or create financial-stability, integrity or external-stability concerns. The scale and transmission channels differ by country. A review therefore considers the surrounding policies and institutions rather than treating the Bitcoin balance alone as a complete measure of risk.
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Operations and effects beyond the wallet balance
Public wallet arrangements, customer-asset segregation, payment mechanisms and support or convertibility promises can create exposures beyond the government’s own Bitcoin holdings. Mining can also matter even when the immediate question is a portfolio: electricity use, power exports and imports may affect the real economy and the external sector.
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What El Salvador and Bhutan illustrate
El Salvador: define the perimeter and track commitments
El Salvador’s 2025 IMF program materials show why the ownership definition matters: the monitored public-sector total includes Bitcoin in wallets owned or controlled by public-sector entities and excludes Chivo clients’ Bitcoin deposits. The same program materials describe a non-accumulation policy and specified transparency measures.
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At a July 24, 2025 press briefing, IMF Communications Director Julie Kozack said that “the total amount of Bitcoin held across government-owned wallets remains unchanged, and that is consistent with El Salvador’s program commitments.” She said increases in the Strategic Bitcoin Reserve Fund related to movements among government-owned wallets. That was her statement at that briefing; it should not be mistaken for an independent chain-analysis finding or generalized beyond that time and context.
Bhutan: uncertainty in holdings and mining’s footprint
The IMF’s 2026 Bhutan Article IV report describes a large state mining program and a significant Bitcoin portfolio, while noting uncertainty in public data and wallet attribution. It estimates that holdings likely exceeded 10,000 BTC in mid-2025, worth more than US$1 billion and close to 40 percent of GDP. These are IMF report estimates, not an official disclosed or corroborated total: the report says authorities had not disclosed the amount and did not confirm or deny outside estimates. It also notes uncertainty over whether an apparent decline reflected sales or movement to an unidentified wallet.
The same report connects mining to wider economic effects. It says domestic electricity use rose by over 60 percent in 2023, driven by new industrial loads from crypto mining; power exports to India fell by about one-third, and electricity imports rose during dry winter months. These are the report’s country- and period-specific figures, not universal effects of Bitcoin mining.
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When comparing claims about a government’s Bitcoin, check what the number actually measures before drawing a conclusion:
- Quantity: the number of BTC attributed to the public body.
- Valuation: the currency value at a stated date or price basis; it can change without a change in BTC quantity.
- Share of GDP: a comparison with economic output, not proof that the amount is an official reserve asset.
- Evidence type: an official disclosure, audited statement, program-monitoring figure, IMF estimate or third-party wallet estimate.
- Perimeter: which institutions and wallets count, and whether customer deposits or other third-party assets are excluded.
A figure without a date, perimeter and evidence source can conceal the difference between a verified public-sector total and an uncertain estimate. That distinction is especially important when wallet transfers may look like accumulation or sales but do not establish either on their own.
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