The Freedom Passport is usually introduced as a program established by Legislative Decree No. 918, a description close enough to be useful and loose enough to mislead. Decree 918 is a two-article amendment to an ordinary migration statute: one new numeral and a closing paragraph, and no figure at all. The $1,000,000, the 1,000 approvals a year, the six-to-eight-week window: none of them appear in any statute. The first two live a level below it, in administrative program terms the executive can change without the Assembly, and the third is ours, an operational estimate rather than a published term. That is what a seven-figure file rests on, and this entry separates what you can read for yourself from what is ours.
What Decree 918 actually says.
Decreto Legislativo No. 918 was issued 20 December 2023, published in Diario Oficial No. 5 of 9 January 2024, in force 17 January 2024. It amends Article 156 of the parent law. Its operative content is a new numeral 5 plus a closing paragraph directing the DGME, the migration authority, to build a secure and expedited procedure. Numeral 5 admits foreigners who meet the requirements of government programs to attract investors or donors, “mediante inyección de capital en moneda de curso legal o mediante proyectos de inversión sostenible.” The chapeau above it, silently corrected by the reform from salvadoreños to salvadoreña, reads “podrán solicitar”: a right to apply, not an entitlement. The decree is on asamblea.gob.sv.
What it does not contain matters more. No monetary amount, no annual cap, no processing-time guarantee, no currency requirement beyond the neutral formula above. “Bitcoin” appears five times, all in the recitals; the enacted articles never mention it. Recital V names the motive, altruistic foreigners supporting development “mediante la donación de Bitcoin”, and Recital I grounds the scheme in Article 92 of the Constitution. A migration amendment with a Bitcoin motive in its preamble, not a Bitcoin statute.
Two Decree 286s, and only one of them is yours.
The industry cites “Decrees 918 and 286” as a unit. The pairing is right, the dating usually wrong, ours included: there are two Decree 286s. D.L. No. 286 of 2 April 2019 is the parent Ley Especial de Migración y Extranjería. The investor residency route is D.L. No. 286 of 30 April 2025, whose Article 2 rewrites Article 152 numeral 13 to grant definitive residence without prior temporary residency, and whose Article 4 prices it at US$690.00. So 918 is the naturalization route, 286 of 2025 the residency route, and that fee is the only monetary figure in the operative text of Decrees 918, 286 of 2025, and 531 themselves. The statute they amend prices more: its Article 325 sets the grant of nationality by naturalization at US$700.00, ordinary first definitive residency at US$345.00, and the Article 94 absence permit at US$100.00.
Two digital-asset statutes, and one label of our own.
The Ley de Emisión de Activos Digitales, D.L. No. 643, was approved 11 January 2023 and took force eight days after publication in Diario Oficial No. 16 of 24 January 2023. In the published 2023 text, Article 2 confines its scope to public offerings and their participants; Article 6 creates the CNAD, the digital-asset commission. Article 19 lists what a registered service provider may do, from exchange and platform operation to placement, promotion, and third-party custody; D.L. No. 781 of 17 July 2023 added certifications of digital assets and smart contracts. Private self-custody is nowhere on that list, though third-party custody is. The LEAD licenses digital-asset businesses. It is not the citizenship decree.
Beside it runs the Ley Bitcoin, D.L. No. 57 of 2021, amended by D.L. No. 199, in force 30 April 2025. Decree 199 reformed six of its articles and repealed three: Article 7 turned mandatory acceptance by every economic agent into permissive acceptance between private parties, and repealing articles 4, 8, and 9 ended tax payment in Bitcoin and the State's convertibility and wallet obligations. Article 5 survives, rewritten only to drop a trailing comparative clause, so exchanges in Bitcoin remain outside capital-gains tax. Now our own copy. We call Decree 199 the repeal of Bitcoin's legal-tender status effective 30 April 2025. That is a characterization, not a quotation: the reformed article still carries the older language, and the position rests on the machinery being gone.
A decree you can open says what it says. A paragraph telling you what that decree means for you is a reading, and at a million dollars the distance between the two is where all the risk sits.
The Four Zeros, and where each one actually comes from.
We sell a tax structure we call the Four Zeros: capital gains on Bitcoin, tax on foreign-source income, estate and wealth taxes, and VAT on Bitcoin. Each leg has a different statutory home, and none is the citizenship decree. Zero capital gains comes from Ley Bitcoin Article 5. Zero tax on foreign-source income comes from the territoriality of the income-tax law, which D.L. No. 969, in force 22 March 2024, reinforced by adding numeral 4 to Article 3 and repealing worldwide-reach provisions. Zero wealth tax comes from the repeal of the patrimony tax by D.L. No. 871 of 27 April 1994, the gift tax from D.L. No. 644 of 8 September 1993. The inheritance tax went the same year, the one repeal here we could not open in a primary text; we flag it rather than dress it.
The fourth leg needs its scope stated, and the correction is ours. No article in the LEAD, the Ley Bitcoin, or the VAT law exempts Bitcoin transactions from VAT. LEAD Article 36 grants its benefits to a defined perimeter: the chapeau reaches acquirers as well as registered issuers, certifiers, and service providers; literal b) is unconditioned; literal c) ties VAT relief to registration; literal e) disapplies the benefits for digital assets swapped for goods or services outside the Article 19 list. Article 36 was itself amended by the reform of 3 October 2024, which extended the benefits to private offerings; the CNAD still publishes only the unamended 2023 text, so the wording in force cannot be verified. Article 54 of the VAT law sets 13% as the general rule. Read as a blanket exemption on spending coins, the fourth zero is our shorthand, and wider than the text.
One reading cuts against our marketing. Salvadoran tax domicile turns on residing more than 200 consecutive days in a calendar year under Article 53 of the Código Tributario. Nationality alone does not create it for a private individual, though the same article domiciles officials posted abroad and anyone whose principal seat of business is in El Salvador. For a citizen who never becomes domiciled, territoriality already places foreign-source gains outside Salvadoran reach, so the exemptions we advertise buy that person nothing they did not already have. They bite for the person who does move. If you are not moving, the tax case is not the reason to do this.
Provenance, claim by claim.
Four claims circulate about the program, we have made all four, and each needs its provenance stated. First, the name, and it is the state's own twice over. At launch it was the Adopting El Salvador Freedom Visa Program: the 8 to 9 December 2023 captures of adoptingelsalvador.gob.sv say “Freedom Visa” forty-four times and “Freedom Passport” not once. By the captures of 17 to 18 December the same site was rendering it Adopting El Salvador Freedom Passport, and its navigation still reads Freedom Passport today. The official name moved inside eleven days, so whichever term you searched, the state has used it. Second, the administrator, where the compression is ours. The Bitcoin Office issues agent credentials and the DGME runs the file, but under Article 157 the file belongs to the Minister of Justice and Public Security, who may delegate everything except the grant-or-deny resolution and the swearing-in, acts reserved to the Minister or Viceminister. “Administered by The Bitcoin Office” compresses a chain of authority that ends elsewhere.
Third, our own credential from The Bitcoin Office, and the reading of it is ours. It is administrative and contractual: no decree or published regulation we could locate creates, licenses, or supervises it. It is not a financial-services license, it confers no power to approve anyone, and no public register of agents exists to check it against. What can be verified we collect at the Official Source Library. Fourth, the numbers: the $1,000,000 contribution, the $999 non-refundable deposit credited toward it, and the 1,000-approvals-a-year cap are official program terms from the government's December 2023 site copy, administrative, not statutory. Our $999-per-additional-applicant figure, and our six-to-eight-week processing and two-to-three-week due-diligence windows, are our operational description.
What the framework does to a holder, not to a brochure.
The decree that most affects a holder is the newest: D.L. No. 531, approved 17 March 2026, in force 31 March 2026. Its Article 2 substitutes Article 119 to require ninety calendar days of presence per year for temporary residents, consecutive or accumulated, and its Article 1 substitutes Article 49 numeral 5 to match. That liberalizes the prior regime, which capped absence at six consecutive or six accumulated months under the old Article 119 and at three consecutive or four accumulated months under the old numeral 5. The nine-months figure in circulation appears nowhere in the statute; it comes from a DGME official's paraphrase in the Assembly's press release of 16 March 2026. The rule does not reach naturalized citizens. Article 4 substitutes Article 279, the grounds for losing naturalized nationality: more than two consecutive years in the country of origin, or more than five years' absence without a permit, itself capped at seven years; or a final judgment for serious intentional crimes, the one ground on which the loss cannot be reversed. The same article directs the DGME to establish the procedure for declaring that loss.
Two details deserve care. The pre-2026 Article 279 carried a statelessness safeguard and a six-step due-process procedure; the substituted article carries neither on its face, and the DGME procedure it delegates is unpublished. We assert neither that the safeguard was removed deliberately nor that it survives. Separately, Article 159 numeral 7 requires a certification from your own country's embassy or consulate that it permits dual nationality; whether the expedited procedure waives that is unknown. Underneath sits a constitutional asymmetry: Article 91's unconditional dual-nationality right belongs to Salvadorans by birth, and a naturalized citizen lives under Articles 93 and 94 instead.
The two questions nobody has answered.
An honest map marks its blank spaces; there are two. The first is constitutional fit. Article 92 enumerates the grounds for naturalization, and every civilian ground requires prior residence in El Salvador. The investment route lives in an ordinary statute instead, and no constitutional-chamber ruling or published analysis testing that fit was located. The second is narrower. Numeral 5 keys eligibility to capital injected in the statute's currency formula, and Decree 199 left the State under no obligation to receive Bitcoin, so whether a donation still satisfies that limb is arguable. The other limb, sustainable investment projects, is untouched, and no official interpretation exists. Anyone who resolves either question in a confident sentence is characterizing, not citing.
The honest trade-offs.
The Salvadoran passport reaches 132 destinations at rank 36 on the Henley index, a figure that moves with each release. It covers the full Schengen Area but not the United States, which requires a visitor visa: no Visa Waiver Program, no ESTA. Nor the United Kingdom, where El Salvador's place on the visa national list rules out an Electronic Travel Authorisation and requires a Standard Visitor visa in advance. The contribution is non-refundable once a file is in motion, and approval is never guaranteed. For US persons, FATCA and worldwide income reporting apply regardless of a second citizenship, and El Salvador's absence from automatic exchange is not an absence from exchange on request. And the trade-off this article exists to state: you are buying a discretionary executive program resting on a two-article statutory hook, and Decree 199 is on the record that such a framework can move.
One date makes the point better than the argument. The program launched 7 December 2023, and the Assembly approved Decree 918 thirteen days later. At launch the government's own program site did not cite Decree 918, unsurprisingly, since the decree did not yet exist. Its terms and conditions did cite legal authority: the Constitution, the Law on Honorary Distinctions, Gratuities and Titles, the Law Against Money and Asset Laundering with its UIF and FGR Instructions of 27 October 2021, and Article 16(4) of the Law of Administrative Procedures. None of it established the program's own naturalization authority. The administration came first, and the statute caught up.
Alignment, not access.
A buyer at $1,000,000 is buying alignment with a state's direction of travel, which is why the floor under that program is worth knowing to the article number. The price is the filter, and it works best when the person crossing it has already read the decree. Our advisory is a flat 5%, which is $50,000, putting the all-in for a single applicant at $1,050,000. The first step is a paid strategy session, one hour with Adam: $4,750 in Bitcoin, Lightning, or USDT via BitSettle, or $5,000 by card via Stripe, credited in full toward the 5% advisory if you proceed within 90 days. Our broader work sits at 21 CBI.
This is legal information drawn from published decrees and program materials, not legal or tax advice. Statutes and program terms change, and the two questions above are unresolved as of publication. Confirm specifics with qualified Salvadoran counsel before acting.
Adam Juchniewicz, CEO, 21 CBI
The Ledger · July 2026