A citizenship program that has been open for a while eventually earns a different question than the one it started with. At launch, the question is whether the thing is real: does the government actually take Bitcoin, is the license genuine, does a passport actually arrive at the end of the file. In the months since the licensed-agent credential took effect on 27 February 2026, that question changes shape. It becomes whether anything has quietly moved since the first pitch was made, whether the figure on the page still matches the figure in the file, and whether a firm that sells trust for a living is still checking its own homework in public. This entry is that check, dated and specific, not reassuring in the abstract.
Why We Publish the Math, published on 29 May 2026 on this Ledger, made the case for why any of this gets posted at all: figures dated, sourced, and restated rather than left to calcify into a claim nobody refreshes. This entry does not repeat that argument; it applies it, as the second installment of what is meant to become a recurring practice, a periodic status update rather than an inaugural announcement, on what has held and what has actually moved since the program opened for business.
What has not moved: the structure the program was built on.
Start with the arithmetic: it is the easiest thing to check, and the thing most likely to drift first if a firm were going to let a number slip. It has not. The government contribution is still a flat $1,000,000 in BTC or USDT regardless of family size, plus $999 for each additional applicant, non-refundable once a file is in motion. The 21 CBI advisory fee is still a flat 5 percent, which is $50,000 on the contribution alone, for an all-in figure of $1,050,000 for a single applicant. The contribution still settles only in BTC or USDT, on-chain, direct to the government's own wallet, and the firm still does not custody it at any point in between. None of that has changed because none of it needed to. The structure was built to be legible from day one, and legible things do not need periodic correction. They need periodic confirmation, which is what this is.
The licensed-agent model is also unchanged, and it is worth stating plainly rather than assuming a reader already knows it. Bitcitizen LLC, operating as 21 CBI, holds its credential as Licensed Agent of The Bitcoin Office of El Salvador, under Director Stacy Herbert, valid from 27 February 2026 to 26 February 2027; that document, and the mechanics of checking any agent's standing rather than taking a claim on faith, sit on the page that explains how to verify a licensed agent. Licensing authorizes submission and processing; it does not constitute pre-approval of any applicant by the Government of El Salvador, and that has not changed either. Herbert remains Director of the Bitcoin Office, active in public view through mid-2026, with no reported departure or restructuring of the office's mandate. Several other licensed agents continue to operate alongside 21 CBI, worth noting since a closed or single-agent model would look different from this. The statutory basis has not moved either. Legislative Decrees No. 918 and No. 286, the founding decrees behind the naturalization pathway launched on 7 December 2023, remain in force, unamended and unrepealed, and they are still the citation this firm stands on whenever the Freedom Passport page makes a legal claim.
What has not moved: the privacy posture and the tax architecture, with one earlier exception.
El Salvador's Non-CRS standing is also exactly where it was. The country still does not appear among the jurisdictions committed to the OECD's Common Reporting Standard, and it is not on the list of jurisdictions that have committed to the newer Crypto-Asset Reporting Framework either, the standard a subset of CRS participants are scheduled to begin exchanging under starting in 2027 and 2028. That exchange timeline applies only to jurisdictions that have already committed to it; it says nothing about El Salvador joining, and nothing found this cycle suggests it will. The full mechanics of that posture sit on the Non-CRS privacy page, though FATCA and worldwide-income reporting still apply to US persons regardless of a second citizenship, and that caveat has not moved either.
The Four Zeros tax structure for foreign investors is unchanged: 0 percent capital gains on Bitcoin, 0 percent income tax on Bitcoin for non-residents, 0 percent inheritance and wealth tax, and 0 percent VAT on Bitcoin itself, with the standard 13 percent VAT still applying to everything else, all detailed on the tax page. One exception sits a layer down, predating this update's window rather than falling inside it: the LEAD digital-asset framework beneath the Four Zeros, supervised by the CNAD since January 2023, was reformed in 2024 to give the CNAD sole regulatory authority over the digital-asset industry. Nothing has moved it further since, as far as the public record shows, though the CNAD's own published materials still cite the 2023-dated base documents, a minor documentation lag rather than a further legal change.
A dated figure that has not moved is not a wasted line item. It is the proof that publishing dates and sources was never a marketing device to begin with.
What actually moved: the reserve, checked again today.
Two figures on this site are built to move, and they are labeled that way on purpose: the sovereign Bitcoin reserve and the mobility count. The Verified Facts Library has carried the reserve at approximately 7,684 BTC, stamped as of June 2026 and verifiable on-chain at bitcoin.gob.sv, among the primary sources collected on the Official Source Library. Checked again directly against that same on-chain source on the day this piece publishes, the reserve now reads 7,711.37 BTC, worth roughly $481.9 million at the time of the check; an independent aggregator landed within a few coins of the same figure on the same day. The gap between the two numbers, roughly 27 BTC over the intervening weeks, is consistent with the pace this site has always described: the treasury's own transaction log shows discrete purchases of roughly one Bitcoin at a time, about once a day. Nothing about that growth is a policy change. It is the same accumulation this program has pointed to since the beginning, simply confirmed again rather than left to sit as a June figure quietly going stale.
What did not move, even though we checked assuming it might: mobility.
The mobility figure checked out the same way the reserve's growth did: confirmed, not manufactured into a story. The Verified Facts Library states 132 destinations at Henley Passport Index rank 36, as of June 2026. Read directly from the live Henley ranking table on the day this piece publishes, El Salvador's row still reads 132 destinations, still rank 36th: unchanged. Some secondary, aggregator-sourced pages report a different, lower count, but that figure traces back to a Wikipedia-sourced page this firm has already caught being wrong about El Salvador's Henley standing once before, so it is not treated as more current than a direct read of Henley's own table. The honest report here is simply: no change. For readers weighing Bitcoin-oriented citizenship options more broadly, the sibling Bitcoin Passport Index applies the same verify-first standard across the wider field. The United States and the United Kingdom remain outside El Salvador's visa-free list either way, the trade-off this program has stated since launch and states again now, since a mobility figure only mentioned when it looks good is not a dated figure at all.
A statute moved nearby. Not the one this program stands on.
One adjacent legal change surfaced in the research behind this update, and it deserves a careful, hedged mention rather than either silence or overstatement: in March 2026, according to two independent legal-firm summaries whose underlying decree text this firm could not independently retrieve this cycle, the Legislative Assembly reformed several articles of the same Special Law on Migration and Foreigners that houses the Freedom Passport's naturalization provisions. The reform itself targeted different articles: residency day-counts for temporary residents, a path for parents to seek retroactive nationality recognition for children born abroad, and, notably, a newly codified set of grounds for loss of naturalized nationality, tied to prolonged residence back in a person's country of origin, prolonged absence from El Salvador, or a final conviction for a serious intentional crime.
Neither summary names Decree 918, Decree 286, or the Freedom Passport program, and nothing found here indicates the investment-naturalization pathway itself was touched; the two summaries agree with each other, but neither stands in for the government's own gazette. This firm has noted elsewhere that the constitutional dual-nationality guarantee in Article 91 applies to citizens by birth, not to naturalized Freedom Passport holders, who fall under the separate Articles 93 and 94 instead. A newly codified revocation framework sitting in the same statute is exactly the kind of adjacent development worth a qualified attorney's direct read of the decree text.
The two structures that are still just an announcement.
Two more items get asked about often enough to warrant a direct answer, and the answer has not changed. The Volcano Bond does not appear in the CNAD's public issuance registry, and a government recap of its digital-asset issuances through early 2026 does not include it either; it remains approved in principle and never actually issued, whatever a handful of unsourced articles online claim. Bitcoin City, the mining city proposed for the Conchagua site, remains conceptual as well; the local mayor's office continues to report no construction on the ground, even as separate infrastructure, the Pacific Airport and a port-modernization deal at La Unión and Acajutla, advances nearby. We describe both the same way we described them before: announced, not realized. Press coverage of El Salvador's Bitcoin policy often conflates the two; this program's own claims do not get to.
What we would tell you if the mechanics had moved. They have not.
The process itself is unchanged, start to finish. The first call is still a paid strategy session, $4,750 in Bitcoin, Lightning, or USDT, or $5,000 by card, one hour directly with Adam Juchniewicz, CEO of 21 CBI, credited in full toward 21 CBI advisory services if retained within 90 days. It is not the program contribution. That $250 gap between the Bitcoin-native rails and the card price is not new; it is the same alignment logic that governs the seven-figure contribution, scaled down to a single phone call. Processing still runs six to eight weeks, fully remote, with due diligence of two to three weeks run jointly by the Bitcoin Office and the DGME (Dirección General de Migración y Extranjería, El Salvador's immigration authority). The program remains capped at 1,000 approvals a year, first-cleared-first-issued. The passport is still valid for six years and renewable, while the citizenship itself remains permanent and hereditary, and one in-country visit every five years still maintains the genuine link. The process page and the Freedom Passport page carry the full detail; nothing in either has needed a correction this cycle, which is itself the report.
The actual decision this piece asks you to make.
This entry does not ask you to decide anything you had not already been asked to decide. It asks you to make that decision on this month's numbers rather than launch-day numbers: a reserve that keeps growing at roughly the pace it always has, a mobility figure that checked out unchanged today, a fee structure and a licensed-agent credential that have not moved, and one adjacent statutory reform worth a lawyer's direct look before anyone assumes it does or does not apply to a naturalized citizen's file. If you have not run the three questions that decide fit, that page is still the fastest honest answer to whether this is worth your time at all. If you have, and the file is ready, the paid strategy session is still where the specifics of your own situation get checked against the current record rather than the record as it stood in December 2023, whether you arrived here directly or through 21 CBI's broader advisory work at 21cbi.io. Book the session when you are ready for that conversation, not before.
This is not tax or legal advice. Program terms, statutory interpretation, and tax treatment are specific to your citizenship, residency, and financial situation, including how a reform like the one described above might eventually be read against a naturalized citizen's file. Confirm your specific position with a qualified advisor before treating anything above as a final answer.
Adam Juchniewicz, CEO, 21 CBI
July 2026