Volume III · Bitcoin · Money Research

04 — Countries That Adopted Bitcoin, in What Form, and What Happened

Four forms of adoption

"Adoption" by a state can mean several different things: requiring or permitting Bitcoin payments, holding it as a public asset, mining it, or regulating private services built around it. A statutory legal-tender label does not by itself establish mandatory acceptance, tax-payment rights, or widespread use. El Salvador's 2021 law required acceptance; its 2025 amendment made private acceptance voluntary while retaining “curso legal” wording, which the IMF says no longer has the essential features of legal tender. The Central African Republic's separate experiment also ended, but its legal path was different. El Salvador, Decree 199; IMF Country Report 25/58, para. 27 n.18. Public holdings, mining and regulation are distinct from making Bitcoin a national unit of account.

El Salvador: payment law and amended private acceptance

What was done. El Salvador's 2021 Bitcoin Law created a legal-tender/payment experiment alongside an existing dollar accounting unit. Decree 199, adopted 29 January 2025 and effective 90 days after 30 January publication, retained “curso legal” wording but made private acceptance voluntary and removed Bitcoin tax-payment authority. The former legislative-vote count, Chivo bonus/trust costs, remittance/account percentages, Bitcoin City/bond and geothermal-mining bundle needs enacted budget, programme and measurement sources before being presented as realised policy or outcomes. Decree 199, arts. 1–8; IMF CR 25/58, para. 27 n.18.

What happened to usage. Household download, repeat-use, merchant sales, remittance and conversion measures require their original study or official series, field date and denominator; they cannot be compressed into one adoption percentage. The earlier Chivo bonus, business-use, 2021–26 purchase/remittance and “unit of account never moved” totals are withheld from this paragraph pending exact source locators and matched periods. The 2025 statute independently establishes voluntary private acceptance and removal of tax-payment authority, not a measured causal economic outcome. El Salvador, Decree 199, arts. 1–8; IMF Country Report 25/58, para. 27 n.18.

What it cost and what it earned. The state's wallet, trust, bonus and purchase costs need a reconciled fiscal account: spending, coin acquisition, market valuation and realised proceeds are different measures. The former $85 million trust draw, $75 million bonus, 0.7%-of-GDP cost, paper-gain and September 2026 coin/value figures are withheld here until exact public statements, valuation dates and ownership can be reconciled. A tracker balance is not an audited fiscal return, and an unrealised gain is not cash available to fund the budget. The programme's separate commitments on public accumulation require implementation evidence beyond Decree 199.

The IMF programme and the 2025 reform. After the IMF urged El Salvador to narrow Bitcoin's official role, the Legislative Assembly adopted Decree 199 on 29 January 2025, published on 30 January and effective 90 days after publication. It amended rather than repealed the Bitcoin Law. The revised article 1 still calls Bitcoin “curso legal” (legal tender/legal currency in the statute's wording), but explicitly makes acceptance voluntary for private persons and wholly private entities. Revised article 7 limits who may accept it; revised article 3 allows prices to be converted into Bitcoin; article 7 of the decree repeals three earlier provisions, including the authorization for tax payment in Bitcoin. State monetary obligations must be paid in the currencies in which they were contracted. Thus neither “all Bitcoin legal-tender language was repealed in January” nor “merchants still had to accept it” describes the text. The IMF's February 2025 staff report describes the reform as removing the essential features of legal tender and requiring taxes in U.S. dollars, while the domestic statute retains its label. El Salvador, Decree 199, arts. 1–8; IMF Country Report 25/58, para. 27 n.18. Programme commitments about Chivo and public holdings are separate from the text of Decree 199 and require their own implementation checks.

The economic change, and what caused it. El Salvador's Bitcoin experiment coincided with changes in security policy, tourism, fiscal policy and the wider economy. The specific growth, homicide, remittance, rating and Bitcoin-use series cited above need their own dated source observations before one can attribute an economic result to Bitcoin or rule out every contribution. “Every rating agency” is broader than the reviewed record, while a paper gain on a public asset is not evidence that it produced growth. The strongest established monetary distinction is narrower: the law tested mandatory Bitcoin acceptance alongside an existing dollar pricing unit, then moved to voluntary private acceptance in 2025. Whether payment use, inclusion or public finances improved requires independently comparable measures. Decree 199, arts. 1–8; IMF Country Report 25/58, para. 27 n.18.

Central African Republic: reported policy and legal questions

The Central African Republic's 2022–23 Bitcoin and Sango episode involved separate domestic law, currency-union authority and token-sales questions. The earlier dates, internet/income measures, Sango revenue, court outcomes, memecoin value and “no measurable effect” verdict need enacted texts, regional court/central-bank documents and fiscal or transaction observations before publication as a country outcome. It should not be treated as the same legal experiment as El Salvador or proof that every country with a currency union faces an identical rule.

The United States: a reserve with a legal-status test

Federal law enforcement has seized bitcoin in cases including Silk Road and the Bitfinex hack. The 6 March 2025 executive order capitalises the Strategic Bitcoin Reserve with bitcoin held by the Treasury that has been finally forfeited and is not needed for other statutory purposes; it also directs an inventory and establishes a separate stockpile for other forfeited digital assets. Seizure, a forfeiture claim, final forfeiture and transfer into the reserve are different events. In October 2025 the Justice Department filed a civil forfeiture complaint concerning approximately 127,271 bitcoin linked to the Prince Group case. That announcement was not a final forfeiture judgment, so those coins cannot be added to a verified reserve balance on its authority. Public wallet trackers do not supply a reconciled Treasury inventory by legal status, beneficial ownership and date; this article therefore withholds a US total instead of repeating a 328,000-coin figure. Federal purchases have not been established by the cited record, while purchase bills remain proposals. White House executive order, §§ 3–4; DOJ Prince Group announcement.

Subnational investment authority and an actual acquisition are separate from the federal executive reserve order. New Hampshire, Arizona and Texas enacted or proposed different reserve mechanisms, but the stated November 2025 Texas ETF purchase amount, price and mid-2026 custody tender still need dated comptroller purchase and procurement records before being treated as completed transactions. Federal digital-asset regulation also proceeds separately from Bitcoin ownership. For the CLARITY market-structure bill, official Senate records show that cloture was filed on 8 August 2026 on the motion to proceed to H.R. 3633. The Senate Press Gallery's 10 September schedule says that motion is due to ripen at 2:15 p.m. Eastern on 15 September. As of this review, that is a scheduled procedural step, not a recorded vote result or enactment. U.S. Senate floor activity, 8 August; U.S. Senate Daily Press, 10 September schedule.

Bhutan: state-linked mining, uncertain disposition

Bhutan's state-owned Druk Holding and Investments announced a hydropower-backed bitcoin-mining partnership in 2023. State-linked mining is documented, but a labelled wallet is not a complete audited statement of Druk's holdings. Transfers from attributed wallets may be sales, transfers to custodians, collateral movements or changes in wallet control; the cited tracking alone does not distinguish them. Nor does it establish how much mining revenue, if any, was realised and spent on wages. Reported peak and current balances differ across trackers and dates, so this article gives no September 2026 sovereign balance or realised-profit estimate. The distinction matters: producing bitcoin with public energy, holding it as a corporate asset, selling it for budget revenue and placing it in central-bank reserves are four different policies. Druk Holding and Investments mining announcement.

The rest: announcements, tests and regimes

Czech Republic. Governor Aleš Michl proposed studying Bitcoin as a possible reserve asset in January 2025. The CNB board approved a separate $1 million mixed-digital-asset test portfolio on 30 October; the bank announced its purchase on 13 November. It includes Bitcoin, a dollar stablecoin and a tokenised deposit and is outside international reserves. The CNB says it will assess the pilot over two to three years and has made no near-term decision to add digital assets to those reserves. Hypothetical 1% or 5% back-test results in its analysis are model outputs, not realised returns from this pilot. The CNB describes its own project as the first central-bank test portfolio of digital assets; a worldwide claim that no other central bank ever acquired Bitcoin requires a separate historical inventory. CNB Digital Assets Pilot, “Test portfolio”; CNB 2025 annual report, p. 131.

Pakistan. Announcements about a Bitcoin reserve, mining power and crypto-licensing should be separated from enacted statute, budget authority and actual public assets. The former council formation, 2,000-MW allocation, March/August 2026 legal status, IMF tariff decision and global adoption rank are withheld here until official cabinet, law, regulator and IMF locators are accepted. No Bitcoin reserve balance is established by an announcement.

Kazakhstan. A proposed reserve, a state fund and attributed wallets are distinct. The former fund launch/purchase and tracker balance need named state-entity filings and legal asset status; this chapter does not treat a tracker attribution as an official reserve or proof of ownership.

Brazil, Switzerland and Poland. Reserve proposals and governors' objections are different from current holdings; the bill status, exact quotations and institutional legal authority need primary legislative records and dated transcripts. Ukraine's reported “46,000 coins” concern officials' private declarations, not a verified state reserve. Ukraine NACP declarations assessment. Japan has discussed changes to crypto taxation and market access, but the former claim that a July 2026 law enacted a 20% rate from 2028 is withheld until the enacted statute, effective date and eligible transactions are identified; a private listed company's Bitcoin holding is not a Japanese reserve. Hong Kong's spot ETF regime is regulated private access, not public Bitcoin ownership. UAE sovereign-fund ETF interests, any state-company mining and official reserves need separate entity-level, dated records; the former $764 million and mining-total claims are withheld here.

Sellers and unresolved seizures. Germany's state of Saxony sold seized bitcoin in 2024; a completed sale is different from either a wallet outflow or an unsold seizure. UK prosecutors report recovery of about 61,000 bitcoin in the Jian Wen money-laundering case and ongoing High Court civil-recovery proceedings. Recovery into official custody is not a final determination that the Treasury owns those coins or holds them as a reserve. UK Crown Prosecution Service case update.

Use under sanctions is not national Bitcoin adoption. Russia's mining, exchange and foreign-trade rules, Venezuela's state-company payment practices and North Korea's alleged theft activity describe different legal and economic acts; the dates, transaction totals and attributed quotations formerly bundled here need primary law, company or law-enforcement records. The Financial Times reported on 9 September 2026 that Iranian businesses and analysts described a quiet relaxation of foreign-exchange controls, with some traders using domestic crypto exchanges, especially dollar stablecoins, for cross-border settlement. That report did not establish formal Iranian central-bank authorization of Bitcoin payments, a Bitcoin reserve or broad national adoption. Financial Times, “Iran turns to crypto to shore up economy,” 9 September 2026.

Summary table

What the record shows

The cases illustrate why legal form, actual payment use, and public-asset holdings need separate evaluation. El Salvador ended mandatory private acceptance without repealing the law's “curso legal” label; the Central African Republic removed its legal-tender provision under a different monetary-union constraint. El Salvador's adoption rates, remittance costs and economic effects need their own source and causal checks; the 2025 amendment alone establishes none of them. Holdings from seizures, mining and purchases also have different fiscal implications. El Salvador, Decree 199; IMF Country Report 25/58, para. 27 n.18.

Key takeaways

El Salvador provides a test of mandatory Bitcoin acceptance alongside an existing dollar unit of account, not of an economy fully denominated in Bitcoin. The 2025 law was amended, not repealed: private acceptance became voluntary, tax payment in Bitcoin was no longer authorized, and the domestic text retained “curso legal” wording even as the IMF described the essential features of legal tender as removed. The law was approved in January but took effect 90 days after its 30 January publication. Whether the programme's separate limits on public holdings and wallet operations were fulfilled requires evidence beyond the amended statute. Decree 199, arts. 1–8; IMF Country Report 25/58, para. 27 n.18.