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The IMF does not use one universal Bitcoin audit checklist for every country. It considers Bitcoin as part of its broader review of a member’s economic and financial policies, asking who owns or controls the assets, how reliably they are measured, and whether they create fiscal, monetary, financial or external risks. The depth and scope of that review depend on the country and, where applicable, its IMF program commitments.
What an IMF country review does
In bilateral surveillance, commonly conducted through Article IV consultations, IMF staff assess a member’s economic and financial policies. The Fund says economists typically visit the country, collect and analyze data, and discuss policy with government and central-bank officials. Crypto assets become relevant when their use or public-sector exposure could affect matters such as monetary sovereignty, capital flows, financial stability, financial integrity or external stability.
That does not mean every consultation includes a dedicated Bitcoin audit. The IMF’s 2022 Guidance Note for Surveillance Under Article IV Consultations treats crypto-related issues as country-specific surveillance concerns, not as a standard audit procedure applied identically to all members.
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What counts as a country’s Bitcoin?
“A country’s Bitcoin” can refer to assets held by different public bodies, with different implications. IMF analysis distinguishes official reserve assets held by a central bank from Bitcoin owned or controlled elsewhere in the public sector, such as by a treasury, public fund or state-owned enterprise.
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The IMF’s 2023 Elements of Effective Policies for Crypto Assets says central banks should not hold unbacked crypto assets or privately issued stablecoins as official reserve assets. That reserve-policy guidance does not make other public-sector holdings irrelevant: they may still expose public finances or the wider economy to risk.
Reserve classification also depends on more than an asset’s label. The IMF’s reserve guidance emphasizes factors including availability, control and use for balance-of-payments purposes. Bitcoin should not be described as foreign-exchange reserves unless the official reserve definition and data support that description.
The ownership perimeter matters
To interpret a reported total, staff need to know which institutions and wallets are included, who controls them, and whether customer assets are counted. A country-specific monitoring definition may exclude customer deposits held by a public wallet provider, for example, rather than treating all Bitcoin in wallets associated with a government service as government-owned.
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The questions staff need to answer
Who owns or controls the assets?
Staff distinguish central-bank reserves from holdings controlled by other public-sector entities. The relevant perimeter may include a treasury, public fund, state enterprise or government-controlled wallet. In El Salvador’s 2025 IMF program documents, the defined public-sector total covers Bitcoin in wallets owned or controlled by specified public-sector entities, net of Bitcoin deposits belonging to Chivo customers.
How large is the exposure, and how dependable is the figure?
A Bitcoin quantity, its market value on a particular date and its share of GDP are different measures. Staff need reporting that makes those distinctions clear. Wallet movements can also make the public record hard to interpret: a balance leaving one known address may reflect a transfer to another address rather than a sale, but the destination may not be identifiable from available information.
What could a price change mean for public finances?
Bitcoin’s price volatility can affect the value and liquidity of public holdings. IMF crypto-risk analysis also considers potential effects on fiscal buffers and government obligations. In its 2023 Board summing-up on crypto assets, IMF Directors said fiscal risks, including contingent liabilities to government, should be disclosed in fiscal risk statements.
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The question is not only whether a government has recorded a gain or loss. Staff may also consider whether a fall in value could affect available public resources, create a need for liquidity, or interact with promises or obligations that expose the government to additional costs.
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The IMF’s surveillance guidance flags possible effects on monetary sovereignty, capital flows, financial stability and integrity, and external stability. The relevance of each channel depends on how Bitcoin is used in that country and how large its role is in relation to the economy and public institutions. The policy against treating unbacked crypto assets as central-bank reserves is one part of this broader assessment, not a substitute for examining other exposures.
Are there operational or wider economic effects?
Public exposure can arise not only from holding Bitcoin, but also from related arrangements such as public wallets, mining programs, payment systems or government support and convertibility promises. Those activities can create operational risks or spillovers beyond the value of the coins themselves. Bhutan’s 2026 IMF report, for example, discusses mining-related electricity demand and effects on power trade as well as the country’s Bitcoin portfolio.
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What the country examples show
El Salvador and Bhutan illustrate different evidence and monitoring problems. They are country-specific examples, not proof that the IMF uses one identical method everywhere.
| Country and source | What the IMF material establishes | How to interpret the evidence |
|---|---|---|
| El Salvador — 2025 IMF program documents | A public-sector monitoring definition includes Bitcoin in wallets owned or controlled by specified public-sector entities, net of Chivo customers’ Bitcoin deposits. 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. | The perimeter and exclusions are essential to interpreting a total. Program monitoring commitments are country-specific; they are not a universal IMF Bitcoin reporting template. |
| El Salvador — IMF Communications Director Julie Kozack’s July 24, 2025 press briefing | Kozack said the total Bitcoin held across government-owned wallets remained unchanged and was consistent with the program commitments. She said increases in the Strategic Bitcoin Reserve Fund related to movements among government-owned wallets. | This was the spokesperson’s statement at that briefing, not an independent chain-analysis finding. An increase in a named fund alone does not establish that the public sector accumulated Bitcoin overall. |
| Bhutan — IMF Article IV report published as Country Report 2026/019 | The IMF report estimated that holdings likely exceeded 10,000 BTC in mid-2025, worth more than US$1 billion and close to 40 percent of GDP. It also said the authorities had not disclosed the amount and had neither confirmed nor denied outside estimates. The report describes uncertainty over whether an apparent decline reflected sales or movement to an unidentified wallet. | These are IMF report estimates, not an official disclosure or confirmed holding. The quantity, dollar valuation and GDP share refer to the report’s mid-2025 estimate and carry the stated uncertainty. |
| Bhutan — IMF Article IV report published as Country Report 2026/019 | The report 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 report-specific descriptions of 2023 changes. They show why mining’s energy and external-sector effects can matter alongside the Bitcoin balance. |
How to read a reported Bitcoin total
Before comparing figures or treating a headline number as a government balance, check what kind of evidence it represents. The distinctions below affect what the number can support.
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- Program-monitoring figure: A value defined for the purpose of a country’s IMF commitments. Check which public entities and wallets count, and whether customer funds are excluded.
- IMF estimate: An estimate in an IMF report, with the report’s date, methodology and uncertainty attached. Bhutan’s mid-2025 holdings figures are in this category.
- Third-party wallet estimate: An estimate based on wallet attribution rather than an official public-sector disclosure. Treat it as distinct from a government-confirmed balance, especially when transfers to unidentified wallets are possible.
For any figure, keep the Bitcoin quantity separate from its market valuation and its share of GDP. A valuation is tied to a point in time and can change with the market; it is not a permanent measure of the public sector’s exposure.
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Why this is not simply a Bitcoin audit
The IMF’s work is a review of economic and financial policies, not a promise to independently verify every government wallet. The material available for any country may support a defined program-monitoring total, an official disclosure, an IMF estimate or only a partial picture. What the Fund can assess depends on the country’s institutions, the quality of its reporting and the commitments in place.
The IMF’s 2023 Working Paper Assessing Macrofinancial Risks from Crypto Assets and its policy guidance help frame the risks to consider. They do not establish a global count of countries with Bitcoin holdings under review or a standard Bitcoin audit checklist. The practical focus is on whether public exposure is sufficiently understood and reported to evaluate its consequences for the country’s policies and stability.
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