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MIRR ASIA · El Salvador DASP (PSAD) License
El Salvador DASP License Guide
A practical guide to the key requirements and procedures for El Salvador Digital Asset Service Providers (PSAD/DASP)
Overview · 01
Overview (Official Terminology)
PSAD (Proveedor de Servicios de Activos Digitales) is the official legal term used in the Spanish text of El Salvador's LEAD (Digital Assets Issuance Law). In English materials, the same concept is referred to as DASP (Digital Assets Service Provider), which is the official English rendering used by the supervisory authority CNAD.
Registration applies to (1) entities with a domicile (legal address/registered seat) in El Salvador, or (2) entities without a domicile that nevertheless actively promote or market their services to potential clients in the Republic of El Salvador. Upon approval, the registration number is published in CNAD's public registry.
Statutory processing time
Decision notice within 20 business days from a complete filing (if deficiencies are notified, corrections must be submitted within the specified period).
Frequently Asked Questions
Scope · 02
Statutory Service Scope (LEAD Art. 19 Summary & Commentary)
- ExchangeExchange between digital assets and fiat/other digital assets (own or on behalf of third parties).
- Trading platform operationOperation of spot/derivatives markets and listing operations.
- Issuance-relatedRisk and price assessment, underwriting/placement.
- Wallet/distributionWallet provision and token placement/distribution.
- Investment productsStructuring, promotion, and management.
- Brokerage/custodyTransfers, custody, order reception/execution.
Core operating duties (summary)
- Clear disclosures of price/fees/risks and maintenance of a complaints channel.
- Market integrity (no manipulation such as spoofing/false signals) and insider-trading prevention.
- Confirm applicability and scope of any tax incentives (e.g., exemptions).
Company · 03
Incorporation Application & Maintenance Requirements (Local Company or Branch)
Form & registrations
- Form: Foreign entities typically either incorporate an S.A. (Sociedad Anónima) or establish a branch (Sucursal), then complete commercial registration and tax registration.
- Share capital: Set a minimum capital of US$2,000 with full paid-in funding (to reduce balance-management issues and banking due diligence risk).
- NIT (Tax ID): Issued for both legal entities and individuals via the Ministry of Finance process.
- Secure a legal address (Domicilio) (lease/registered office address, etc.).
Personnel, office, governance
- Local officers/staff: No explicit statutory minimum or nationality requirement. However, you must maintain adequate resources proportionate to the business size and risk.
- Office: No minimum floor-area rule, but you must maintain a domestic legal address and client support channels (phone/email, etc.).
- Governance: Board rules, authority matrix (approval map), conflict-of-interest policy and code of ethics, and documented internal controls.
- Accounting & records: Maintain books and supporting evidence in line with local accounting standards (NIIF/IFRS accepted).
Terminology
- Notario = notary attorney. Notarial acts are performed by a Notario Autorizado.
- Apostille = Hague Apostille authentication for foreign-issued documents.
- Traducción jurada = certified (sworn) translation into Spanish for court/administrative filings.
License · 04
License (PSAD/DASP) Application & Ongoing Obligations
Application requirements (key documents/content)
- Evidence of service capability (organization, personnel, systems, internal controls, cybersecurity plan).
- List of assets to be listed/handled and each asset's risks, restrictions, limits, and disclosures.
- Organization chart (name/title/role/authority) and client support system (SLA and complaint handling).
- Timeline: decision within 20 business days from a complete filing (corrections within the specified period if deficiencies are notified).
Ongoing obligations (during operations)
- Market integrity, insider-trading prevention, and clear disclosures of pricing/fees.
- Client asset protection (segregation, settlement, title/beneficial ownership) and cybersecurity, BCP/wind-down plan.
- AML/CFT framework: risk assessment → KYC/CDD/EDD → sanctions/PEP screening → transaction monitoring → suspicious transaction reporting (STR) → training → recordkeeping.
- Reporting & notifications: periodic reports and change/incident notifications, plus cooperation with the supervisor.
Process · 05
Process (Including Initial KYC, Engagement Decision, Contract/Payment)
Pre-consultation & information request1-2 business daysShare a high-level overview of the business model, service scope, governance, and source-of-funds plan.
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KYC / Client Due Diligence2-5 business daysCollect and review UBO identification/address, corporate registry documents, sanctions/PEP screening, and source-of-funds evidence. EDD (Enhanced Due Diligence) may be required for high-risk jurisdictions, complex ownership, large amounts, or cash-like flows.
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Engagement Decision1-2 business daysConfirm risk, scope, timeline, and fees → decide whether to proceed.
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Contract (LOE) Execution & Payment2-4 business daysE-signature, invoice issuance, payment (wire transfer / card +3.5%) → project kickoff.
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Local Company/Branch Incorporationtypically 3-4 weeksName confirmation → articles/incorporation deed notarized by a Notario → commercial registration (CNR) → full paid-in capital → NIT issuance → legal address confirmation.
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Document Package Preparation2-4 weeksLEAD Art. 20 requirements + AML/security/BCP documentation, translation, apostille.
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Pre-inscription (Optional)1-2 weeksPreliminary review by CNAD to identify points to address before the main filing.
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PSAD Main Filingstatutory decision within 20 business daysReview (with corrections if requested) → approval notice.
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Government Fee Payment & Registry Publication1-2 weeksPay the initial registration fee computed under LEAD Art. 12 → issuance/publication of registration number.
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Go-live & Periodic Obligations2-4 weeks (initial setup)Publish pricing/fees, operate client support, activate reporting/notification, AML training and monitoring.
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Bank/EMI Account (Optional)4-12 weeksLocal banks may initially support mainly domestic flows; consider combining with an EMI multi-currency account.
Documents · 06
Required Documents (Checklist) & Guidance on Translation, Apostille, Notarization
A. Incorporation (local company/branch)
- Articles/incorporation deed (Escritura de Constitución) notarized by a Notario
- Shareholder/director passport copies with Apostille + address proof (English)
- Representative POA with Apostille + Spanish Traducción jurada
- Recent register of shareholders and board resolutions (if required)
- Capital deposit proof (full paid-in)
- Commercial registration (CNR) and tax registration (NIT) filing documents
- Legal address proof (lease/occupancy confirmation, etc.)
B. License (PSAD/DASP) application
- Service capability memorandum (organization, systems, internal controls, security, operational flows)
- Asset listing/handling list + risks, restrictions, limits, draft disclosures
- Organization chart (name/title/role/authority) and client support policy (SLA and complaints process)
- AML manual, cybersecurity policy, BCP/wind-down plan
- Online platform/IT architecture (access, key management, logging, monitoring)
- Appointment document for the AML officer (no local-nationality requirement)
Detailed guidance on translation, apostille, notarization
- Foreign-issued documents should be apostilled in the issuing country before submission (apostille generally replaces consular legalization).
- Non-Spanish documents should include a Traducción jurada (certified/sworn translation) for court/administrative filing use.
- Documents signed/executed in El Salvador are notarized before a Notario (identity verification, stamping, and—where required—recording).
- To reduce rejection risk, prepare the chain in this order: original → apostille → certified translation → local notarization.
- For electronic documents, submit both the original scan (PDF) and a certificate of authenticity (if required).
Tax · 07
Local Accounting, Tax, and Audit Obligations (Operating Stage)
Accounting & audit
- Bookkeeping: Maintain periodic accounting entries and supporting evidence in accordance with local accounting standards (NIIF/IFRS accepted).
- Annual financial statements preparation and board/shareholder approvals; where thresholds/requirements apply, perform external audit.
- Policies: Define revenue recognition, digital asset valuation/custody, segregation of entrusted assets, and footnote disclosure standards.
Tax & filings (illustrative items)
- Periodic corporate income tax filings and monthly filings for advance payments/withholding (salary/vendor payments, etc.).
- Where applicable, monthly/quarterly filings for IVA (VAT) and other relevant taxes.
- Dividend tax, related-party transactions (TP) documentation/filings, and counterparty/inventory reporting.
- Business permits and contact/legal address renewals, plus other annual reports and approvals.
Rates and liabilities can vary by business type and transaction structure. Manage by tracking obligations and deadlines.
Costs · 08
Costs (Setup vs. Annual)
8.1) Setup costs (incorporation & application stage)
| Item | Formula / Scope | Notes |
|---|---|---|
| PSAD registration fee (government) | Industry/commerce/services monthly minimum wage × 15 e.g., monthly $408.80 × 15 = $6,132 | LEAD Art. 12 formula (new). The actual amount depends on the statutory minimum wage at filing time. |
| Company incorporation & commercial registration | Notary attorney (Notario) and registration disbursements $300-$800 | Varies by case (complexity, expedited processing, etc.). |
| Apostille & certified translation | $200-$600 per document | Varies by issuing country, page count, and lead time; includes legalization chain. |
| Paid-in capital | $2,000 fully paid in | Policy set as fully paid-in for balance management and due diligence practicality. |
| Documentation & advisory (optional) | Quoted separately based on scope | Drafting/review of AML, security, BCP, listing policies, etc. |
Total setup cost = government fee (formula) + incorporation/notary disbursements + optional documentation/advisory.
8.2) Estimated annual costs (operating stage — base table)
| # | Item | Amount (USD) | Notes |
|---|---|---|---|
| 1 | Business license renewal | 560 + government fees (35-500) | Permit/registration renewal |
| 2 | Annual renewal cost (internal approval process) | 1,800 | Approve AGM, financials, external audit, compliance/training plan |
| 3 | Contact/legal address notification | 560 | Registered address notification |
| 4 | AML suspicious transaction staff training | 1,300 | Once per year |
| 5 | External accounting audit | 1,650 | May vary by statutory requirement and size |
| 6 | Annual tax reporting package | 1,350 | Income, capital gains, IVA, payroll withholding, dividends, TP, counterparties, inventory, etc. |
| 7 | Advance income tax / withholding (monthly) | 6,600-9,240 | $550-$770 per month (12 months) |
| 8 | PSAD license annual renewal (government) | 5,700 | Reference. Government formula is minimum wage × 10 |
| 9 | Local regulatory liaison | 2,800 | Local communications channel |
| 10 | Compliance officer (20h/month) | 36,000 | $3,000 per month |
Interactive cost calculator
Use the Quick Quote tab above to select only the annual-cost items you need and compute the PSAD renewal fee live using the government minimum-wage × 10 formula.
Services · 09
MIRR ASIA Services (Optional Packages)
Standard Package (USD 31,000)
- Company incorporation + registered address for the first year
- Support for obtaining the PSAD (DASP) license
- Drafting and advisory for AML/KYC internal policies and procedures manual
- Drafting and advisory for internal policy documents (enterprise risk assessment, BCP, InfoSec, business termination, compliance, risk management, asset protection, code of ethics)
- During the licensing period, provide an exclusive local nominee owner and an alternate compliance officer (employment contract)
- Advisory related to obtaining the DASP license with the National Digital Assets Commission (NDCA)
- Includes a portion of government costs (USD 5,500), plus English translation and apostille for incorporation documents
Full Package (USD 40,000)
- Includes all items in the Standard Package
- Legal advisory after business model review
- AML registration with El Salvador's financial intelligence authority (UIF) (mandatory)
- Local bank or EMI account opening
- European EMI account opening (dedicated B2B/B2C accounts and multi-currency support)
- Initial accounting system setup and issuance of company books by a certified auditor
* Transcribed verbatim from the source, which refers to the regulator as CNAD elsewhere in this guide but as the "National Digital Assets Commission (NDCA)" here — to be confirmed with the client before publishing.
Next Steps · 10
Inquiry & Next Steps
Execute now
(1) Pre-consultation → (2) KYC/DD → (3) Engagement decision → (4) Contract & payment → (5) Company/branch incorporation (full paid-in capital) → (6) Document package & pre-inscription → (7) PSAD main filing (statutory 20 business days) → (8) Fee payment & registry publication → (9) Go-live & periodic obligations.
Contact a MIRR ASIA representative
Payment options (choose before invoicing)
- International wire transfer (Hong Kong corporate account)
- Card payment (3.5% fee)
Reference · 11
Reference
Laws, regulations, registration
- LEAD (Digital Assets Issuance Law) — original text (PDF) — Art. 12 (fee formula), Art. 19 (services), Art. 20 (application requirements), Art. 21 (obligations), Art. 36 (tax).
- PSAD/DASP registration process (English, CNAD)
- PSAD registration process (Spanish, CNAD)
- CNAD downloads (regulations, forms, AML guidance)
- PSAD public registry
Company, tax, wages
- CNR (National Registry Center) — Commercial Registry
- Ministry of Finance (MH) — NIT issuance guidance
- Ministry of Labor (MTPS) — publishes the monthly minimum wage
* Before commencing work, reconfirm the latest government regulations. Service items and pricing may change depending on the client's industry, requirements, decision-making structure, and the scope/category of our services.