MicroStrategy, the publicly traded company with the largest Bitcoin holdings globally, submitted comments to index provider MSCI on Wednesday, opposing the proposed policy changes.
DAT is a tool-type company that does not hold assets passively
The policy changes proposed by MSCI, which will officially take effect in January next year, will exclude reserve companies holding 50% or more of their balance sheets in cryptocurrencies from being part of stock market indices. If digital asset reserve companies wish to maintain their eligibility, they must liquidate part of their cryptocurrency holdings, resulting in additional selling pressure on the cryptocurrency market.
MicroStrategy pointed out in the letter that Digital Asset Reserve Companies (DAT) are essentially operational companies capable of actively adjusting their business operations, rather than passive holding companies for assets. The letter uses Strategy's own business of providing credit instruments based on Bitcoin as an example to illustrate that its business model has proactive operational characteristics.
The letter emphasizes that this proposed policy would create bias against cryptocurrency assets as an asset class for MSCI, instead of serving as a neutral evaluator as it has in the past.
MicroStrategy accuses MSCI of not excluding other similar companies.
MicroStrategy stated that the 50% digital asset threshold is "unreasonable, arbitrary, and impractical," and emphasized that MSCI has not excluded other major investment companies focused on a single asset class, such as real estate investment trusts (REITs), oil companies, and media investment portfolio companies. This reflects MSCI's intervention in index compilation with "policy preferences," no longer acting as a neutral organization. MicroStrategy wrote in the letter:
"Many financial institutions essentially hold large amounts of specific types of assets and further package them into derivative financial products, such as residential mortgage-backed securities."
The letter also emphasizes that if the policy is implemented, it will undermine the policy goals promoted by President Trump, which is to make the U.S. a global leader in cryptocurrency assets. However, critics point out that including Digital Asset Reserve Companies in the global index may bring additional risks.
MicroStrategy emphasizes that the new policy will harm the market, innovation, and U.S. competitiveness, and will cause MSCI to lose its neutral role. The company calls on MSCI to maintain the current standards, allowing DATs to continue to be included in the global investable index. If MSCI still intends to set special standards for DATs, it should at least reopen consultations and extend the discussion time to allow businesses and market participants to provide more complete data and opinions.
MSCI states that DAT may pose systemic risks.
MSCI stated in a statement released in October that Digital Asset Reserve Companies are more like "investment funds" rather than operational companies that truly produce goods or services; therefore, if included in the index, it might distort the representativeness of the index. Furthermore, MSCI further stated that cryptocurrency assets lack consistent valuation methods, and the accounting treatment has a high degree of uncertainty, which could distort the index valuation if included.
As of the time of writing this article, MicroStrategy holds 660,624 BTC. According to market data, the company's stock has fallen more than 50% over the past year. Although Bitcoin itself has also performed poorly this year, with prices down over 15% from the early 2025 peak, the decline is still smaller than that of Strategy's stock, indicating that the performance of the underlying asset is still better than that of the wrapped proxy stock.
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