Strategy Submits Formal Response to MSCI Proposal on Digital Asset Treasury Companies

Strategy Inc. has submitted a formal response to MSCI regarding the index provider’s proposed rule that would exclude companies from its Global Investable Market Indexes if digital assets account for 50% or more of total balance sheet assets.

Michael Saylor, Executive Chairman and Founder of Strategy, confirmed the submission in a public statement on X.

The letter, dated December 10th, 2025, was addressed to the MSCI Equity Index Committee and responds to MSCI’s consultation on a proposed eligibility test for companies classified as Digital Asset Treasury Companies (DATs). 

The proposal would apply to firms whose balance sheets are primarily composed of Bitcoin and digital assets.

Strategy’s Characterization of Digital Asset Treasury Companies

In its response, Strategy states that DATs should be classified as operating companies rather than investment funds. 

The company describes its business model as actively using digital asset holdings, primarily Bitcoin, to support financial products and capital markets activity. 

These offerings include both equity and fixed-income instruments designed to provide varying degrees of economic exposure to Bitcoin.

Strategy also argues that high asset concentration has historically not been a basis for exclusion from MSCI indices for companies in other industries. 

In its letter, the company references sectors such as oil, mining, utilities, real estate, timber, and intellectual property, where firms may hold a majority of assets in a single category while remaining eligible for inclusion.

Objections to the 50% Digital Asset Threshold

Strategy’s letter describes the proposed 50% digital-asset threshold as discriminatory, arbitrary, and difficult to implement. 

The company states that volatility in Bitcoin and digital asset prices could lead to repeated changes in index eligibility. 

It also points to differences between U.S. GAAP and international IFRS accounting standards, which could result in inconsistent treatment of similarly structured companies across jurisdictions.

The letter further argues that the proposal would require additional oversight mechanisms for asset valuation, threshold monitoring, and compliance enforcement that are not currently part of MSCI’s methodology.

Index Methodology and Neutrality

Strategy asserts that MSCI’s proposal introduces policy considerations into an index framework that has traditionally been presented as neutral and market-representative. 

The company states that selectively applying eligibility standards based on Bitcoin and digital asset exposure could affect how certain business models are represented within broad equity benchmarks.

Strategy also contends that the proposal could lead to reduced representation of digital-asset-focused companies within widely used indices.

Market and Policy Context Referenced in the Letter

The response letter references recent U.S. federal policy developments related to Bitcoin and digital assets, including initiatives tied to digital asset infrastructure, retirement investment access, and national reserve strategies. 

Strategy states that excluding DATs from major indices could affect capital flows into the sector and alter passive investment exposure.

Citing third-party analysis, Strategy notes that companies with large digital asset holdings could face significant forced selling if removed from major benchmarks. 

The company also states that Bitcoin mining firms and other digital-asset-intensive businesses could be indirectly impacted by the proposed rule.

Request for Additional Review

In the closing section of its letter, Strategy urges MSCI not to adopt the proposal in its current form and requests that the consultation process be extended to allow additional industry feedback. 

The company compares the current development stage of digital asset treasury strategies to earlier periods of technological transition in industries such as telecommunications and internet infrastructure.

The letter was signed by Michael J. Saylor, Executive Chairman and Founder, and Phong Le, President and Chief Executive Officer of Strategy Inc.