Strategy, the world’s largest Bitcoin treasury company, has submitted a formal response to MSCI’s consultation on digital asset treasury companies (DATs), urging index providers not to exclude companies with digital asset holdings exceeding 50% of their total assets.
In a detailed letter to the MSCI Equity Index Committee, Strategy argued that the proposed thresholds are “misguided” and would have “significant detrimental consequences” for both investors and the broader digital asset industry.
Founded in 1989, the company operates the treasury and capital markets business of companies with significant Bitcoin holdings, offering investors a range of stocks and bonds backed by digital assets.
The company says its model is fundamentally different from passive investment funds. Strategy is actively leveraging its Bitcoin reserves to generate returns for shareholders and offer new financial products similar to traditional banking and insurance products.
The company emphasized that “DAT is an operating company, not an investment fund,” noting that its operational flexibility allows it to adapt its business model as technology evolves.
Strategy called MSCI’s logic “arbitrary and unworkable.”
Strategy criticized MSCI’s proposal to introduce a digital asset-specific 50% threshold as “discriminatory, arbitrary and unenforceable”.
The company emphasized that many traditional companies, such as oil companies, timber operators, REITs and media companies, also maintain concentrated holdings in a single asset type, but are not treated as investment funds.
The company warned that price fluctuations, differences in accounting standards, and changes in asset valuations create instability in the index, causing DAT to move in and out of the MSCI index.
The letter further argued that the proposal inappropriately injects policy considerations into index construction.
“MSCI remains committed to providing indices that accurately and objectively measure market performance,” Strategy wrote.
Excluding DATs based on the type of assets they hold rather than their underlying business model undermines MSCI’s neutrality and could mislead investors about how these companies operate.
Citing historical trading patterns in which the company’s stock has often exceeded the underlying value of its digital holdings, Strategy noted that investors are buying exposure to the company’s operations and innovation capabilities, not just Bitcoin itself.
Strategy: Digital assets are popular in government policy
The company also framed the discussion in the context of U.S. economic policy. Strategy noted that under President Trump, the federal government has put digital assets at the center of the nation’s economic life, including establishing the Strategic Bitcoin Reserve and promoting access to digital assets in retirement accounts.
Excluding DAT from the MSCI index is inconsistent with these policies and would chill innovation in the nascent sector, the letter argued.
In the letter, analysts cite estimates that if MSCI implements the exclusion, Strategy alone could face an equity outflow of up to $2.8 billion, with wide-ranging implications for the emerging digital asset economy.
The strategy compared the rise of digital asset treasury to previous industry leaders and placed itself in historical context.
The letter highlighted examples such as Standard Oil, AT&T, Intel, and NVIDIA, noting that these companies invested heavily in emerging technologies that were initially considered risky but ultimately became the foundation for economic growth.
Similarly, the Digital Assets Treasury is building critical infrastructure for the new financial system, the letter claims.
Don’t give in to “myopia”
The letter concluded by calling on MSCI to reject the 50% standard, citing the risk of stifling innovation, undermining the integrity of the index, and undermining federal strategy. The strategy recommended that MSCI conduct more thorough consultations before considering policies that would allow the market to continue to evolve and differentiate DAT from other operating companies.
The company suggested a cautious and measured approach, citing the precedent of MSCI, which reorganized its communications services sector after nearly two decades of industry evolution.
“History shows that when a fundamental technology emerges, prosperous financial institutions allow it to be tested in the market rather than restricting it up front,” Strategy writes. “MSCI will either succumb to myopia or allow its indexes to neutrally and faithfully reflect the next era of financial technology.”
Elsewhere, companies like Strive and Bitcoin For Corporations also challenged MSCI’s decision.
