Strategy Submits Official Response to MSCI

Journalist

Tanzeel Akhtar

Journalist

Tanzeel Akhtar

Part of the Team Since

Feb 2018

About Author

Tanzeel Akhtar has been reporting on cryptocurrency and blockchain technology since 2015. Her work has appeared in leading publications including The Wall Street Journal, Bloomberg, CoinDesk, Bitcoin…

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Last updated: 

December 10, 2025

Strategy Inc., the world’s largest Bitcoin treasury company, has submitted a detailed response to MSCI’s consultation on how to classify Digital Asset Treasury Companies (DATs).

MSCI has proposed excluding from its Global Investable Market Indexes any company whose digital asset holdings represent 50% or more of total assets.

In a letter dated December 10, sent by Executive Chairman Michael Saylor and CEO Phong Le, Strategy argues the move is “misguided” and would have “profoundly harmful consequences” for capital markets, innovation, and U.S. leadership in digital assets.

“DATs Are Operating Companies, Not Investment Funds”

The core of Strategy’s argument is that DATs like itself are operating businesses, not passive investment funds. Strategy stresses that it does not simply sit on a Bitcoin hoard; instead, it runs a Bitcoin-backed corporate treasury and capital markets program, issuing a range of equity and fixed-income instruments that provide investors with varying degrees of Bitcoin exposure.

It compares this model to banks and insurers that capture a spread between financing costs and returns on underlying assets.

The company notes that many traditional firms—such as oil majors, REITs, timber companies and media groups—are also heavily concentrated in a single asset type, yet are not treated as funds or excluded from indices. Singling out digital-asset-heavy balance sheets, it says, would be discriminatory and inconsistent.

Strategy Warns of Index Instability and Policy Bias

Strategy contends that MSCI’s proposed 50% digital asset threshold is both arbitrary and unworkable. Given crypto price volatility and divergent accounting standards (GAAP vs. IFRS), companies could “whipsaw on and off” MSCI indices as market values fluctuate, undermining index stability and investor confidence.

The letter also accuses MSCI of improperly injecting policy judgments into index construction, departing from its stated role as a neutral provider of “exhaustive” benchmarks that reflect market evolution rather than deeming certain business models “good or bad.”

Excluding DATs, Strategy argues, would structurally under-represent a fast-growing segment of the economy and call into question the neutrality of MSCI’s indices.

Conflict with U.S. Digital Asset Strategy and Call for Extended Review

Strategy further argues that the proposal conflicts with the current U.S. administration’s pro-innovation digital asset agenda, including initiatives like a Strategic Bitcoin Reserve and efforts to expand access to digital assets in retirement plans.

Excluding DATs from major benchmarks, the company says, would choke off access to passive capital, chill innovation, and weaken U.S. competitiveness in a strategically important sector.

Concluding, Strategy urges MSCI to reject the proposal outright or, at minimum, extend the consultation and undertake a longer, more deliberate review as digital asset treasury models continue to mature. “The wiser course,” the letter states, “is for MSCI to remain neutral and let the markets decide the course of DATs.”