Strategy has planted a flag against MSCI’s proposal to remove digital asset treasury companies (DATs) from its Global Investable Market Indexes. According to the company, the wiser course for MSCI, for investors, and for the broader economy is for MSCI to remain neutral and let the markets decide the course of DATs.
MSCI argued that crypto treasury companies are more like investment funds than operating companies.
However, Strategy, led by Executive Chairman Michael Saylor, argued that it builds Bitcoin-backed credit instruments, manages an active corporate treasury program, and maintains a global enterprise analytics software business, not a passive vehicle for tracking price movements. Investors buy the company’s strategy and management, not a static wrapper for Bitcoin.
“Strategy is not an investment fund, and it does not passively hold Bitcoin. Strategy is an operating business that actively uses the Bitcoin it holds to create returns for shareholders,” the company wrote.
Strategy Argues Proposal is Discriminatory and Arbitrary
The company warned that implementing the proposal’s 50% threshold is discriminatory, arbitrary, and has zero positive effect. It singles out digital asset businesses while leaving untouched companies in other industries with similarly concentrated holdings in oil, timber, gold, media and entertainment, and real estate.
Additionally, Strategy stated that such a move would disrupt market stability. The leading corporate holder of Bitcoin is urging MSCI to consider DATs as operating entities that contribute to economic progress and innovation.
Strategy also claimed that the proposal is believed to conflict with US policy. President Trump signed an executive order to promote the growth of digital financial technology. The administration also established a Strategic Bitcoin Reserve and promoted the inclusion of digital assets in 401(k) plans.
The company also requested that MSCI provide further consultation.
“MSCI should allow time for the digital asset industry and DATs to evolve and gain their footing before proposing broad-stroke rules and criteria. At a minimum, MSCI should not take such a consequential step without engaging in further consultation,” the letter read.
Besides Strategy, Strive, a structured-finance company listed on Nasdaq, is fighting MSCI’s proposal to exclude Bitcoin-heavy companies from major global equity benchmarks.
The firm that holds over 7,500 Bitcoins sent a letter to Henry Fernandez, MSCI’s CEO, stating that the proposed exclusion would violate the “long-established principle of index neutrality.”
According to analysts, Strategy could see up to $2.8 billion of its stock liquidated under MSCI’s proposal. The company was added to MSCI’s indices in May 2024 and has been included for approximately a year and a half.
Strategy Continues Aggressive Bitcoin Accumulation
Strategy has continued its aggressive accumulation approach through November and December 2025. In November, the company added a total of approximately 9,062 BTC across several transactions, including a major purchase of 8,178 BTC for $835.6 million at an average price of $102,171 per coin.
The company added 130 BTC for $11.7 million early this month, reaching a symbolic 650,000 BTC milestone, valued at roughly $58.5 billion at the time. The pace accelerated slightly later in the month with a purchase of 10,624 BTC for $962.7 million between December 1 and 7 at $90,615 per coin.
This brought the total holdings to 660,624 BTC, acquired for approximately $49.35 billion at an average cost of $74,696 per BTC.
In a recent statement, CEO Phong Le said that Bitcoin sales are possible in extreme situations, such as a 95% price drop that would trigger margin calls. This goes against Saylor’s long-held “never sell” mantra and has led to speculation about an unimaginable fire sale of their 3% share of the total Bitcoin supply. The company’s mNAV is hovering near 1.0, and shares have dropped 50% since October.