Key Highlights
- The Bitcoin Policy Institute published a September 30 paper examining MSCI’s proposal to exclude certain companies from major indexes under a non-operating company screen.
- MSCI previously proposed excluding companies with at least 50% of assets in digital assets before shelving that proposal in January 2026.
- A revised methodology uses operating assets and five financial ratios; MSCI’s May 2026 simulation would have excluded Strategy, Metaplanet, and Yellow Cake.
The Bitcoin Policy Institute, a non-partisan, non-profit think tank, released a paper on September 30 examining MSCI’s proposal to screen certain companies from its Global Investable Market Indexes based on whether they meet proposed criteria for operating activity.
The paper, titled “Wall Street’s Invisible Committee” and authored by Conner Brown, reviews the proposal’s development, related public statements by MSCI, and its possible application. According to the paper, MSCI reports $21 trillion in assets benchmarked to its indexes. Changes to methodology can require funds tracking those indexes to adjust holdings, potentially shifting billions of dollars.
Proposal history and metadata findings
In 2025, MSCI proposed excluding Digital Asset Treasury Companies holding at least half their assets in digital assets from its Global Investable Market Indexes. After opposition, MSCI shelved the proposal in January 2026.
It later returned with a broader test for non-operating companies based on operating assets and five financial ratios. MSCI’s simulation using May 2026 data would exclude Strategy, Metaplanet, and Yellow Cake plc, a company that holds uranium.The institute examined the public consultation PDF and identified embedded metadata.
The paper states that while metadata alone cannot prove the outcome was predetermined, it raises a question about whether the criteria were developed for consistent classification or to reach the same exclusions through a broader rule.
Public comments on the current proposal closed on September 30, with a decision expected by October 16. If adopted, the changes are proposed to take effect as part of the November 2026 Index Review.
Earlier statements on cryptocurrency
The paper traces MSCI’s public record to an October 2021 article titled “Creeping Crypto.” In it, MSCI warned about cryptocurrency exposure entering equity portfolios, described most cryptocurrencies as speculative investments with little evident utility, and flagged Bitcoin’s Proof of Work as environmentally dangerous.
It identified at least 52 public companies with cryptocurrency exposure, including 26 constituents of the MSCI ACWI Index. Strategy, then known as MicroStrategy, appeared at the bottom of the governance-score ranking shown in the article.
CEO Henry Fernandez has publicly stated the importance of ESG investing. In 2021, he recounted urging bankers to refuse to take a company public or do a bond offering without a net-zero pledge. MSCI’s then-head of indexes described an ambition for its flagship global index to become green, one company at a time.
Leadership combined responsibility for ESG and index governance. The paper notes these statements do not prove the motive behind the current proposal but raise a governance question about the boundary between advocacy and broad-market index decisions.
According to the paper, the proposed test relies on operating assets without a standardized classification framework under U.S. GAAP or IFRS. The paper analyzes how interpretations could apply to assets such as a satellite awaiting launch, a mine under construction, or capital raised to build a factory.
It states that the discretion could affect emerging industries. MSCI has maintained that an index is a mathematical calculation that does not channel investments and that it expresses no opinion on whether any company or investment is good or bad. Index providers are not regulated as investment advisers.
Company responses on the proposal
In comments submitted on September 25, Strive Chairman and CEO Matt Cole asked MSCI to clarify how it would determine whether assets form part of a company’s operating business under the proposed methodology. Cole questioned applications to companies that use financial assets in lending, structured finance, and asset management.
Strategy, in a letter dated August 31 signed by Executive Chairman Michael Saylor and President and Chief Executive Phong Le, stated it does not fail the proposed exclusion screen. The company said it has not triggered four of the five financial-ratio flags. Strategy said it records $22.77 billion of Bitcoin fair-value changes within operating expenses; excluding that line, it said operating expenses would equal 0.37% of total assets.
The letter described the proposal as a repackaging of the earlier digital-asset-specific rule withdrawn on January 6, 2026, which drew opposition from more than 250 organizations and 1,500 signatories. Strategy noted that the terms “operating” and “non-operating” appear in no U.S. GAAP or IFRS standard and that no accounting framework or other index provider uses the five proposed ratios.
It said MSCI has not engaged with the company in the eight months since withdrawing the first proposal and asked MSCI to withdraw the consultation.
The Bitcoin Policy Institute paper provides recommendations for policymakers, including a presumption of inclusion for lawful, liquid, investable equities in broad-market indexes and transparent, reproducible criteria for any categorical exclusions.
Also Read: Strategy’s Saylor Sees Separate Capital Pools for Bitcoin Treasury Firms
