Strategy’s Response to MSCI’s Consultation on Eligibility of Non-Operating Companies
MSCI proposes a new eligibility test that would exclude "non-operating" companies, including Strategy, from its Global Investable Market Indexes. This proposal would not meaningfully affect Strategy: funds tracking MSCI GIMI indices hold only 3.1% of Strategy's basic shares outstanding.¹ We believe the proposal is misguided, and we oppose it for the following reasons:
- The proposal is a pretext for targeting Digital Asset Treasury Companies, repackaging MSCI's own withdrawn 2025 proposal to exclude companies with 50%+ digital asset holdings in different language, but reaching the same result.
- MSCI's "operating" and "non-operating" terminology is undefined, has no basis in U.S. GAAP, IFRS, or any recognized legal framework, and appears designed to reach a predetermined outcome.
- The proposed deletion of Strategy conflicts with established accounting and securities-law principles. Strategy reports its Bitcoin business as an operating segment under U.S. GAAP, consistent with discussions with SEC Staff.
- The proposal injects MSCI's own policy judgments into index construction, undermining the neutrality and reliability that MSCI's customers depend on.
We ask MSCI to withdraw its proposal. Please voice your support by sending an email to MSCI yourself and registering on the left.