Strategic Bitcoin reserves: states, corporations and public funds

In 2021, El Salvador×El SalvadorFirst country to adopt Bitcoin as legal tender, in September 2021 under Nayib Bukele. Its status was amended in 2025 under IMF pressure.See in the lexicon → made Bitcoin legal tender and built a state reserve of several thousand BTC. In March 2025, the Trump administration signed an executive order creating a US "Strategic Bitcoin Reserve×Strategic Bitcoin Reserve (SBR)United States strategic Bitcoin reserve created by executive order of Donald Trump in March 2025. Built from seized bitcoins.See in the lexicon →" from seized bitcoins. MicroStrategy×MicroStrategy (Strategy)US company led by Michael Saylor, which has made bitcoin its main treasury asset since 2020. More than 400,000 BTC accumulated by 2025.See in the lexicon → holds more than 600 000 BTC in 2026, about 3 % of the maximum supply, on its listed company balance sheet. The strategic reserve topic has become central.

Three different logics coexist. Sovereign state reserve : Bitcoin as a hedge against fiat×Fiat (fiat currency)State currency with legal tender status (euro, Swiss franc, dollar), issued by a central bank and not backed by a physical asset. By contrast, Bitcoin has an issuance capped at 21 million units, with no central issuer.See in the lexicon → depreciation and partial substitute for USD foreign exchange×ExchangeService that lets you buy, sell and swap cryptocurrencies against fiat money. Examples : Kraken, Coinbase, Bitstamp, Bitvavo. Most are custodial.See in the lexicon → reserves. Corporate reserve : Bitcoin treasury to escape monetary erosion and capture an appreciation option. Community reserve : initiatives like Lugano×Lugano (Plan ₿)Swiss city that launched a Bitcoin adoption programme in 2022 (tax payments, shops, events). The annual Plan B Forum has become a European fixture.See in the lexicon → Plan B or a European municipality adopting BTC in its treasury.

This article retraces the 2021-2026 timeline (El Salvador, MicroStrategy, Argentina, US Trump, first Swiss cantons in debate), exposes the underlying logics, addresses the IFRS accounting of a Bitcoin treasury (IAS 38 versus US accounting amendment), exposes the risks (volatility, electoral perception, fork×Fork (soft fork, hard fork)Change to the protocol rules. A soft fork stays compatible with old nodes (SegWit, Taproot); a hard fork creates a separate chain (Bitcoin Cash in 2017).See in the lexicon →) and the geopolitical bandwagon dynamic.

Why the reserves topic has become central

Three converging movements explain the shift.

1. Infrastructure maturity. In 2017, accumulating 100,000 BTC for a state or corporation was technically complicated: unprofessional exchanges, no institutional custody×CustodyThe custody of funds. See self-custody and custodial in the dedicated section below.See in the lexicon →, hostile IFRS accounting. In 2026, infrastructure exists: Coinbase Custody, Fidelity Digital Assets, BitGo, Anchorage handle tens of billions of dollars in institutional BTC. IFRS accounting has evolved (FASB ASU 2023-08 in the US now authorises fair value evaluation for cryptoassets). Spot ETFs offer a regulated wrapper for entities that cannot hold Bitcoin directly (constrained public funds, regulated funds). The technical obstacle has fallen.

2. Degradation of traditional reserve assets. Sovereign bonds, long the reserve asset par excellence of central banks and corporate treasuries, have lost attractiveness since 2020. The 2021-2023 inflation showed that real sovereign bonds can stay in negative territory for years. The freezing of Russian reserves in USD/EUR in March 2022 (~300 billion USD) showed that reserve assets are politically seizable. China and several Global South countries have since been seeking non-seizable alternatives: physical gold first, Bitcoin as experimental complement. Saylor puts it: Bitcoin is « the hardest reserve currency ever invented ». The argument is partial but heard.

3. Short-term political calculation. Announcing a Bitcoin reserve has become a political signal. For Trump (March 2025), it is a message to his crypto-friendly electoral base. For Bukele (2021), it was a stunt of international communication. For the Republican senators supporting the BITCOIN Act, it is a differentiating position against Democrats. For Switzerland via the 2B4CH initiative, it is an affirmation of monetary sovereignty against the strong franc vs USD. Part of these announcements are sincere, another is cosmetic. Telling the two apart takes hindsight.

The sum of the 3 movements (mature infrastructure + degradation of alternatives + political calculation) creates an institutional accumulation dynamic that did not exist before 2024. The pace remains modest compared to available supply: identified institutions (ETF + US SBR + main corporates) hold in May 2026 about 2.2 million BTC out of the 19.7 million in circulation, or ~11 %. It is enough to modify market microstructure (volatility, liquidity, cycle behaviour), not enough to make Bitcoin « controlled » by institutions in the sense gold is by central banks.

For Sylvain and other retail investors, the most tangible effect is felt in 2 areas. Volatility dampens slightly: the -80 % historical drawdowns (cf. halving and cycles) could become -60 % to -70 % as ETF flows stabilise bears. Regulation intensifies: MiCA×MiCA (Markets in Crypto-Assets)European regulation 2023/1114 that frames crypto services across the EU since 2024. Creates the CASP status.See in the lexicon → in Europe (2024-2025), FATF evolutions, KYC×KYC (Know Your Customer)Mandatory identification procedure that regulated platforms apply to their users : ID document, proof of address, and so on.See in the lexicon → debates on self-custody×Self-custodyModel in which you hold your own private keys. Your bitcoins depend on no third party. This is Bitcoin's founding promise.See in the lexicon →. Bitcoin remains possible in self-custody in 2026, but the legal framework is less free than in 2017.

The 3 levels of actors: states, corporations, public funds

Institutional Bitcoin holders fall into 3 categories with different logics.

Level 1: sovereign states. As of 27 May 2026, 4 states openly hold Bitcoin:

• USA: ~200,000 BTC in the federal SBR since March 2025, mainly from seizures. No accumulation by budget purchase to date, but possibility in the Lummis BITCOIN Act if voted.
• El Salvador×El SalvadorFirst country to adopt Bitcoin as legal tender, in September 2021 under Nayib Bukele. Its status was amended in 2025 under IMF pressure.See in the lexicon →: ~6,100 BTC accumulated since September 2021 via modest scheduled purchases (1 BTC per day between November 2022 and end 2023, then slowdown). Bitcoin remains legal tender but the December 2024 IMF agreement reduced its official status.
• Bhutan: ~13,000 BTC according to Arkham Intelligence (April 2025), accumulated by hydroelectric mining×MiningProcess of validating blocks through proof of work. Consumes electricity by design : that is what secures the network.See in the lexicon → via the Druk Holding sovereign fund. Discreet approach but materially larger than El Salvador.
• United Kingdom (seizures): ~61,000 BTC seized mainly in 2018 in the Zhao Wei case, kept by the NCA. No declared strategic reserve but passive de facto accumulation.

Several other jurisdictions have engaged debates without decision: Switzerland (2B4CH initiative), Hong Kong (2024 senatorial proposal), Sweden (negative 2025 Riksbank report), Brazil (2024 Eros Biondini proposal). France and Germany have positioned themselves against, in line with the ECB stance.

Level 2: listed corporations. As of 27 May 2026, 78 listed companies hold more than 100 BTC each in treasury, totalling about 1.1 million BTC. The main ones:

• Strategy (formerly MicroStrategy×MicroStrategy (Strategy)US company led by Michael Saylor, which has made bitcoin its main treasury asset since 2020. More than 400,000 BTC accumulated by 2025.See in the lexicon →, ticker MSTR): ~605,000 BTC accumulated since August 2020 under Michael Saylor, financed by stock and convertible debt issuance. Hyper-concentrated model, the company has become de facto a leveraged listed Bitcoin proxy.
• Marathon Digital (MARA): ~50,000 BTC, mainly North American miner×MinerComputer or farm of computers that solves the cryptographic puzzle required to add a new block to the blockchain, in exchange for a bitcoin reward.See in the lexicon → that keeps its production.
• Riot Platforms: ~22,000 BTC, model similar to Marathon.
• Tesla: ~11,500 BTC, position partially restored in 2024 after the 2021-2022 sales.
• Block Inc. (formerly Square, Jack Dorsey): ~8,000 BTC, modest but public position since 2020.
• About fifty other small and mid caps in Europe (Bitcoin Group SE, Coinsilium), Japan (Metaplanet ~25,000 BTC, Japanese Saylor model), Latin America (several listed in Mexico and Brazil).

The corporate model dominates numerically: 1.1 million BTC corporate vs ~280,000 BTC sovereign (and 1.2 million in ETFs). The logic is different: the corporation accumulates to protect its cash from inflation and offer a Bitcoin proxy to its shareholders. The state accumulates for macro-strategic or political reasons.

Level 3: public funds and endowments. Hybrid category between institutional actor and collective retail investor. Documented cases:

• State of Wisconsin Investment Board (SWIB): declared ~165 million USD invested in IBIT in May 2024, position increased to ~340 million USD in early 2026.
• Houston Firefighters' Pension System: pioneer, direct purchase of 25 million USD of BTC in October 2021 (still held).
• Yale, Harvard endowments: Bitcoin exposure via specialised funds (Paradigm, Pantera, Bitwise), undisclosed amounts but documented in the several hundred millions.
• Several European public funds via ETF (Germany, Norway via NBIM indirectly).

This 3rd level is the most discreet but potentially the most structuring long term. If Western pension funds (several tens of trillions USD under management) allocate even 0.5 % to Bitcoin, the buy flow would exceed neo-mining issuance for years.

The macro thesis behind sovereign reserve

The argumentation for a sovereign Bitcoin reserve rests on 3 macro-economic guides.

1. Diversification of reserve assets. Central banks historically hold 4 large categories of reserves: foreign currencies (USD, EUR, JPY, GBP, CHF mainly), gold, IMF special drawing rights, commercial claims. Bitcoin proposes a 5th category with unique properties: fixed and programmed supply, geopolitical neutrality (no issuing state), digital portability, on-chain verifiability. For a state that observes the growing fragility of USD hegemony (Russian reserves freeze 2022, US extraterritorial sanctions, US debt at 130 % of GDP), a 1-5 % Bitcoin allocation serves as diversification without abandoning other reserves.

2. The accumulation cycle effect. The argument of the Lummis BITCOIN Act is explicitly game-theoretic: if the US accumulates 1 million BTC over 5 years before other states, it captures a disproportionate share of the supply capped at 21 million×21 millionMaximum number of bitcoins that will ever exist, hard-coded in the protocol. This programmed scarcity is a founding feature. The last sat will be mined around the year 2140.See in the lexicon →. States that hesitate then pay a higher price for the same accumulation. It is a prisoner's dilemma applied to monetary reserves: if you wait for others to move, you pay more; if everyone moves at the same time, the price explodes and nobody can accumulate mass. This argument is powerful for early movers, empty for late movers.

3. Positioning in a multipolar world. Post-1944 USD hegemony (Bretton Woods) then post-1971 (end of gold convertibility) enters a contestation phase since 2020 (BRICS+, partial dedollarisation of China-Russia trade, oil payments in CNY, AED). Several scenarios are on the table for the next 10-20 years: maintenance of softened USD hegemony, transition to a multi-currency system (USD + CNY + EUR), partial return to a gold standard, emergence of a neutral digital reserve asset (Bitcoin, or a crypto basket, or an ECB synthetic asset like CBDC). No scenario is dominant. A 1-5 % Bitcoin reserve is a low-cost option that hedges against several scenarios.

These 3 arguments are serious but contested. Counter-arguments exist and are solid (cf. section 6). The position of established central banks (ECB, SNB, Bank of Japan) remains structurally opposed. Christine Lagarde (ECB) declared in 2024 that Bitcoin « will never be a reserve asset ». Martin Schlegel (SNB, May 2025) repeats the same position. On the other side, US Treasury and some Fed governors now support or tolerate the option. The transatlantic political divide on this topic is not a detail.

The retail investor must retain 2 things. First, the macro pro-reserve arguments are defendable and defended by serious economists (Lyn Alden, Saifedean Ammous, Vijay Boyapati, more recently Larry Lepard and Greg Foss). Second, they are not universally accepted. The majority of the monetary establishment remains sceptical. The outcome over 10-20 years is open.

Central table: 5 Bitcoin reserve cases compared

Synthesis of the 5 most documented cases in May 2026, chosen for their representativeness of the 3 actor levels (2 sovereign, 2 corporate, 1 public fund).

Reading the table. 5 actors, 5 different motivations, 5 distinct risks. None is a universal model. The retail investor observing this landscape can conclude: (a) the diversity of approaches shows there is no established orthodoxy, (b) institutional Bitcoin is still in an exploratory phase, (c) the specific risks (Strategy margin call, SBR political reversal, El Salvador adoption failure) are concrete, not hypothetical. Bitcoin enters institutional mainstream but remains a high-risk asset even for sophisticated actors.

Serious criticisms against Bitcoin reserves

The pro-reserve argument has solid counter-arguments, defended by economists, central bankers and researchers who are not anti-crypto in principle. 4 criticisms deserve to be raised.

1. Volatility incompatible with a reserve. A reserve, by definition, is an asset one preserves to be able to use in case of need. A reserve that can lose 80 % of its value in 12 months is not a reserve, it is a speculative asset. This is the central argument of the SNB (Schlegel May 2025), the ECB (Lagarde 2024), the Bank of Japan. Pro-reserve advocates respond that gold is also volatile over certain periods (1980-1999), and that volatility dampens with growing capitalisation. But in absolute 2026 value, Bitcoin remains 3 to 5 times more volatile than gold, which is itself rarely considered « non-volatile ».

2. Concentration and capture. If a few states (USA first) accumulate 5-10 % of total supply, what does it mean for the decentralised character of the network? Maximalist×MaximalistBitcoiner who considers that Bitcoin alone is legitimate among cryptos, and that the others (Ethereum, Solana, and so on) are distractions or scams.See in the lexicon → pro-Bitcoiners respond that coin holding gives no power over the protocol. Technically that is true (Bitcoin governance passes through nodes and developers, not holders). Politically it is more nuanced: a state holding 1 million BTC can influence regulation, finance attacks on competing miners, or use its position as a geopolitical weapon. The risk is underestimated in the pro-reserve discourse.

3. El Salvador×El SalvadorFirst country to adopt Bitcoin as legal tender, in September 2021 under Nayib Bukele. Its status was amended in 2025 under IMF pressure.See in the lexicon → popular adoption failure. The El Salvador case was presented in 2021-2022 as the vanguard of Bitcoin adoption by populations. The 2024-2025 figures are disappointing: less than 10 % of Salvadorans regularly use Bitcoin for their daily transactions (BCR-FUSADES surveys, José Simeón Cañas University, IMF Article IV 2024). The official Chivo wallet×WalletSoftware or device that manages your Bitcoin keys and lets you sign transactions. A wallet does not really « hold » your bitcoins, it holds the keys that prove you own them.See in the lexicon → had technical problems, hacks, and user rejection. The December 2024 IMF agreement withdrew Bitcoin's mandatory legal-tender status. The lesson: sovereign reserve does not guarantee popular adoption, and international institutional pressure (IMF, World Bank) remains strong against experimentation.

4. Fiscal opportunity cost. For a state that would accumulate 1 million BTC at average price 80,000 USD, the budget engaged would be 80 billion USD. This amount alternatively invested in infrastructure, education, R&D, or even inflation-indexed sovereign bonds, produces measurable social return. Bitcoin produces a potential financial return over 10-20 years, but no direct social return (no production, no service, no redistribution). For a Keynesian economist or a traditional public planner, the opportunity cost argument is strong. The pro-reserve answer (Bitcoin protects against systemic monetary risk) is defendable but hard to quantify ex ante.

These 4 criticisms are the backbone of the position of European and Japanese central banks. They are not marginal. Governments that adopt the Bitcoin reserve (USA, El Salvador, Bhutan) explicitly assume these criticisms while betting that long-term benefits will prevail. The outcome will be judged over 20 years, not over 2 years.

Central case: the SNB and the 2025 Swiss popular initiative

Switzerland occupies a singular position in the Bitcoin reserves debate. Not by its size (the SNB manages ~750 billion CHF of reserves, modest at Fed or ECB scale), but by the combination of 3 factors: tradition of monetary independence, direct democracy allowing popular initiatives, mature local crypto ecosystem (Crypto Valley Zug, Bitcoin Suisse, Sygnum, Relai).

Genesis of the 2B4CH initiative. In late 2024, a federal popular initiative committee launched by Yves Bennahmias (Zurich tech entrepreneur), Luzius Meisser (chairman of Bitcoin Association Switzerland) and several Crypto Valley personalities files the text of an amendment to the federal Constitution. Current article 99 paragraph 3 states that « the National Bank constitutes, from its revenues, sufficient monetary reserves, of which a part in gold ». The initiative proposes to add « as well as in Bitcoin » at the end of the paragraph. Mechanically, this would force the SNB to constitute a Bitcoin reserve, without specifying the share (current practice for gold is ~7-8 % of SNB reserves).

Signature collection. Initiated on 31 December 2024 by publication in the Federal Gazette, the initiative has 18 months to collect 100,000 valid signatures, so until 30 June 2026. As of 27 May 2026, the committee announces ~62,000 collected signatures, or 62 %. The pace accelerated in spring 2026 after the Trump SBR executive order. The probability of reaching 100,000 signatures before the deadline is judged at about 60-70 % by observers.

Official SNB position (Schlegel, 15 May 2025). SNB statement at the time of the 2025 general assembly: clear but reasoned refusal, without dramatisation. The 4 arguments advanced:

• Bitcoin volatility -77 % to -86 % on historical drawdowns, incompatible with the « buffer » reserve function that an SNB asset must play.
• Bitcoin liquidity (~50 billion USD of daily global spot volume in May 2026) insufficient for an SNB managing 750 billion CHF. Selling a significant fraction moves the market.
• Absence of clear macro-economic function: SNB holds reserves to stabilise the franc, finance its exchange×ExchangeService that lets you buy, sell and swap cryptocurrencies against fiat money. Examples : Kraken, Coinbase, Bitstamp, Bitvavo. Most are custodial.See in the lexicon → interventions, guarantee confidence. Bitcoin directly serves none of these functions.
• Reputation risk for the SNB, already under criticism for its inflated balance sheet (management of EUR/CHF purchases 2011-2021). Adding Bitcoin would expose to politically visible potential losses.

Response from the initiative committee. The 2B4CH committee contests the 4 arguments: volatility dampens (2018-2024 vs 2009-2017 statistics), liquidity grows with ETFs, the macro function exists (anti-fragile diversification, inflation hedge), reputation risk is also that of missing an emerging asset. The debate is argued on both sides, without excessive demagogy (unlike other Swiss popular initiative campaigns).

Probable scenario. If the initiative succeeds (gathering 100,000 signatures before June 2026), it will be submitted to federal popular vote in 18-36 months, so late 2027 or in 2028. The Federal Council and Parliament will probably issue a rejection recommendation, as is traditionally the case for anti-establishment economic initiatives. The average acceptance rate of popular initiatives in Switzerland since 1891 is 11 %. The 2B4CH initiative would start disadvantaged. But the topic will have been raised publicly, and the SNB will have been forced to defend its position before the people. It is a precedent in Europe.

For Sylvain in Geneva, the initiative changes nothing in his individual estate strategy. But it modifies the context: Bitcoin is now discussed at the level of the Swiss federal Constitution, which marks a stage of institutionalisation, even if the vote outcome remains very uncertain.