September 4th – Nasdaq is intensifying regulatory scrutiny on publicly-listed companies that raise capital to purchase and hold cryptocurrency assets long-term, according to informed sources. These entities, termed ‘Digital Asset Treasury Companies’ (DATs), characterize themselves by placing crypto assets like Bitcoin and Ethereum directly onto their balance sheets as core corporate reserves to attract investor attention and boost share prices. The initial report by The Information indicates that while Nasdaq hasn’t issued an official statement, internal sources have confirmed ongoing reviews. Following the news, several DAT-concept stocks faced immediate selling pressure: MicroStrategy (MSTR) fell 3.5%, Bitmine Immersion (BMNR) plunged 8.7%, and SharpLink Gaming (SBET) dropped 9%. DAT Model and Capital Cycle Pioneered by Michael Saylor’s MicroStrategy (now Strategy Inc.) starting in 2020, the DAT model established the narrative of a ‘corporate treasury = Bitcoin asset pool.’ In 2025, SharpLink Gaming and Bitmine announced increased Ethereum holdings, further fueling market interest in this reserve model. The operational logic for DATs is clear: actively and publicly incorporate digital assets into reserves and leverage capital market tools to amplify influence. For traditional institutional investors constrained by custody and compliance challenges—such as pension funds, sovereign wealth funds, and university endowments—DAT stocks provide a regulated, equity-based exposure to crypto assets, an alternative beyond the limited options of BTC and ETH ETFs. Unlike passive ETFs, DATs are active entities whose management must continuously make critical decisions on timing, financing methods (equity or debt), and asset management strategies. This active role makes DATs both amplifiers and sources of risk. The core driver is a financing mechanism: issuing stock or convertible bonds at high share prices to raise capital for further crypto acquisitions, creating a self-reinforcing ‘capital flywheel’ effect. However, this cycle is bidirectional and can accelerate a downturn if market confidence wanes. At Bitcoin Asia 2025, Dr. Xiao Feng, Chairman and CEO of HashKey Group, suggested that DATs might represent the optimal method for moving crypto assets on-chain to off-chain, citing advantages over ETFs including stronger liquidity, higher price elasticity, more reasonable leverage design, and inherent downside protection mechanisms. From a Net Asset Value (NAV) perspective, the rush into this model is understandable. For the top 20 NAV-ranked companies, the value of their digital asset holdings often constitutes 70-80% of their market capitalization, sometimes exceeding it, as seen with Twenty One. This indicates that once a company’s ‘treasury’ is filled with crypto, its stock price becomes highly correlated with the crypto market, potentially even trading at a premium. Nasdaq’s Regulatory Concerns Nasdaq’s primary motivations for tighter oversight are concerns over potential market manipulation and investor misinformation. Since 2025, numerous companies have seen their stock prices surge after announcing crypto reserve plans, only to experience sharp volatility and subsequent declines post-announcement, posing significant risks to investors. For instance, SharpLink Gaming’s stock skyrocketed from $3 to $124—a 40-fold increase—after announcing ETH acquisitions, before cooling to around $9 and currently trading near $14. Nasdaq’s concerns focus on two areas: 1. Artificial Inflation Risk: Companies might use complex structures or target smaller, illiquid tokens for accumulation, potentially creating price bubbles. 2. Investor Protection: Shareholders may not fully understand the risks inherent in the company’s asset structure, while stock prices are inflated based on the ‘coin储备’ narrative. Consequently, Nasdaq is proposing two core review measures: – Mandatory Shareholder Approval: Requiring shareholder votes for certain stock issuances intended for crypto purchases, increasing the decision threshold and preventing board-driven high-risk investments. – Enhanced Disclosure Requirements: Mandating detailed reporting on crypto holdings, investment strategies, potential risks (e.g., market volatility), and fund usage. Nasdaq will subject companies frequently trading crypto to special scrutiny. Varying Impact by Asset Class The crucial question is how this regulatory tightening will affect the DAT model for different crypto assets. Analysis suggests that while increased oversight may generally slow institutional adoption and reduce corporate reserve demand, thereby exerting negative pressure on crypto prices and market dynamics, the impact will vary significantly based on an asset’s maturity, market dominance, and the size of the DAT companies involved. Data from Blockworks indicates that DAT company holdings are predominantly concentrated in BTC, followed by the recently rising ETH, with other crypto assets representing much smaller portions. – Bitcoin (BTC): As the crypto market’s ‘gold standard,’ Bitcoin’s reserve status is nearly institutionalized. MicroStrategy alone holds over $72 billion in Bitcoin, creating a powerful demonstration effect. Even with stricter disclosure or shareholder vote procedures from Nasdaq, BTC’s core position remains solid. For BTC, regulation implies ‘additional compliance costs’ rather than ‘existential risk.’ – Ethereum (ETH): Ethereum is increasingly becoming the most active reserve asset for DAT companies, exemplified by the ‘arms race’ between Bitmine and SharpLink, which have established themselves as stable buyers, solidifying a top-two hierarchy. Both companies have responded swiftly to Nasdaq’s potential requirements, asserting that their existing financing mechanisms (e.g., ATM programs) are already registered and compliant, potentially exempting them from needing new shareholder approvals for specific crypto purchases. While enhanced regulation may temporarily slow their financing and acquisition pace by adding friction through shareholder approval and disclosure processes, it is more likely to prompt more robust and transparent strategies rather than alter the fundamental logic of ETH reserves. – Solana (SOL): The DAT ecosystem for SOL is still in its early stages. Data from StrategicSolanaReserve.org shows only 13 related companies with total assets of $1.96 billion, nearly a quarter held by Sharps Technology, Inc. This pales in comparison to the hundred-billion-dollar scale of BTC and ETH reserves. However, competition is heating up as a promising infrastructure project, with several companies recently announcing intentions to join the ‘SOL reserve’ camp. This combination of small scale and intense competition means SOL treasury companies are more vulnerable under regulatory scrutiny. Shareholder votes, disclosure demands, and high capital market volatility could become significant pressure points for their survival. In other words, the magnifying effect of regulation might lead to an ‘elimination-style differentiation’ for the SOL DAT model in its infancy, making truly successful leading companies even scarcer. In conclusion, regulatory tightening will not affect all assets equally. BTC is nearly ‘regulation-resistant,’ ETH faces constraints but maintains stable underlying demand, while SOL is most susceptible to structural impact. This suggests that as DATs become increasingly institutionalized, the advantages of leading companies and mainstream assets will likely be further reinforced, while marginal assets face greater survival pressure. Regulation is not merely an external constraint but also an ‘acceleration of differentiation,’ pushing the market structure towards a clearer hierarchy.