The shift of Strategy (formerly MicroStrategy) from being an enterprise software firm selling business intelligence tools to a corporate owner of bitcoin when they first purchased in August 2020 around USD$250 million of Bitcoin (BTC) to hold in its treasury, has caught on, it seems, on this side of the pond.
Initially this strategy was limited to Strategy and Tesla among a few other well-known US publicly listed companies but now it has spread globally and here in the UK it is gaining traction as a treasury strategy for publicly listed companies. It only takes a brief review of BitcoinTeasuries.net to see the 60 biggest publicly listed companies with BTC in their treasury. This ranges from Strategy which holds circa 597,000 BTC (second place holding a “mere” 50,000) and includes companies listed in Japan, Canada, Germany, UK (Smarter Web Company and Phoenix Digital Assets the only UK listed companies to make the list), France and indeed all over the world.
1 This image and data is from BitcoinTreasuries.net and does not belong to Laytons ETL and was accessed on 7 July 2025.
What is a Bitcoin Treasury Strategy?
A Bitcoin treasury strategy involves a company allocating a portion of its treasury reserves into BTC instead of traditional assets like cash or bonds. This approach aims to diversify the company's holdings, hedge against inflation, and potentially enhance capital efficiency – in short there are a variety of reasons why a company might adopt the strategy but these are often the key benefits discussed as they aim to leverage BTC’s potential for long-term value appreciation.
Bitcoin Treasury Strategy in the UK
The interest in the UK has been largely driven by Smarter Web Company Plc (SWC). SWC is a UK based web design company that shortly after its shares were admitted to trading on the Aquis Stock Exchange in April 2025 formerly adopted a 10 year plan which included the adoption of a BTC treasury strategy. Since SWC’s admission to trading at market capitalisation of approximately £3.7 million it has seen its share price explode and its market capitalisation blow past £1 billion (circa 200x) within approximately 2 months from admission to trading (sitting at a current share price of approximately £3.00 and market capitalisation of approximately £733 million at the time of writing). SWC currently now holds 1000 BTC with plans to continue growing their BTC holdings through their treasury strategy.
They are not the first or only listed company in the UK to hold BTC or cryptocurrencies, but they are by and far the most well-known and the UK pioneer of promoting and adopting a BTC treasury strategy. Since SWC’s announcements there have been more than 8 other companies that we have anecdotally seen adopting a BTC/cryptocurrency treasury strategy.
It appears that UK capital market stakeholders have been largely supportive of the benefits that have flowed into the market with the adoption of BTC treasury strategies, including investor interest and liquidity of share trading but time will tell whether ultimately BTC treasury become a long-term mainstay of UK capital markets.
Regulatory Considerations and Risks
A BTC treasury strategy may not be for everyone and ultimately listed companies need to consider whether it makes sense for their business as well as consider the various regulatory considerations. One of the main considerations among these is that BTC and other cryptocurrencies are and remain unregulated meaning therefore they don’t fall under the same legal protections as traditional financial assets. This can mean in the event that something does go wrong there is little recourse and generally investors in cryptocurrency have no protection - the UK Financial Conduct Authority consider investment in BTC/cryptocurrencies as high risk.
While these are not the only risks we think the key risks to consider for listed companies to consider are:
Regulation - As discussed, BTC and cryptocurrencies are unregulated in the UK. Therefore, there is increased risk of loss from events and/or bad actors related to cyber-attacks, financial crime and counterparty failure;
Complete Loss of Investment - BTC and cryptocurrencies are highly volatile assets, and any investor can and should be prepared to lose any and all investment made;
Liquidity – the ability to be able to sell/convert any BTC/cryptocurrency into cash will depend on various different factors such as supply and demand and could even be affected by other various technological delays and particularly delay could be caused as due to ‘custody’ of BTC/the cryptocurrency. Most listed companies often hold their BTC via a third party provider in an offline cold multi-signature wallet – the process to transfer the BTC to be able to access payment rails to convert it into £ or $ will not be instantaneous (more on custody below).
As mentioned above these are not the only risks or considerations for companies particularly from a regulatory perspective as listed companies will also need to consider their legal and regulatory obligations as a listed company.
How do Listed Companies Actually ‘Hold’ Bitcoin
BTC is a decentralized cryptographically secure digital currency that allows for peer-to-peer transactions without the need for intermediaries like banks or governments and operates on technology called a blockchain, how exactly do listed companies ‘hold’ their BTC?
Listed companies typically do not actually hold or physically custody their own BTC. Rather than holding BTC in an account with a cryptocurrency exchange (think Kraken or Coinbase) or in their own created ‘hot’ or ‘cold’ wallet they use specialist third-party custodial service providers to secure their BTC and these providers employ institutional grade security which can include, offline cold wallet storage, use of multi-signature wallets (meaning transfer in and out of the wallet requires minimum 2 separate people to sign off) and insurance. Some well-known providers include Coinbase Custody, BitGo and Fidelity Digital Assets. By using these type of custodial service providers listed companies seek to reduce some of the risks detailed above.
A ‘cold’ wallet as opposed to a ‘hot’ is whether, for example, a company’s BTC is held in a ‘hot’ wallet where the cryptocurrency is actively connected to the internet as this makes it easy and convenient for transactions but conversely potentially more vulnerable to online threats. An offline ‘cold’ wallet is where the wallet is kept unconnected to the internet (think of this as being stored in a USB that is password protected and stored somewhere) meaning it is less susceptible to hacking and online threats, but this means the transfer or sale of assets is more difficult and time consuming.
Accordingly, it’s clear why some listed companies particularly from a risk perspective will choose to custody their BTC with a third party custodial provider but then they also need to consider access to capital/ability to sell BTC if needed when bringing in a BTC treasury strategy.
How Can Laytons Help?
The Laytons’ Equity Capital Markets and Regulatory teams are experienced in advising and assisting listed companies including the regulatory issues discussed in this article. If you have any questions on the matters discussed in this article or if you need further guidance, then please get in touch with us to discuss things further.
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Disclaimer: This publication is provided by Laytons LLP for informational purposes only. The information contained in this publication should not be construed as legal or financial advice. Any questions or further information regarding the matters discussed in this publication can be directed to your regular contact at Laytons LLP or Laytons’ ECM team or to your own financial adviser.