Opinion by: Abdul Rafay Gadit, co-founder at Zignaly and ZIGChain
Digital asset treasury companies (DATCOs) face a classification problem the market can no longer ignore. Built to hold crypto, many are now deciding whether to own assets passively or operate the systems those assets run on. Index providers and regulators are debating whether these firms remain operating companies or have become investment vehicles.
The original DATCO model was simple: hold Bitcoin, signal long-term conviction, and let balance-sheet exposure do the work. That simplicity suited boards, auditors and index providers because outcomes tracked macro forces rather than execution risk. Now that model is fracturing.
Industry participants label the change “active treasury management,” but the term understates the new risks. Moving beyond passive exposure to pursue yield—by rotating tokens, staking, or running infrastructure—introduces leverage, correlated tail risk and governance complexity. Reports show some treasuries expanding beyond Bitcoin and Ether into more volatile tokens to boost returns. While that may improve short-term performance optics, it steepens tail risk: in stressed markets these positions can unwind quickly and in correlated ways, precisely when liquidity is weakest.
More consequentially, some DATCOs are shifting from asset holders to infrastructure participants by running validator nodes and engaging in protocol governance. That work is about reliability, control and system participation; any yield is incidental. But validator operations carry protocol-level obligations that boards cannot treat as peripheral: slashing risk, uptime guarantees, key management, client concentration and governance decisions are operational business risks. These exposures bring liability and reputational risk that passive holding never did.
Once a DATCO takes on protocol responsibilities, it is exposed not only to market volatility but to operational failure and protocol outcomes. That leaves two coherent identities: an operating company with formal controls, or a fiduciary-style fund. The real danger is occupying the space between—claiming the upside of active operations without the governance, controls and accountability those operations demand.
If DATCOs want to avoid being treated as unregulated investment vehicles, they must adopt fund-grade guardrails. That includes clear disclosures of strategy and risk, segregation of custody, execution and oversight, independent controls, audit-ready reporting and stress testing that models correlated drawdowns and protocol-level failures—not just price swings. Boards must formally recognize protocol exposure and governance influence as core risks, not experimental upside.
Addressing this also requires infrastructure improvements. Legacy systems were not designed to combine tokenized assets, staking income and compliance obligations under one mandate. Ad hoc wallets, spreadsheets and loosely governed smart contracts are inadequate. Institutional on-chain rails must support delegated execution, policy-driven controls and auditable workflows so DATCOs can operate at scale without amplifying systemic risk. In active treasury models, operational and market risk are inseparable and must be treated with equal seriousness.
The MSCI consultation over how to classify digital asset treasury companies signals that the easy phase is over. As DATCOs evolve from passive holders into active operators, the market will demand clarity about what these companies are and what risks they are taking. Those that chase yield without guardrails may find that classification was the least of their problems—by the time the market reacts, the risks will already be embedded.
