An examination of the rationale behind the proposed deferral, which appears misaligned with the rules-based nature of the benchmark, and a suggestion for a more strategic approach.

JPX Market Innovation & Research (JPXI) is currently evaluating a new regulation that would defer the inclusion of companies whose primary asset consists of cryptoassets in TOPIX and other periodically reviewed indices. While the tone of the proposal is considered, the underlying concern regarding the categorization of this emerging class of issuers is a reasonable consideration for any index provider.

Nevertheless, the specific rule under review raises significant issues. It would impact companies such as Metaplanet, Remixpoint, and ANAP Holdings, along with an expanding group of Japanese issuers whose business models are legitimate, fully regulated, and well-aligned with established corporate treasury practices.

Below are seven compelling reasons for JPXI to reconsider the proposal before February 2026.

1. The Rule Diverges from Traditional TOPIX Metrics

TOPIX is established to serve as a broad, neutral, and investable benchmark for the Japanese equity market. Its existing methodology already incorporates objective criteria such as liquidity screens, free-float-adjusted market capitalization, continuation buffers, and set procedures for delistings and other quality listing events.

The proposed crypto-asset screening introduces an entirely different evaluative measure, focusing on the composition of a company’s balance sheet rather than standard metrics like liquidity or market capitalization. This marks a substantial departure from the historical criteria for TOPIX eligibility, necessitating a more robust justification than what the current consultation provides. If a company meets the existing eligibility criteria, deferring its inclusion based solely on one asset type undermines the methodology’s valued objectivity.

2. A Clear Definition of “Principal Asset Is Cryptoassets” Is Required

The consultation references companies with a “principal asset” in cryptoassets but leaves critical administrative questions unresolved:

• Is the evaluation based on parent-only holdings or consolidated holdings?
• Will exposure through wholly owned subsidiaries, affiliated companies, or strategic equity stakes be considered?
• Will indirect exposure through securities, derivatives, or similar instruments be included?
• Is the inquiry strictly formal (legal title) or substantive (economic exposure)?

These inquiries are not marginal; they determine the applicability of the rule. Index methodology derives its credibility from established, objective, and measurable rules. A clearer definition would benefit issuers, investors, and JPXI alike.

3. The Rule May Facilitate Avoidance Rather Than Compliance

A practical concern arises from the definitional ambiguity. If holding Bitcoin directly is discouraged but equivalent exposure through alternative structures is not, the rule could become overly focused on legal form rather than economic substance.

Consider the following asymmetries:

• A direct Bitcoin holding would trigger the rule.
• Investment in the iShares Bitcoin Trust ETF (IBIT) would likely not.
• Investment in a publicly traded Bitcoin miner would likely be exempt.
• A stake in a crypto-linked subsidiary would likely escape scrutiny.

The economic exposure in these scenarios could be quite analogous, yet the index treatment would differ significantly. This creates an incentive for issuers to restructure toward less transparent forms of exposure instead of disclosing direct holdings. Generally, a benchmark rule is more effective when it promotes transparency rather than obscurity.

4. The Carve-Out for Existing Constituents Introduces Internal Inconsistency

The consultation envisions a deferral for new inclusions while exempting existing constituents from the rule. While this approach may be perceived as stabilizing – to avoid unnecessary index turnover – it also introduces logical inconsistency. If Bitcoin treasury exposure is indeed incompatible with TOPIX, justifying the exemption for current members becomes problematic. Conversely, if such exposure is not truly incompatible, it raises the question of why new entrants meeting identical investability criteria should be treated differently.

Reconciling this inconsistency would significantly strengthen the proposal.

5. “For the Time Being” Creates an Open-Ended Timeline

The consultation states the deferral applies “for the time being,” lacking clarity on review timelines, exit standards, or sunset provisions. Consequently, this renders the timeline ambiguous.

Timing is critical; the first periodic review under the next-generation TOPIX framework will occur in October 2026, at which point Standard and Growth market companies could become eligible through a new process. A deferral that coincides with this review, without a defined path towards eligibility, may effectively function as a prolonged exclusion, despite not being articulated as such.

Establishing a clearer review timeline or an explicit sunset provision would facilitate a better evaluation of the proposal’s merits.

6. Global Peers Are Undertaking Comprehensive Reviews on Similar Issues

JPXI is not alone in its deliberation. MSCI has recently considered a threshold-based approach for digital-asset treasury companies and opted against an outright exclusion, recognizing the necessity for further differentiation between operating companies and non-operating or investment-like entities. FTSE Russell has yet to introduce a comparable rule.

The overarching theme is that the classification issues are far from settled. Operating companies that hold Bitcoin alongside traditional business lines—such as media, energy, retail, mining, and infrastructure—do not align neatly with existing classifications, and the global index community continues to explore these complexities.

Therefore, it would be prudent for JPXI to engage further with issuers and market participants before formalizing the rule, rather than proceeding in advance of a broader consensus.

7. An Asset-Neutral Framework Would Offer Greater Durability

If the fundamental concern is that various listed companies have become overly concentrated or investment-like, it is crucial to address this issue; however, it is not exclusive to cryptoassets. Concentrated holdings can manifest in numerous forms: listed equities, stakes in private companies, fund interests, real estate, or other non-operating assets.

A regulatory framework consistently applicable across various categories would likely be more robust than a singular asset-based rule. It would also mitigate the definitional and avoidance challenges previously discussed, as the focus would shift to the economic characteristics that JPXI is genuinely concerned about, rather than restricting it to one specific asset class.

Possible approaches could include:

• Enhanced disclosure standards for concentrated treasury positions of any asset class, providing investors with clarity without altering index composition.
• An asset-neutral concentration framework that applies the same evaluation to all non-operating assets held above a defined threshold.
• An optional index variant for investors wishing to exclude cryptoasset-heavy companies from their exposure, to be offered alongside, rather than instead of, the primary benchmark.

The Current Status of the Proposal

This commentary does not suggest that JPXI’s efforts to thoughtfully engage with this new category of issuer are misguided. On the contrary, the emergence of Bitcoin treasury companies and their rapid growth in Japan necessitates serious consideration of their treatment within the index.

However, the specifics of the proposed rule are currently more restrictive, ambiguous, and open-ended than the questions it aims to address. A clearer definition, a defined review timeline, and an asset-neutral approach would significantly mitigate underlying concerns while preserving TOPIX’s esteemed reputation as a trusted benchmark characterized by objective, rules-based eligibility reflecting the reality of the Japanese equity market.

This recommended approach emphasizes substance over form, clarity over ambiguity, and neutrality across asset classes—a more robust path forward.

Support for the Coalition

Bitcoin For Corporations has initiated a coalition letter advocating for JPXI to withdraw the proposed exclusion and maintain TOPIX as a neutral, rules-based benchmark. The public comment period concludes May 7, 2026, and each signature strengthens the assertion that this issue is critical for issuers, investors, and market participants globally.

If these arguments resonate, individuals and organizations from all jurisdictions are encouraged to add their names to the letter.

→ Sign the coalition letter at topix.bitcoinforcorporations.com

Additionally, the full position letter can be reviewed, along with details on existing signatories and sharing options for the campaign. The deadline is firm, and the opportunity to influence JPXI’s final decision is limited.

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