Bitcoin For Corporations urges JPX to drop crypto-asset exclusion from TOPIX

JPXI’s April 3, 2026 consultation does not propose a specific numerical threshold. Instead, it says that, “for the time being,” companies whose principal asset is cryptoassets would be deferred from new inclusion in TOPIX and other periodically reviewed indices. The consultation also states that the proposal would not apply to companies already included in the index.

BFC opposes the proposal, arguing that it is not a true investability rule. The group said TOPIX already has objective criteria designed to protect investability and stability, including liquidity screens, free-float-adjusted market capitalization requirements, continuation buffers, and existing rules for delistings and other listing-quality events.

According to BFC, the proposed crypto-asset exclusion does not measure liquidity, free float, replicability, or listing quality. Instead, it would exclude companies based on the composition of their balance sheet.

TOPIX is meant to be a broad, neutral, investable benchmark of the Japanese equity market. If a company satisfies the ordinary market-based eligibility standards, excluding it because of one asset category is not a normal investability screen. It is a policy judgment about one asset class, and it does not belong in the methodology of a flagship market benchmark,

said George Mekhail, Managing Director of Bitcoin For Corporations.

BFC said the proposal raises four core concerns.

1. It is not a proper investability rule. The consultation is framed in the language of investability and stability, but the proposed exclusion does not address the criteria that normally determine whether a stock belongs in a broad market index: liquidity, free float, market capitalization, and listing quality. It introduces an asset-specific screen into a benchmark that already has objective eligibility rules.
2. It is too vague to administer coherently. The consultation refers to companies whose “principal asset is cryptoassets,” but does not explain how that standard would be applied in practice. It does not say whether the test would be based on parent-company holdings or consolidated holdings, whether it would look through subsidiaries or affiliates, or whether indirect exposure through securities or similar instruments would be captured. A rule that cannot be applied clearly and consistently should not be inserted into a flagship benchmark.
3. It creates obvious form-over-substance arbitrage. If direct Bitcoin holdings by a parent company are disfavored, but equivalent exposure through a wholly owned subsidiary, an affiliated company, or a strategic equity position is not, then the rule is targeting legal form rather than economic substance. That would encourage balance-sheet engineering rather than improve index quality.
4. It is preemptive and open-ended. October 2026 will be the first periodic review under the next-generation TOPIX framework, in which Standard and Growth market companies can become eligible through the new process. Yet JPX is proposing to exclude a category of companies before they have even been assessed under the ordinary criteria. At the same time, the consultation says the exclusion would apply “for the time being,” without setting out a clear review period, exit standard, or sunset mechanism. That is not a disciplined framework. It is an indefinite deferral with uncertain boundaries.

BFC also noted that major global index providers have treated this issue with greater caution. MSCI considered a threshold-based exclusion for digital-asset treasury companies and ultimately did not adopt a blanket exclusion, instead acknowledging the need for further work to distinguish operating companies from non-operating or investment-like entities. FTSE Russell has not announced a comparable blanket exclusion. In BFC’s view, JPX should show the same restraint rather than moving ahead with a crypto-only exclusion before a broader principle has been defined.

More broadly, BFC said the issue extends to the neutrality, credibility, and representativeness of Japan’s flagship equity benchmark.

“If JPX believes there is a broader question about highly concentrated or investment-like companies, then an asset-neutral framework applied consistently, would be more appropriate.” Mekhail said. “Singling out one asset class by introducing a vague rule that is easy to evade and difficult to administer would be unprecedented and untethered from TOPIX’s actual investability criteria.”

Bitcoin For Corporations and participating market participants are calling on JPXI to:

• Withdraw the proposed exclusion for companies whose principal asset is cryptoassets
• Preserve TOPIX as a neutral, broad, rules-based benchmark tied to objective investability and listing-quality standards
• Refrain from adopting an open-ended deferral without a clear review process, exit standard, or sunset mechanism
• Engage with issuers and market participants on any broader, asset-neutral framework before changing TOPIX methodology

Organizations and individual investors may review the full position letter and add their signatures at: topix.bitcoinforcorporations.com

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