Nasdaq Plans to Strengthen Scrutiny, DAT Flywheel Hits the Brakes?

  • 2025-09-06

 

A regulatory announcement has suddenly cooled the recently heated trend of crypto stocks. Recently, news emerged that Nasdaq will enhance its scrutiny of listed companies holding cryptocurrencies, putting pressure on the stock prices of DAT (Digital Asset Treasury) companies. Many premium mNAV ratios have fallen "underwater" amid the sentiment reversal, and the once rapidly spinning treasury flywheel may soon slow down.

Nasdaq Steps In, Pressuring U.S. DAT Stock Prices and Premium Ratios

On September 4, citing informed sources, The Information reported that Nasdaq is strengthening its scrutiny of listed companies, focusing on those that raise funds to purchase and hoard cryptocurrencies to boost their stock prices.

As the exchange hosting the vast majority of crypto stock trades, Nasdaq believes such practices could mislead investors and has therefore decided to increase regulatory oversight. Specific measures have not yet been disclosed, but it is expected that relevant companies will be required to disclose investment scale, strategies, and potential risks, with special scrutiny applied to firms frequently trading crypto assets. If companies fail to comply, the exchange may take measures such as suspending trading or delisting.

In practice, U.S.-listed companies dominate the DAT space. According to data from consulting firm Architect Partners, at least 154 U.S. listed companies have participated in purchasing cryptocurrencies since January this year. Meanwhile, data from Bitcointreasuries tracking Bitcoin-held listed companies shows 61 such companies in the U.S. stock market, far exceeding numbers in Canada, the U.K., Japan, and other markets. Once Nasdaq takes action, the overall development of the DAT market will face significant impact.

With the news of Nasdaq’s heightened scrutiny, market confidence is already wavering. Stock prices of DAT-type companies in the U.S. are generally under pressure. For example, after today’s market opening, MSTR fell 0.81%, SBET dropped 8.26%, and BTCS declined 2.3%.

At the same time, mNAV (market value to net asset value ratio) is also declining across the board. Blockworks data shows that as of September 4, for instance, MSTR’s mNAV dropped from a peak of 3.5x to 1.3x, SBET fell from 3.72x to 0.82x, and BMNR declined from 9.45x to 0.88x. Notably, only six DAT companies have an mNAV above 1, while the rest continue to trade at negative premiums. The reservoir effect previously reliant on crypto asset appreciation is further weakening.

Tighter Regulations May Intensify Market Divergence, Marginal Coins Face Survival Pressure

With regulatory pressure looming, the DAT market landscape may undergo significant changes.

On one hand, strengthened regulations will push DAT companies toward greater transparency and caution in their crypto asset investment strategies, helping to reduce risks such as potential market manipulation and insider trading. According to Fortune, several listed crypto treasury companies have experienced abnormal stock price fluctuations. For example, SharpLink’s stock price hovered below $3 in April and early May but surged to nearly $36 on May 27 after announcing plans to increase its Ethereum reserve assets by $425 million. However, in the three trading days before the announcement, SharpLink’s stock price had already doubled from $3 to $6, yet the company did not file relevant documents with the SEC or issue a press release. Similar situations have occurred with companies like Mill City Ventures, MEI Pharma, Kindly MD, Empery Digital, Fundamental Global, and 180 Life Sciences Corp.

On the other hand, the head effect in the DAT market will become more pronounced. Although crypto treasury strategies are increasingly popular, covering assets such as Bitcoin, Ethereum, Solana, Tron, BNB, Chainlink, SUI, and Ethena, Blockworks data shows that as of September 4, the total value of cryptocurrencies held by DAT companies exceeds $69.5 billion, primarily concentrated in Bitcoin and Ethereum, amounting to $68.1 billion. Among these asset types, only Bitcoin’s mNAV reaches 1.17, while all others are below 1, reflecting insufficient investor recognition of other crypto assets.

Moreover, leading companies dominate the majority of the market share. Blockworks data indicates that as of September 4, the total market capitalization of crypto treasury companies exceeds $108.48 billion, with Bitcoin and Ethereum reserve leaders Strategy and BitMine contributing over 91.4% of the market share. This suggests that in the future, the advantages of leading companies and mainstream assets may further strengthen, while marginal assets face survival pressure.

Additionally, tighter regulations could slow the overall expansion of the DAT market. If financing costs and difficulties increase for DAT listed companies, it will directly impact investment pacing, i.e., the scale and speed of coin hoarding. Simultaneously, shrinking arbitrage opportunities and market prospects will reduce the appeal of the DAT model, especially for companies with limited financial strength or those focused on single, smaller coins.

“Unless DAT companies in preparation acquire 100% of the shell company’s shares, they must hold a shareholders’ meeting and vote when first announcing the transition to the DAT micro-strategy model. This actually increases the operational costs and cycles for new DAT treasury companies. Already transformed DAT treasury companies must also hold shareholders’ meetings and votes for subsequent stock issuances. Bond or convertible bond issuances, not being new stock issues, are likely exempt from this rule.” Crypto KOL @qinbafrank analyzed that Nasdaq’s move aims to cool the DAT model, increase the difficulty for shell companies to transform, and add steps for already transformed companies to issue new shares. In the short term, this should pour cold water on the market, making it increasingly difficult for many altcoin DAT treasury companies. Those already transformed into DAT treasuries must win shareholder approval and majority votes in shareholders’ meetings, avoiding capital manipulation tactics (such as token-for-share swaps or purchasing discounted tokens).

Liquidity Innovation or Financial Bubble? DAT’s Sustainability Sparks Debate

The escalating trend of DAT has elicited polarized reactions in the market.

Supporters view it as the best bridge for on-chain to off-chain transfer of crypto assets, believing this new model could reshape the liquidity landscape of crypto financial markets. For instance, Xiao Feng, Chairman and CEO of HashKey Group, argues that DAT may be the best way to transfer crypto assets from on-chain to off-chain, elaborating on four core advantages of DAT over ETFs: Better liquidity. ETF subscriptions and redemptions are time-consuming, whereas DAT facilitates more convenient and efficient asset transfers for investors. Higher price elasticity. DAT market caps are more volatile and possess risk isolation properties, providing institutions with more arbitrage tools. More reasonable leverage design. DAT companies offer leveraged financing structures, potentially delivering higher premiums to investors compared to direct crypto price appreciation. Built-in downside protection. When stock prices fall below the net asset value per share, investors gain opportunities to buy Bitcoin or ETFs at a discount, and such discrepancies are quickly corrected by the market.

Furthermore, several crypto VCs are increasing their DAT investments. For example, Pantera Capital disclosed for the first time that it has invested over $300 million in DAT companies. Andrei Grachev, Managing Partner of DWF Labs, recently stated willingness to provide 10–20% of funding for projects promoting token treasuries in U.S. listed companies.

However, many voices question DAT’s sustainability. According to Adam Reeds, Co-founder and CEO of Ledn, digital asset treasury companies obsessed with hoarding coins are at a turning point. Bitcoin treasury companies were once a revolutionary innovation in the industry, but such excess returns are now hard to replicate. What has truly diminished is the ability to create unique value propositions. Most DAT CEOs claim their sole goal is to increase crypto holdings per share, but it remains unknown whether they possess unique management teams or exceptional capital operation capabilities.

Similarly, James Check, Chief Analyst at Glassnode, believes the Bitcoin treasury strategy has a much shorter lifespan than most expect and may already be over for many newcomers. This is not a “measurement contest”; the key lies in a company’s product and strategy sustainability in the long-term Bitcoin market. Moreover, as investors favor early adopters, newly established Bitcoin treasury companies face an uphill battle.

Further doubts arise from judgments about DAT’s financial nature. Nate Geraci, President of The ETF Store, stated that if investors are truly optimistic about Bitcoin and Ethereum, they can directly buy spot or ETFs instead of relying on DAT, a derivative-like alternative. He emphasized that these companies thrive largely on regulatory arbitrage, and as regulatory barriers gradually break down, market demand for them will naturally fade. Analysts at Franklin Templeton warned that if DAT market caps fall below their net asset values, new share issuances would have a dilutive effect, hindering capital formation. If coupled with falling crypto prices, companies might be forced to sell assets to maintain stock prices, further depressing the market and confidence, creating a self-reinforcing downward spiral. Former Goldman Sachs analyst Josip Rupena compared DAT to CDOs (Collateralized Debt Obligations) during the 2007–2008 financial crisis, pointing out that although crypto treasury companies ostensibly hold bearer assets with no counterparty risk, they actually introduce multiple risks, including management capabilities, cybersecurity, and insufficient value creation capabilities. This叠加效应 (superimposed effect) could amplify into systemic risks.

In summary, DAT’s development prospects hinge on whether it can move beyond relying solely on regulatory arbitrage and leverage amplification, instead maintaining market capitalization above net asset value long-term, continuously creating value-added transactions, and establishing effective risk management frameworks to achieve sustainable development.

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