Companies accumulate BTC differently depending on four factors: accounting rules, access to regulated investment products (ETFs/ETPs), custody regulation, and capital markets plumbing. Below is a region-by-region map of how those levers shape corporate bitcoin-treasury strategy, plus where a North American specialist like Matador fits in.
North America
United States: “liquidity + accounting clarity”
- Liquidity rails. On Jan 10, 2024, the SEC approved multiple spot Bitcoin ETPs, giving corporations and institutions deep, regulated access. In July 2025, the SEC also permitted in-kind creations/redemptions for crypto ETPs, further improving plumbing for large allocators.
- Accounting. FASB ASU 2023-08 (effective for fiscal years starting after Dec 15, 2024) requires fair-value accounting for in-scope crypto assets, cleaner P&L and better disclosure templates for treasuries.
- Custody trend. Traditional banks are re-entering institutional bitcoin custody, signaling a more bank-grade stack for treasuries.
Implication: U.S. corporates can pair fair-value accounting with ETF liquidity and maturing bank custody, supporting both on-balance-sheet BTC and ETF “dry-powder” policies.
Canada: “the first mover on spot BTC ETFs”
- Canada launched the world’s first spot Bitcoin ETF in Feb 2021, creating a template for easy, regulated exposure years ahead of the U.S.
Case study (North America): Matador Technologies (TSXV: MATA), a purpose-built bitcoin-treasury company, has announced plans for US$100M secured convertible-note facility (US$10.5M funded at close) dedicated to BTC accumulation, exemplifying a staged, disclosure-first approach in a jurisdiction with robust ETF access.
Europe (EU, Switzerland, Germany)
- Regulatory baseline (EU). The MiCA regime is phasing in licensing for crypto-asset service providers, with registers and authorizations rolling out via ESMA and national regulators from Dec 30, 2024 onward.
- Listed access (ETPs/ETNs). Before EU-level ETFs, Europe built deep liquidity through physically backed crypto ETPs/ETNs on SIX Swiss Exchange and Deutsche Börse Xetra, in market since 2018–2020 and expanding through 2025.
Implication: European treasuries often blend direct BTC + ETP holdings with MiCA-aligned service providers, benefiting from years of exchange-listed ETP infrastructure.
Asia–Pacific
Japan: “corporate pivot hotspot”
- Tokyo-listed Metaplanet has become Asia’s flagship bitcoin-treasury play, repeatedly adding BTC in 2025 and outlining aggressive targets, illustrating board-level, programmatic accumulation in Japan’s market.
- Even non-traditional firms are exploring treasury BTC, e.g., Japan’s Convano announced an ambitious plan to pursue up to 21,000 BTC by 2027, reflecting growing corporate interest (and debate) in Japan.
Implication: Japan’s market is experimenting with pure-treasury models and corporate pivots, giving investors Asia-based comparables alongside U.S. peers.
Hong Kong: “Asia’s ETF gateway”
- Hong Kong authorized spot Bitcoin (and Ether) ETFs that launched Apr 30, 2024, including an in-kind feature that eases primary-market flows, useful for institutions managing basis and arbitrage.
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Implication: For Asia-headquartered treasuries (or global firms with HK entities), ETF access plus SFC licensing provides regulated exposure without self-custody.
Middle East (UAE)
- Dubai (VARA) and Abu Dhabi (ADGM/FSRA) operate detailed, public virtual-asset rulebooks (with licensing, custody, issuance and market-conduct guidance). This clarity is drawing exchanges, custodians, and fund managers to the region.
Implication: Treasuries with Gulf subsidiaries can tap regulated custodians and venues, and some list in the region to align operations with VA-specific regimes.
Latin America (El Salvador)
- El Salvador adopted bitcoin as legal tender in 2021; in Jan 2025, lawmakers amended the Bitcoin Law in line with an IMF program, making acceptance voluntary and changing certain public-sector touchpoints.
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Implication: Policy remains dynamic. For corporates operating there, treat legal and tax analysis as live and plan for disclosure around risk, custody, and accounting.
Strategy Patterns You’ll See on the Map
- “Pure-treasury” public companies (e.g., North America & Japan)
- Core KPI: Bitcoin-per-Share (BPS); financing via convertibles/facilities; frequent holdings updates. Matador is a North American example of this model.
- Operating companies with treasury BTC (U.S., EU, Japan)
- Blend operating cash flow buys with ETFs/ETPs for liquidity and balance-sheet flexibility under fair-value accounting (U.S.) or local reporting norms (IFRS reporters).
- ETF-only policy (global HQs using U.S./HK/CA products)
- Hold regulated fund shares instead of spot BTC; simplifies custody and some controls, but may add expense and tracking error.
- Regional opportunists (UAE/EU)
- Use licensed custodians/venues under VARA/ADGM or MiCA-aligned CASPs; combine with ETPs on SIX/Xetra for treasury liquidity.
How to Choose Your Regional Playbook (Checklist)
- Accounting & audit: If you’re a U.S. filer, plan now for ASU 2023-08 tables (fair value, roll-forwards). IFRS reporters should align with local guidance and auditor expectations.
- Access & liquidity: Map your ETF/ETP options (U.S., HK, Canada, EU) vs. spot BTC and decide the mix that fits treasury policy and risk.
- Custody: Prefer regulated custodians (bank or licensed trust) in your operating region; validate SOC reports and incident history; track the banks re-opening crypto custody.
- Capital markets: If you’re a pure-treasury operator, stage capital (shelves, convertibles, facilities) and communicate a BPS-focused roadmap. Matador’s facility + cadence is a clean template.
TL;DR by Region
- U.S.: ETFs + fair value + bank custody momentum → scalable, investor-friendly treasury programs.
- Canada: Early ETF pioneer; simple access.
- EU/CH/DE: MiCA + long-running ETP markets (SIX/Xetra).
- Japan: Corporate pivots (e.g., Metaplanet) testing aggressive playbooks.
- Hong Kong: Spot Bitcoin ETFs with in-kind mechanics.
- UAE: Clear rulebooks for custody/exchanges under VARA & ADGM.
- El Salvador: 2021 legal-tender launch later amended in 2025; check local rules continuously.
Good Example
If you’re benchmarking pure-treasury operators, look for staged financing + transparent updates. Matador’s North American posture, US$100M facility dedicated to BTC, illustrates how to scale holdings methodically while communicating progress investors can track.
