Banks add rails to serve 13.9M BTC they don’t own

Twenty-five banks earned a composite score of 32% on Strategy’s Bitcoin Banking Adoption Index after building custody, trading, lending and investment services. The index measures how far those institutions have developed the systems and products needed to offer Bitcoin services; it does not measure whether banks own the coins.

Bitwise’s Q3 2026 Crypto Market Review estimates individuals control 66.1% of Bitcoin’s 21-million maximum supply, about 13.9 million BTC. Businesses hold roughly 7.8% and funds and ETFs about 7.2%, a combined institutional share near 15% or about 3.15 million BTC.

Strategy’s index scores depth of infrastructure across five categories: custody systems, trading desks that execute orders, investment products, lending programs and public leadership support. A higher score indicates a bank has built more of the plumbing to custody, trade, lend against and package Bitcoin for clients; the index does not assign ownership of users’ coins to the banks.

Banks are adding custody and trading infrastructure after retail holders accumulated significant Bitcoin holdings. Exchanges, specialist custodians and self-custody tools currently serve many individual holders; banks are building services to provide alternative custody, trading and lending channels to those same customers.

A bank can provide custody, execute trades and administer collateral without becoming the beneficial owner of the assets. Customer rights and protections depend on the specific custody, brokerage or lending agreements, including terms on rehypothecation, collateral use and withdrawal rights. If bitcoins move onto bank-controlled rails, banks would hold the coins on their infrastructure while contractual terms determine whether customers remain the beneficial owners.

If 10% of the 13.9 million BTC attributed to individuals moved into bank-controlled custody or brokerage accounts, roughly 1.39 million BTC would sit on bank-run infrastructure. At 25%, about 3.47 million BTC; at 50%, roughly 6.94 million BTC. In each case, legal ownership and access rights would be set by the applicable customer agreements.

Recent regulatory and accounting changes have affected banks’ ability to offer crypto services. The SEC rescinded SAB 121. The Federal Reserve removed a special advance-notice requirement for state member banks’ crypto activities and folded those reviews into ordinary supervision. The Office of the Comptroller of the Currency has said national banks may buy and sell crypto assets held in custody at a customer’s direction. The Basel Committee’s disclosure framework for bank crypto-asset exposures took effect Jan. 1, 2026, and calls for qualitative and quantitative reporting by internationally active banks in implementing jurisdictions.

Banks can offer loans collateralized by Bitcoin, where holders borrow against their coins while retaining price exposure and banks collect lending fees. Operational problems such as custody outages, withdrawal limits, fees or counterparty risk may lead some holders to remain in self-custody or on crypto-native platforms. Banks are also handling flows into regulated Bitcoin wrappers such as ETFs while developing direct custody and lending services to serve existing individual holders.