Basel is a set of non-binding international banking standards published by the Basel Committee on Banking Supervision at the Bank for International Settlements. U.S. regulators (Federal Reserve, OCC, FDIC) often adopt or adapt these rules into domestic regulation.

What is a risk weight?

A risk weight is a multiplier that determines how much capital a bank must hold against an asset. A 100% weight means standard treatment; 0% means no capital is required (e.g., U.S. Treasuries, gold); 1,250% is the maximum and effectively requires a bank to hold capital equal to the full value of the position.

Why does Basel assign bitcoin a 1,250% risk weight?

In 2022 the Basel Committee classified all cryptoassets, including bitcoin, in Group 2b — the most punitive bucket — which carries a 1,250% risk weight. Bitcoin Policy Institute argues this treats bitcoin like an opaque securitization tranche when it is actually a transparent, issuerless, globally traded asset whose risks can be measured directly.

Is the rule already in effect in the United States?

No. U.S. regulators have not finalized adoption. The Federal Reserve, OCC, and FDIC are currently accepting public comment on the proposed treatment. Comments close June 18, 2026.

Where do I submit a public comment?

Use the official Federal Reserve comment form at https://www.federalreserve.gov/apps/forms/proposals/FR-2026-0008-01

Will my comment be public?

Yes. Public comments become part of the official rulemaking record and are searchable. Do not include sensitive personal or financial information, account numbers, wallet addresses, or seed phrases.

How long should my comment be?

A short, personal comment is more effective than a long form letter. A few paragraphs that say who you are, why you care, why the 1,250% weight is wrong, and what regulators should do instead is sufficient. Personal language is weighted more heavily than copied form letters.

Who is behind this site?

The Bitcoin Policy Institute (BPI), a nonpartisan research organization. The underlying paper, 'Basel's 1,250% Mistake,' was written by Conner Brown, BPI's Head of Strategy, in February 2026.

Bitcoin Policy Institute

Fix Basel's 1,250% Mistake

Tell the Fed, OCC, and FDIC: Bitcoin deserves risk-based capital treatment, not a blanket penalty that keeps American banks out of Bitcoin.

Submit your public comment to the Federal Reserve (deadline: June 18, 2026)

One number. One massive problem.

1,250% — the risk weight Basel assigned to bitcoin. It is the harshest penalty in the entire banking framework.

The Federal Reserve, the Office of the Comptroller of the Currency, and the Federal Deposit Insurance Corporation are currently accepting public comments on proposed changes to U.S. bank capital rules.

This is a critical opportunity for Bitcoin users, bank customers, entrepreneurs, investors, and concerned citizens to explain why Basel's proposed treatment of Bitcoin is wrong.

Under the Basel cryptoasset framework, Bitcoin receives a harsh 1,250% risk weight. In practice, that means a bank may be required to hold capital equal to the full value of its Bitcoin exposure before additional buffers. That treatment does not make Bitcoin services safer. It makes them economically impractical for regulated banks to offer.

America cannot lead the next generation of financial infrastructure if American banks are effectively blocked from touching the world's largest decentralized digital asset.

What is Basel?

The Basel standards are a non-binding international set of guidelines that recommend how banks should operate. Regulators often rely on these rules to help determine how banks can safely operate and what products and services banks can offer their customers.

Basel includes recommendations for "risk-weight" of assets. This is a rating that determines how inherently risky an asset is. When an asset receives a very high risk weight, banks must take greater precautions by holding significantly more capital against it. That raises costs and can make the activity commercially impossible.

Basel assigns Bitcoin its harshest risk weighting

In 2022, Basel put out standards on how banks should risk weight cryptoassets generally. They assigned all cryptoassets, including Bitcoin, with the harshest rating possible: a 1,250% risk weighting. This rating is harsher than any other asset and more severe than what is assigned to a broad range of opaque and illiquid credit instruments.

Basel risk weights by asset class
Asset	Risk weight
U.S. Dollar (Cash)	0%
Gold	0%
U.S. Treasuries	0%
Corporate Debt (A-rated)	50%
Corporate (Unrated)	100%
Speculative Equity	400%
Bitcoin	1,250%

Placing Bitcoin in this category means that for every dollar of Bitcoin on a bank's balance sheet, banks must fully offset that Bitcoin with another dollar in reserve.

Why this matters

A 1,250% risk weight does not merely affect a bank's internal balance sheet. It determines what services regulated banks can realistically provide.

If Bitcoin activity is made uneconomic for U.S. banks, banks will be deterred from offering custody, settlement, secured lending, treasury services, payment infrastructure, market-making support, hedging tools, and risk-management services for Bitcoin users and businesses.

This pushes Bitcoin activity away from regulated banks and toward less supervised venues, offshore institutions, or fragmented workarounds. That is worse for customers, worse for supervisors, and worse for American leadership.

Basel does not recognize what makes Bitcoin unique

There are plenty of risky instruments in crypto — but Bitcoin is fundamentally different.

Bitcoin has no issuer. It has no borrower. It has no management team. It has no coupon, redemption promise, reserve portfolio, or defaulting counterparty. Bitcoin is an issuerless, decentralized, globally traded capital asset with a transparent supply schedule, public settlement history, open-source validation, and continuous market pricing.

What regulators should do instead

Treat Bitcoin price exposure under appropriate market-risk capital rules.
Apply operational-risk standards to custody, cybersecurity, key management, access controls, and internal governance.
Recognize hedging and risk mitigation where a bank can demonstrate that exposure has been reduced.
Distinguish Bitcoin from issuer-backed tokens, stablecoins, DeFi instruments, and other cryptoassets with materially different risk profiles.

The comment period

The Federal Reserve, OCC, and FDIC are accepting public comments on proposed changes to U.S. capital rules. Comments are due June 18, 2026.

Your comment does not need to be long. It should be respectful, specific, and personal. Do not include private financial information, account details, wallet addresses, seed phrases, or anything confidential.

What to say

Who you are.
Why you care.
Why Basel's 1,250% recommendation is the wrong approach.
What you want the agencies to do instead.

Pick your angle

Bank customer: explain why you would prefer Bitcoin services from a regulated U.S. bank rather than an offshore or less supervised provider.
Business owner: explain how access to banking, custody, treasury, payments, settlement, or risk-management services affects your ability to operate in the United States.
Investor: explain why regulated custody and financial infrastructure matter for consumer protection, market integrity, and responsible access.
American competitiveness: explain why the United States should not force Bitcoin financial infrastructure to develop elsewhere.
Safety and soundness: explain why Bitcoin activity is easier to supervise when it occurs inside regulated banks.

Example comment

Use this as a starting point — but please rewrite in your own words.

Subject: Comment on Bank Capital Treatment of Bitcoin

To the Board of Governors of the Federal Reserve System, the Office of the Comptroller of the Currency, and the Federal Deposit Insurance Corporation:

I am submitting this comment because I believe U.S. bank capital rules should treat Bitcoin according to its actual risks, not through a blanket penalty that makes regulated bank involvement economically impractical.

Bitcoin is not risk-free. It has price volatility, custody risk, cybersecurity risk, liquidity risk, and operational risk. Banks that engage with Bitcoin should be required to manage those risks through strong controls, audited custody standards, prudent inventory limits, appropriate supervision, and robust operational safeguards.

But Bitcoin is fundamentally different from many other cryptoassets. It has no issuer, borrower, management team, coupon, redemption promise, reserve portfolio, or defaulting counterparty. It is not a claim on a company, stablecoin issuer, DeFi protocol, or lending platform.

Bitcoin is an issuerless, decentralized, globally traded capital asset with a transparent supply schedule, public settlement history, open-source validation, and continuous market pricing. Its risks are real, but they are not opaque. They are primarily market, custody, cybersecurity, operational, liquidity, hedging, and concentration risks. Those risks can be measured, supervised, and capitalized directly.

The blanket 1,250% risk weight proposed by Basel is therefore the wrong tool for Bitcoin's actual risk profile. Regulation that lumps Bitcoin together with speculative instruments and opaque credit products fails to distinguish among different assets, different structures, and different risks.

At an 8% minimum capital ratio, a 1,250% risk weight can require capital equal to the full value of a bank's Bitcoin exposure before additional buffers. That treatment does not make banks safer. It prevents regulated banks from offering custody, settlement, secured lending, treasury services, payment infrastructure, market-making support, hedging tools, and client services that Bitcoin users and businesses increasingly need.

I respectfully urge the agencies not to adopt or entrench Basel's blanket 1,250% treatment for Bitcoin. Instead, the agencies should adopt their own risk-sensitive framework that addresses Bitcoin's actual risks through market-risk capital, operational-risk treatment for custody and key management, cybersecurity standards, recognition of hedging, audited custody controls, prudent inventory limits, and graduated concentration limits.

The agencies should also distinguish Bitcoin from issuer-backed tokens, stablecoins, DeFi instruments, and other cryptoassets with materially different risk profiles. Bitcoin should not receive special treatment. It should receive accurate treatment.

A risk-sensitive framework would better protect safety and soundness while allowing Bitcoin-related activity to occur inside regulated, supervised U.S. financial institutions. A blanket penalty would push activity away from regulated banks, reduce consumer choice, and weaken American leadership in Bitcoin and financial technology.

America cannot lead the next generation of financial infrastructure if American banks are effectively blocked from participating in Bitcoin.

Submit your comment

Submit a comment before June 18, 2026.

Be respectful. Be specific. Use your own words.

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