Morgan Stanley’s Amy Oldenburg said a future move by major banks to put bitcoin on their balance sheets “is not entirely out of the question,” pointing to regulatory progress while warning that capital rules and global supervisory alignment still matter.

Speaking at the Bitcoin 2026 conference panel, Oldenburg was he asked what it would take for a bank like Morgan Stanley or another regulated financial institution to make the leap from offering exposure to Bitcoin to actually holding Bitcoin as a treasury asset.

“Bitcoin on the balance sheet,” she said, pausing on the premise. “You know, I think if we continue to see the progress that we’ve made over the last 16 months in terms of regulation, that’s something you might see in the future. It’s not completely out of the question.”

Morgan Stanley and Bitcoin?

This response is noteworthy less because it signals an imminent move and more because it lays out the idea as procedurally as possible. For years, the issue of a bank’s balance sheet has been at the other end of Bitcoin’s institutional adoption: beyond ETFs, beyond custodianship, beyond customer access and in the realm of prudential capital, examiner expectations, accounting, liquidity planning and board-level risk appetite.

Oldenburg stipulated that the limitation is not a single rule. She first pointed to SAB 121, the SEC accounting guidance that made it harder for banks to hold crypto assets on a immense scale, before its rollback changed part of the equation. But she immediately widened the lens.

“I think the second thing is that we’ve talked about SAB 121’s rollback on equity treatment, but that’s not the only thing that’s holding us back,” she said. “It’s the Fed guidelines, it’s the Basel guidelines. When you’re a large G-sub bank, you don’t just report to one agency.”

This is the crux of the problem for a company like Morgan Stanley. The global systemically vital bank does not evaluate Bitcoin solely through the lens of market risk. It must simultaneously meet the expectations of multiple regulatory authorities, capital frameworks and jurisdictional expectations. Oldenburg said immense banks have “a lot of supervisory groups” to deal with and need “a little more alignment of all activities with some of these agencies.”

Background

The Basel Point is particularly vital. The Basel Committee’s standard for cryptocurrencies most conservatively treats unsecured crypto assets such as Bitcoin, and industry advocates have argued that the 1,250% risk weight treatment effectively makes direct exposure to a bank’s balance sheet uneconomic. In February 2026, the Basel Committee announced that it had accelerated a targeted review of its prudential standard for banks’ exposure to cryptocurrencies, with an update expected later in the year.

The Bitcoin Policy Institute is trying to push this debate into the US implementation process. In March, the group said it planned to review and comment on the Basel Federal Reserve’s upcoming proposal, arguing that the current approach discourages banks from holding or handling Bitcoin due to its punitive risk weighting.

The US side is also moving, although not in a straight line, towards bank-owned Bitcoin. In April 2025, the Federal Reserve withdrew previous guidance related to banking activities in the field of cryptocurrencies and dollar tokens, saying that such a move would adjust expectations to evolving risks and support innovation in the banking system. The FDIC and OCC have also moved away from the prior approval style framework for permissible crypto activity, while maintaining that banks still need sound risk management.

Recently, U.S. banking agencies clarified that eligible tokenized securities should generally receive the same capital treatment as their non-tokenized counterparts, describing the capital rule as technology neutral. This explanation does not solve the problem of including Bitcoin on the balance sheet because Bitcoin is not a tokenized version of a time-honored security. However, it shows that regulators are separating blockchain rails from asset risk, rather than treating each digital asset exposure as the same category.

This distinction helps explain Oldenburg’s answer. The bank’s path to holding Bitcoin isn’t simply about “regulators becoming more pro-crypto.” The first issue concerns Basel: if Bitcoin continues to be subject to the most punitive capital treatment, G-SIB will have little economic incentive to hold it as a treasury asset, even if customer demand is clear.

The second issue is Federal Reserve oversight: even with recent reversals, immense banks still need a consistent examination framework that tells them how exposure to Bitcoin will be assessed in terms of safety and soundness, liquidity, operational risk and capital planning.

At the time of publication, BTC was trading at $1.3716.

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