The Sovereign Race — Part 2: 23 Nations, Four Strategies, and the Countries Most Likely to Move Next
A follow-up to: The Sovereign Race — Part 1: How 23 Nations Entered the Bitcoin Reserve Race
The Same Race, Different Strategies
Part 1 of this series established that at least 23 governments now hold Bitcoin at the national level — through seizures, state-backed mining, sovereign wealth fund allocations, or formal legislative mandates. It identified three paths into the race: seizure and retention, state-backed mining, and legislative mandate with direct purchase.
Part 2 examines what each major participant is actually doing — their holdings, their strategies, and what their approaches reveal about the next phase of sovereign Bitcoin adoption.
The picture that emerges is not a uniform global movement. It is a collection of distinct national calculations, each reflecting different economic pressures, different political constraints, and different views about what Bitcoin is actually for. Some governments are accumulating aggressively. Some are holding passively. Some are selling. And some are watching from a distance, waiting to see which approach proves correct.
Understanding who is doing what — and why — is essential to understanding where the race goes next.
Which Countries Already Treat Bitcoin as a Strategic Reserve?
These are governments that have established explicit legal frameworks designating Bitcoin as a strategic national reserve asset. Their holdings are intentional, their policies are documented, and their commitment is formal rather than incidental.
📌 Source: Bleap Finance — "Cryptocurrency Reserve by Country (2026)"; CleanSky — "Bitcoin as a Sovereign Reserve Asset" (April 2026); CCN — "National Crypto Reserves Tracker" (December 2025)
United States — approximately 328,372 BTC
The United States holds the largest known sovereign Bitcoin position in the world. Its path to this position was not strategic from the outset — the majority of holdings were accumulated through decades of law enforcement seizures, primarily from the Silk Road case, the Bitfinex hack recovery, and other criminal asset forfeitures. For years, the standard policy was rapid liquidation: sell the seized Bitcoin, convert to dollars, deposit in the Treasury.
That policy reversed in March 2025, when an executive order established the Strategic Bitcoin Reserve. The order prohibited further sales and directed the Treasury to hold all government-controlled Bitcoin as a long-term reserve asset. A separate U.S. Digital Asset Depository was established for other seized cryptocurrencies — Ethereum, Solana, XRP — treated with less permanence than the Bitcoin reserve.
The rationale presented by policymakers is straightforward: Bitcoin provides diversification beyond traditional reserve assets, its fixed supply makes it immune to debasement, and its independent network architecture removes the counterparty risk inherent in dollar-denominated reserves. What began as the unintended consequence of criminal enforcement has become the foundation of a formal national reserve strategy.
📌 Source: CleanSky — "Bitcoin as a Sovereign Reserve Asset" (April 2026); Bleap Finance — "Cryptocurrency Reserve by Country (2026)"
El Salvador — over 7,500 BTC
El Salvador's position is smaller in absolute terms but more significant in historical terms. In 2021, it became the first country to adopt Bitcoin as legal tender — a decision made not from a position of financial strength but from one of necessity. With approximately 70% of the population unbanked, a dollarized economy dependent on remittances, and no monetary policy tools of its own, El Salvador's government under President Nayib Bukele concluded that Bitcoin offered a path toward financial sovereignty that the existing system could not provide.
The accumulation strategy is transparent and disciplined: one Bitcoin purchased per day, regardless of price, since 2021. Holdings have reached approximately 7,514 BTC. A public-facing dashboard publishes holdings in real time — a level of transparency that remains rare in sovereign Bitcoin policy. Bitcoin-linked tourism generated approximately $180 million in foreign exchange in 2025, with "Bitcoin Beach" in El Zonte attracting over 34,000 international visitors.
The IMF has repeatedly conditioned loan support on moderating Bitcoin-related policies. El Salvador has navigated this tension — maintaining its reserve position while adjusting the mandatory acceptance requirements that initially triggered international concern.
📌 Source: CleanSky — "Bitcoin as a Sovereign Reserve Asset" (April 2026); CCN — "National Crypto Reserves Tracker" (December 2025)
Bhutan — approximately 11,286 BTC
Bhutan's approach is arguably the most elegant of any government in the race. The Kingdom holds an estimated 11,286 BTC — a position estimated to represent over one-quarter of GDP — accumulated almost entirely through state-run Bitcoin mining powered by its abundant Himalayan hydroelectric resources.
Unlike every other sovereign holder, Bhutan did not purchase Bitcoin on the open market and did not seize it from criminals. It converted surplus renewable energy into digital currency, treating Bitcoin mining as an industrial policy rather than a financial speculation. The sovereign investment fund, Druk Holding and Investments, began mining when Bitcoin's price was approximately $5,000 — meaning the cost basis of Bhutan's reserve is among the lowest of any government holder globally.
Bhutan does not formally classify its holdings as a "Bitcoin reserve" in the policy sense. Its position reflects an industrial strategy that happens to have produced a sovereign Bitcoin stockpile of considerable size. Whether that distinction matters in practice is a question for Bhutanese policymakers, not outside observers.
📌 Source: Webopedia — "Countries With a Bitcoin Reserve"; CleanSky — "Bitcoin as a Sovereign Reserve Asset" (April 2026)
Who Holds Bitcoin Without Calling It a Reserve?
These governments control substantial Bitcoin positions — in some cases larger than those of formal reserve holders — but have not established explicit strategic reserve frameworks. Their holdings result from criminal seizures that remain in government custody, often with ambiguous or unstated long-term plans.
📌 Source: Webopedia — "Countries With a Bitcoin Reserve"; Bitget News — "Sovereign Adoption Expands as 23 Governments Hold Bitcoin" (February 2026); Analytics Insight — "Which Countries Own the Most Bitcoin in 2026?" (March 2026)
China — approximately 190,000–194,000 BTC
China's position represents one of the most significant strategic ambiguities in the global Bitcoin landscape. Despite maintaining strict domestic restrictions on cryptocurrency trading and mining since 2021, the Chinese government controls an estimated 190,000 to 194,000 BTC — primarily seized from the PlusToken Ponzi scheme, which defrauded millions of retail investors.
China has not formally designated these holdings as a reserve asset. It has not publicly stated a long-term strategy for them. And it has not — to public knowledge — begun liquidating them at scale. What it does with this position will have significant implications for global Bitcoin markets. A decision to liquidate would represent substantial selling pressure. A decision to formalize reserve status would represent a significant geopolitical signal from a government that has publicly positioned itself against cryptocurrency adoption.
The situation is, by design, ambiguous. China's government has rarely telegraphed its intentions regarding assets of this sensitivity. Either outcome would likely influence global market expectations.
United Kingdom — approximately 61,245 BTC
The United Kingdom holds an estimated 61,245 BTC, accumulated through law enforcement seizures from darknet marketplace operations, financial crime investigations, and related criminal cases. The UK's proactive policing of digital crime means its position continues to grow as enforcement actions produce additional forfeitures.
The UK has not established a formal Bitcoin reserve policy, nor has it announced plans to liquidate holdings systematically. Its position reflects an enforcement posture rather than an investment strategy — Bitcoin that was acquired because it was the proceeds of crime, not because the government sought exposure to the asset class. Whether that distinction will persist as the holdings become more valuable is an open question.
Ukraine — holdings not reliably verified
Ukraine's Bitcoin exposure combines law enforcement seizures, government wallet holdings, and cryptocurrency donations received following the Russian invasion of 2022 — making it difficult to assign a single verified figure. Figures reported across sources vary considerably, as donation receipts, government custody, and formal government ownership represent different legal categories that are not always clearly distinguished in public reporting.
What is clear is that Ukraine demonstrated Bitcoin's utility as a rapidly transferable asset across borders under conditions where traditional financial channels were constrained. Ukraine has since developed a formal digital asset regulatory framework, and its experience with cryptocurrency in wartime conditions has informed both its own policy and the observations of other governments.
📌 Source: Webopedia — "Countries With a Bitcoin Reserve"; Analytics Insight — "Which Countries Own the Most Bitcoin in 2026?" (March 2026)
Which Countries Could Join the Race Next?
These governments have moved beyond informal holdings into active legislative processes to formalize Bitcoin reserve status or authorize significant accumulation programs. Their decisions in the next twelve to twenty-four months will determine whether the current 23-country count expands significantly.
📌 Source: CCN — "National Crypto Reserves Tracker" (December 2025); CleanSky — "Bitcoin as a Sovereign Reserve Asset" (April 2026); Bleap Finance — "Cryptocurrency Reserve by Country (2026)"
Brazil — proposed allocation of up to 5% of foreign reserves
Brazil has produced one of the most ambitious legislative proposals in the sovereign Bitcoin race. PL 4501/2024, introduced in the Chamber of Deputies, proposes forming a Reserva Estratégica Soberana de Bitcoins — a Sovereign Strategic Bitcoin Reserve — through the allocation of up to 5% of Brazil's $344 billion in foreign reserves to Bitcoin purchases. Depending on future Bitcoin prices, a full implementation could require several hundred thousand Bitcoin.
The explicit motivation is currency diversification: protecting national wealth against devaluation of the Brazilian real and establishing Brazil as a technological center for the region. Brazil's central bank is simultaneously developing a comprehensive crypto regulatory framework, and the tension between elected officials who favor reserve adoption and monetary technocrats who are more cautious will determine whether the legislative ambition translates into actual accumulation.
UAE — reported exposure across sovereign-linked entities
The UAE has reported significant Bitcoin exposure across sovereign wealth-linked entities — though the precise breakdown between direct government holdings, sovereign wealth fund allocations, and state-linked entities varies across sources. What is consistent across reporting is the UAE's strategic focus: positioning Dubai and Abu Dhabi as global centers for the tokenization of real-world assets, with Bitcoin reserve exposure as one component of a broader digital finance infrastructure strategy.
📌 Source: CleanSky — "Bitcoin as a Sovereign Reserve Asset" (April 2026); Bitget News (February 2026)
Pakistan — holdings undisclosed
Pakistan announced the creation of a government-led Strategic Bitcoin Reserve in 2026, marking a significant shift in a country that had previously maintained a restrictive posture toward cryptocurrency. Government communications have focused on strategic intent and infrastructure development, including energy allocation for mining and data center capacity. Specific holdings have not been publicly disclosed. Pakistan's reserve strategy is at an early stage — positioning and policy alignment rather than demonstrated accumulation.
Czech Republic, Poland, Japan — exploratory positions
Several European and Asian nations have moved into the exploratory phase. The Czech Republic's central bank has formally proposed allocating a portion of its reserves to Bitcoin — a significant signal given the institution's conservative mandate. Poland has initiated legislative discussions. Japan's Government Pension Investment Fund, the world's largest pension fund with approximately $1.5 trillion in assets, announced that it would study the feasibility of Bitcoin as a diversification option. No allocation decision has been made, and the outcome of the feasibility study remains uncertain.
These exploratory positions matter because of the institutions involved. A feasibility study by the world's largest pension fund is not a purchase decision — but it is a signal that Bitcoin is being evaluated at the institutional level where such decisions are ultimately made.
📌 Source: Bleap Finance — "Cryptocurrency Reserve by Country (2026)"; Webopedia — "Countries With a Bitcoin Reserve"
Kazakhstan — proposed State Fund of Digital Assets
Kazakhstan has emerged as a potential new entrant, with President Kassym-Jomart Tokayev outlining plans for a State Fund of Digital Assets under the National Bank's Investment Corporation. The proposal would accumulate a strategic crypto reserve — potentially including Bitcoin — as the country builds a broader digital asset ecosystem. Kazakhstan's position as a major Bitcoin mining hub gives this proposal additional credibility: the country has existing infrastructure, existing expertise, and existing economic interest in Bitcoin's success.
📌 Source: Webopedia — "Countries With a Bitcoin Reserve"
Why Are Some Governments Still Selling Bitcoin?
Not every government has concluded that holding Bitcoin is the correct policy. Some have actively liquidated. Others have imposed conditions on allies that reduce Bitcoin adoption. Understanding their reasoning is as important as understanding the buyers.
📌 Source: Bleap Finance — "Cryptocurrency Reserve by Country (2026)"; CCN — "National Crypto Reserves Tracker" (December 2025)
Germany — 0 BTC
Germany's decision in 2024 to sell virtually all of its seized Bitcoin — approximately 50,000 BTC at the time — stands as the most consequential counter-example in the sovereign Bitcoin race. The Bundestag's decision reflected a preference for converting crypto assets into fiat rather than incorporating them into sovereign reserve strategy. Bitcoin later appreciated significantly following the sale, a development that has drawn retrospective attention to the timing of that decision.
Germany's approach reflects a specific institutional philosophy: cryptocurrency is a risk asset unsuitable for sovereign reserve purposes, and the appropriate response to seized holdings is rapid monetization. This view remains common among European central banks and is not without basis — volatility, regulatory uncertainty, and custody complexity are real considerations for risk-averse public institutions.
The IMF — active institutional skeptic
The International Monetary Fund has consistently opposed sovereign Bitcoin adoption among its borrowing members. Its loan conditions have included provisions requiring El Salvador to moderate Bitcoin integration and have created friction with other nations considering reserve adoption. The IMF's position reflects institutional concerns about financial stability, monetary sovereignty, and the volatility of crypto assets — concerns that are not unfounded but that increasingly place the IMF in tension with the direction a growing number of governments are choosing.
What the Strategies Reveal
Examined as a whole, the sovereign Bitcoin holdings landscape reveals several patterns that will shape the next phase of the race.
The gap between holding and strategy is large. Most governments with substantial Bitcoin positions — China, the UK — acquired them incidentally and have not articulated clear long-term strategies. The absence of explicit policy creates optionality but also uncertainty. As holdings grow more valuable, the pressure to formalize strategy will increase.
The smallest holders have the clearest strategies. El Salvador and Bhutan, with relatively modest holdings in absolute terms, have the most explicit and disciplined approaches. El Salvador publishes daily holdings data. Bhutan has integrated Bitcoin into a coherent energy policy. The largest holders — the US, China, UK — maintain more ambiguity about long-term intentions.
Legislative proposals are the leading indicator of the next wave. Brazil's PL 4501/2024, Pakistan's reserve announcement, Japan's GPIF feasibility study, Czech Republic's central bank proposal, and Kazakhstan's State Fund initiative represent governments moving from informal exposure to formal commitment. If these proposals are enacted, they will produce the next significant wave of sovereign accumulation.
The supply arithmetic is tightening. As Part 1 noted, fewer than 1 million Bitcoin remain to be mined. Government holdings already represent approximately 3% of total supply. The countries currently in the legislative frontrunner group — if they execute even partial versions of their proposals — would acquire Bitcoin at prices that will not exist once the demand becomes known to the market.
The race has 23 participants as of mid-2026. The question that follows from their accumulation is not whether more countries will join — the direction of that trend is reasonably clear. The question is what governments plan to do with what they hold.
Throughout history, nations accumulated reserve assets to preserve value. The next question is whether reserve assets can also generate value. That question begins in Part 3.
This is Part 2 of 3 in The Sovereign Race series.
← Previous: The Sovereign Race — Part 1: How 23 Nations Entered the Bitcoin Reserve Race
→ Next: [The Sovereign Race — Part 3: From Accumulation to Productivity]
Related Reading:
→ The $100 Trillion Shift — Part 1: The Gate Opens
→ Strategy and BTCFi — Part 3: When Selling Bitcoin Becomes the Answer, What Was the Question?
→ Bitcoin Has $2 Trillion Sitting Idle. Here's the Infrastructure Being Built to Make It Productive.
📋 Coming Up on crypto-insight.net
The following series and articles are currently in development:
The Sovereign Race — Part 3: From Accumulation to Productivity
When governments hold Bitcoin, the next question is what to do with it. The infrastructure for making sovereign Bitcoin productive already exists.
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Written by Dongbum Kim · Former CEO (1,200-employee firm) · LL.B. · MBA (Univ. of Northern Iowa) · 3.5 Years Independent Blockchain Research | crypto-insight.net
This analysis is based on publicly available government filings, legislative records, and market data.
⚠️ This article is for educational and informational purposes only and does not constitute financial advice. Government Bitcoin holdings data reflects publicly reported estimates as of mid-2026 and may not reflect real-time positions. Always conduct your own research before making any investment decisions.
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