Texas Bitcoin Reserve Plan Advances as Federal Push Faces Delays
Texas is getting closer to holding Bitcoin directly. Not just through a fund. Not as a press-release asset. The state has named an advisory committee for its Strategic Bitcoin Reserve, while the federal version is still stuck in legal work. My take: the gap is bigger than it looks, because a state treasury moving from ETF exposure to custody is a very different bet.
The Texas Comptroller’s office said Thursday that it had formed a five-member Texas Strategic Bitcoin Reserve Advisory Committee. Acting Comptroller Kelly Hancock will sit on the committee, which will advise the state on custody, valuation, and management of its Bitcoin. The office said the committee was created under Senate Bill 21, signed on June 22, 2025. The law gave the Comptroller authority to run the reserve and set up a state framework for Bitcoin exposure.
Hancock said lawmakers gave his office a clear job: manage the reserve openly, securely, and with real financial controls. That sounds bland. It isn’t. If a public office is going to hold Bitcoin, the dull questions are where the risk lives. Who controls the keys? Who prices the asset? Who approves a transfer? Most Bitcoin reserve commentary focuses on price. That’s only half right. The harder problem is operational control, because taxpayers do not get a do-over if custody fails.
The committee includes people with market, legal, and custody experience. Laurie Dotter, chair of the Investment Advisory Board for the Employees’ Retirement System of Texas, has more than 35 years in investment oversight and governance. Jamie McAvity, founder and CEO of Cormint Data Systems, brings mining experience through a company that operates a 130-megawatt Bitcoin mining facility in Fort Stockton. Carla Reyes, a Southern Methodist University law professor and member of the CFTC’s Innovation Advisory Committee, covers the legal side. Gary A. Vecchiarelli, CPA, president and CFO of CleanSpark, has worked on Bitcoin trading desks and digital asset governance systems. I’ll be honest: this looks less like ceremonial window dressing and more like Texas knows it has to operate the reserve for real.
The Comptroller’s office also issued a request for proposals for a crypto custodian. The RFP covers custody, liquidity services, asset management, and the practical mechanics around holding the asset. The reserve now has about $10 million of exposure through BlackRock’s iShares Bitcoin Trust. Under the RFP, Texas would move from ETF exposure to direct Bitcoin holdings within 60 days after signing a contract. That is the part worth watching. ETF exposure is easy to explain. Direct custody makes the state deal with Bitcoin as Bitcoin. Why does this matter? Because the state stops borrowing BlackRock’s wrapper and starts owning the operational problem itself.
Texas is now one of the more active U.S. states trying to build a formal Bitcoin reserve. Its plan depends on direct custody and financial controls, with the option to add other digital assets later. Washington is taking longer. Counter to the usual advice, “wait for federal clarity” may not be the playbook here. If more states try their own versions, the result could get uneven fast: separate rules, separate custodians, separate risk limits, separate disclosure habits. Markets can handle uneven. Investors still need to know which version they are looking at.
The federal Strategic Bitcoin Reserve is still moving, but slowly. President Donald Trump signed an executive order on March 6, 2025, directing the Treasury Department to create a reserve from Bitcoin already held through criminal and civil forfeitures. The order barred Treasury from selling those holdings, estimated at 328,372 $BTC. That would make the U.S. government the largest known state holder of Bitcoin. In January 2026, Patrick Witt, executive director of the President’s Council of Advisors for Digital Assets, said legal issues still had to be resolved. By May 2026, he said a major legal breakthrough had been reached and an announcement was close. The difference between Texas and Washington is plain: Texas is hiring people, issuing an RFP, and building the machinery. The federal government is still finishing the legal work.
Congress has a larger proposal in play. Senator Cynthia Lummis and Representative Nick Begich have backed the American Reserves Modernization Act, which would let the Treasury buy up to 200,000 $BTC per year for five years and hold it for at least 20 years. If the bill passes, the first open-market Treasury Bitcoin purchase is projected for the fourth quarter of 2026. This is not small. A steady federal buyer would change how traders think about downside, available supply, long run demand, and political signaling. Yes, that sounds like it contradicts the earlier point that custody is the real story. Bear with me: at the federal level, buying scale becomes the story too.
What this means
Texas is making a direct statement: it wants Bitcoin on the state balance sheet, and it wants to hold it itself. The advisory committee and custodian search make the plan harder to dismiss as symbolism. The 60-day shift from ETF exposure to direct Bitcoin holdings is the strongest signal. We have seen this pattern before in institutional crypto mandates: the moment an entity moves from fund exposure to custody, the conversation changes from allocation size to governance design. Is this overkill for about $10 million of exposure? No. The reserve framework matters more than the starting balance.
The federal side is larger, but it is moving slower. The American Reserves Modernization Act could allow purchases of up to 200,000 $BTC a year, but the bill still has to get through Congress. Investors should watch for a formal update from the President’s Council of Advisors for Digital Assets and any movement on the Lummis-Begich bill. Q4 2026 is the date to keep on the calendar if the bill passes. My read: a confirmed Treasury purchase program would likely move the market quickly, especially if traders start pricing in the U.S. government as a repeat buyer near levels such as $75,000.