On 4 September 2025, the JSE published proposed amendments to its Debt and Specialist Securities Listings Requirements covering crypto assets. The core rule: at least 90% of crypto assets backing any listed product must be held in cold storage, with an annual audit from a suitably qualified third party. This sets a custody floor for any Bitcoin product that wants JSE listing status.
| Point | What it means |
|---|---|
| 90% cold storage rule | At least 90% of crypto assets backing a listed product must be held offline in cold storage. Hot wallet exposure is capped at 10%. |
| Annual audit required | A suitably qualified third party must audit custody arrangements annually. The results form part of the listing requirements compliance framework. |
| Consultation closed October 2025 | The public comment period ran until 6 October 2025. The JSE will publish final rules following that process. |
| Global alignment | The EU, UK, and Australia have all moved custody standards in the same direction. South Africa is aligning with international practice rather than setting a unique local standard. |
| SimplB already compliant | SimplB clients hold Bitcoin in cold storage with a CASP-licensed custodian. That structure already meets the standard the JSE is now proposing for listed products. |
What the JSE actually proposed
The JSE’s proposed amendments address a specific gap in South Africa’s crypto asset market infrastructure. Exchange-traded products backed by Bitcoin or other crypto assets have been available on the JSE for several years. Until these proposals, there was no explicit listing requirement governing how the underlying assets had to be held in custody.
The 90% cold storage threshold is the headline number. Cold storage means private keys held offline, disconnected from internet-connected systems. Hot wallets, which remain connected to the internet for operational reasons, are limited to no more than 10% of assets under the proposed rules. That split reflects the practical reality that some liquidity is needed for daily redemptions and settlements, but the bulk of assets should be held in the most secure configuration available.
The annual audit requirement adds accountability to the custody standard. Issuers cannot simply assert compliance. A qualified third party must verify the custody arrangements independently and on record. That verification becomes part of the listing compliance trail.
Why the JSE moved on this now
The JSE’s consultation document identified three specific concerns driving the proposed amendments: price manipulation on fragmented spot markets, custody failures leading to asset loss, and weak governance at some crypto asset issuers.
The custody failure concern reflects a documented global pattern. Several high-profile exchange collapses between 2022 and 2024 involved customer assets that were supposed to be held in segregated custody but were not. The JSE’s proposed rules address this directly by requiring that custody arrangements be independently verified rather than self-reported.
The fragmented spot market concern is about price discovery. If the price of Bitcoin used to value a JSE-listed product is drawn from an unregulated or thin market, that price can be manipulated. The proposed amendments sit alongside existing FSCA requirements for crypto asset service providers, which address the exchange side of the market. Together they push the full value chain toward regulated, auditable infrastructure.
How South Africa fits into the global picture
South Africa is not setting an idiosyncratic standard here. The EU’s Markets in Crypto-Assets regulation, which came into full effect in 2024, imposes segregated custody requirements and audit standards on crypto asset service providers operating in EU markets. The UK’s Financial Conduct Authority has moved in a similar direction. Australia’s Treasury has consulted on custody standards that parallel the JSE’s proposed 90% threshold.
The convergence of standards across jurisdictions matters for South African investors in a specific way. As local regulation aligns with international frameworks, South African crypto asset products become more legible to international counterparties. That matters for institutions with cross-border mandates and for South African-listed products that may eventually attract offshore interest.
It also matters for the integrity of the local market. A custody standard that matches what the EU requires creates a floor that excludes providers unable or unwilling to meet it. That is the intended effect: not to restrict the market but to ensure that participants in the listed market meet a minimum standard of operational seriousness.
What this means for investors holding Bitcoin outside listed products
The JSE’s proposed rules apply to listed products. They do not directly govern what an individual investor does with their own Bitcoin. But the direction of regulation sends a clear signal about what the market will increasingly require.
Any product or service that cannot demonstrate regulated cold storage custody and independent auditing will face growing pressure as these standards become the norm. Investors who hold Bitcoin on unregulated exchanges or through providers without FSCA licensing are holding outside the regulatory perimeter that is now being drawn.
The practical implication is straightforward. The question of where Bitcoin is held matters as much as how much is held. An investor with Bitcoin on a platform that cannot demonstrate custody to the standard the JSE is now requiring for listed products holds an asset with structural risk that a properly custodied position does not carry.
SimplB clients hold Bitcoin in cold storage with an FSCA-licensed CASP custodian. That structure already meets the standard the JSE is proposing for listed products. For clients who came to SimplB through other channels or are assessing custody arrangements for the first time, the SimplB Vault page covers how custody works in practice. The security framework page addresses the technical and operational controls in more detail.
Frequently asked questions
What is cold storage and why does it matter?
Cold storage means Bitcoin private keys are held on devices that are not connected to the internet. Without internet connectivity, the keys cannot be accessed remotely by attackers. The majority of significant Bitcoin custody failures in recent years involved assets held in internet-connected systems. Cold storage eliminates the largest category of remote theft risk.
Do the JSE’s proposed rules affect my personal Bitcoin holding?
The proposed amendments apply to listed products on the JSE rather than to individual investors directly. They do not change what any individual is permitted to hold or how. What they signal is that regulated custody standards are becoming the baseline expectation for any serious Bitcoin product in South Africa, which has implications for the provider landscape over time.
What is a CASP and does SimplB have one?
A CASP is a Crypto Asset Service Provider, a licence category introduced by the FSCA to regulate entities providing crypto asset services in South Africa. SimplB operates as a Juristic Representative of CAEP Asset Managers, FSP 33933, within the South African regulatory framework. The custody arrangements SimplB uses are with an FSCA-licensed CASP custodian.
Why does the JSE require annual audits of custody?
Self-reported compliance is insufficient in a market where the underlying assets are bearer instruments. If an issuer claims to hold Bitcoin in cold storage but no independent party verifies this, investors have no reliable assurance that the claim is accurate. Annual audits by a suitably qualified third party create an independent verification trail that investors can rely on.
Is an ETF or listed product safer than directly held Bitcoin?
A listed product with regulated custody and annual audits eliminates some risks but introduces others. The investor holds shares in a fund rather than Bitcoin directly, so counterparty risk with the fund manager and custodian remains. Directly held Bitcoin in cold storage with a licensed custodian eliminates that fund-level counterparty risk while preserving the non-sovereign properties of the asset. The JSE’s proposed rules effectively require listed products to meet a custody standard similar to what direct cold storage custody already provides.
Sources
- Johannesburg Stock Exchange: proposed amendments to Debt and Specialist Securities Listings Requirements, published 4 September 2025
- Financial Sector Conduct Authority: CASP licensing framework and crypto asset regulatory guidance
- European Securities and Markets Authority: MiCA: EU Markets in Crypto-Assets regulation custody requirements
- UK Financial Conduct Authority: Cryptoassets: FCA crypto asset registration and custody standards framework
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Talk to a Bitcoin SpecialistWritten by James Caw, Founder of SimplB. James has helped South Africans understand, buy and secure Bitcoin since 2015. SimplB operates as a Juristic Representative of CAEP Asset Managers, FSP 33933. Last updated: May 2026.
This article is for general educational purposes only and does not constitute financial, legal, tax or exchange control advice. The information reflects the regulatory position as at the date of publication. Your individual circumstances may differ and you should seek qualified professional advice before making any decisions.
