JSE Outlines Custody Rules for Bitcoin Listings

For four years the JSE was not allowed to list anything that referenced a crypto asset, and on 4 September 2025 that door started to open. The exchange published proposed amendments to its Debt and Specialist Securities Listings Requirements that would finally admit exchange traded notes and funds tracking approved crypto assets like Bitcoin. The rules are strict where it counts. At least 90% of the coin behind a listed product must sit in cold storage, pricing must come from a proper index rather than a single exchange, and every creation or redemption happens in cash. This is the process I read for clients so they can tell a genuinely custodied product from a marketing claim.

Public comment closed on 6 October 2025 and the final rules follow from there. The direction is not in doubt.

What the JSE actually proposed

Start with what changed, because the shift is bigger than a single threshold. Until this consultation there was no way for a fund or a note that references Bitcoin to list on the JSE at all. The reason was Recommendation 23 in the 2021 position paper from the Intergovernmental Fintech Working Group, which said plainly that securities referencing crypto assets should not be listed until the risks were properly addressed. That recommendation kept the fund door shut for years while the treasury company route, which I unpack in my piece on Africa's first JSE-listed Bitcoin treasury company, walked Bitcoin onto the exchange through an ordinary equity listing instead. The 4 September 2025 amendments are the JSE answering the risks Recommendation 23 raised, point by point.

The 90% figure is the one that travels. Under the proposals a listed crypto fund must hold at least 90% of the underlying coin in cold storage, meaning an offline depository wallet with the private keys kept off any internet-connected system. Where an issuer uses an arrangement it argues is equivalent to cold storage rather than cold storage itself, that claim cannot simply be asserted. A suitably qualified third party has to audit it, the audit report goes to the JSE and onto the issuer's own website before listing, and it is refreshed every year alongside the fund's financial statements. So the online exposure, the part a hacker can actually reach, is capped at a tenth, and the arrangement holding the rest is verified on the record rather than taken on trust.

There is a further quiet condition worth noticing. The proposals only allow a listed product to reference crypto assets the JSE has specifically approved, and that approved list lives on the exchange's own website rather than being left to the issuer's discretion. So an issuer cannot invent a product around some obscure token and pass it off as a regulated instrument. The universe of what can list is drawn by the exchange, which is a small thing on the page and a large thing in practice, because it puts the gatekeeping where the accountability is.

Custody is only half of it.

Why the pricing rules matter as much as the vault

The JSE's real fear is not only theft. It is a rigged price. Bitcoin trades across hundreds of venues, most of them unregulated and thin, and a value drawn from one of them can be pushed around by anyone with enough size and patience. So the proposals forbid pricing a listed product off a single exchange. The price used to value the fund must come from a crypto asset index whose provider complies with either the EU Benchmark Regulations or the IOSCO Principles for Financial Benchmarks, and whose rules pull reference prices from multiple eligible service providers rather than one favoured venue.

Those venues have to earn their place in the index. They must be centralised platforms with transparent ownership, subject to know-your-client and anti-money-laundering law, of a set size and liquidity, running real-time price discovery and the kind of surveillance and cyber security you would expect of a serious exchange.

Platforms on sanctions lists are out. A platform that has suffered a meaningful breach in the previous twelve months can be removed. The effect is a reference price that is expensive to manipulate and easy to defend, which is the whole point of listing an asset on a regulated market in the first place.

Two more requirements finish the frame. Creations and redemptions of a listed crypto fund can be processed in cash only, which keeps coin from moving in and out at the settlement layer and closes off a set of operational risks that have sunk lesser structures. And every issuer must appoint an independent market maker to keep a secondary market running, so a holder who wants out is not left staring at an empty order book. None of this is glamorous. All of it is the difference between a product built to survive an audit and a product built to survive a bull market.

How this fits South Africa's wider crypto rulebook

These listing rules did not arrive out of nowhere. They sit on top of a regulatory frame that has been hardening for years, and I set the whole of it out in my guide to Bitcoin regulatory compliance in South Africa. The pivotal date is 19 October 2022, when the FSCA declared crypto assets a financial product under the FAIS Act and pulled advice and intermediary services into a licensing regime. That is what created the Crypto Asset Service Provider licence and, with it, the pool of regulated venues an approved index can actually draw from.

Read together, the two layers do different jobs. The FSCA licences the people who advise you and the platforms that trade for you. The JSE rules govern how a product that references Bitcoin behaves once it is listed on the exchange.

A South African investor buying a properly listed crypto fund would therefore be standing on a regulated venue, priced off a defensible index, backed by audited cold storage, with a service provider licensed under FAIS somewhere in the chain. That is a genuinely different animal from buying coin on an offshore platform with no local licence and hoping the withdrawals button keeps working.

It is also, quietly, a nudge to the rest of the market. Once regulated cold storage and independent audit become the baseline expectation for a listed product, every provider that cannot demonstrate the same standard starts to look exposed by comparison. The bar moves for everyone, not only those who must clear it.

What the JSE's checklist tells you to demand

The most useful thing about this consultation is that it reads like a checklist a serious investor can borrow. Strip away the listing language and the JSE is telling you what good custody looks like: keys offline for the overwhelming majority of the holding, a genuine third party auditing the arrangement rather than the operator marking their own homework, a price you can defend because it does not depend on one venue, and enough liquidity that you can actually exit. Those are exactly the questions I put to any structure a client is weighing up.

I see this weekly. A client in George or Sandton comes to me holding coin on some offshore platform they found through a friend, comfortable because the balance shows on a screen and nothing has gone wrong yet. Then I ask the four questions the JSE now asks of a listed product. Where are the keys. Who has audited that. How is the price you see actually derived. And on the day you want your money out, who is obliged to be on the other side of the trade. Most of the time the honest answers are unknown, nobody, one exchange and no one. The comfort was never in the structure. It was in the absence of a bad day.

A listed product built to these rules would answer all four cleanly, which is genuine progress and worth saying out loud. The point of holding the coin yourself is that you answer them cleanly too, and you do it without paying a wrapper for the privilege. Cold storage under your own keys is not a lesser version of what the JSE is describing. It is the thing itself, with one fewer stranger in the chain.

A listed product is not the same as holding your own coin

Here is where I have to be straight with you rather than merely enthusiastic. A well-built listed fund solves real problems. It handles custody, it handles pricing, it lets a pension fund or a unit trust take a Bitcoin view through an instrument its mandate already permits, and for that mandated capital it is often the only open door. If you cannot hold coin directly for legal reasons, a product audited to this standard is a serious improvement on the alternatives.

But own a share in that fund and you own paper that references Bitcoin. You do not own Bitcoin. You cannot withdraw the coin, verify it against your own node or move it. Someone else holds the keys, and the whole appeal of Bitcoin as a bearer asset, which I lay out in Bitcoin as a bearer asset, is that you need not trust that someone.

A listed product also carries the machinery that comes with any wrapper: a premium or discount to what the underlying coin is worth, running costs, and the tracking drift I describe in my review of Bitcoin treasury companies. The coin itself has none of that between you and the asset.

So which is right depends entirely on whose money it is and what the rules around it allow. A pension fund under an equity mandate wants the listed product because it is the only permitted expression of the view. A private saver over a five to ten year horizon, which is the only horizon I accept for Bitcoin, almost always wants the coin. That is the work I do at SimplB: guided self-custody from R10,000 and a 2-of-3 multisig Vault for serious holdings, where the client holds two hardware keys and I hold only a recovery key, so no listing rule and no custodian sits between them and their Bitcoin.

The JSE has just written an excellent specification for how a stranger should hold your coin. It is worth reading it as a specification for how you should hold your own.