Texas is moving closer to holding Bitcoin directly after the state’s Comptroller of Public Accounts opened a formal search for a custody and liquidity provider for its Strategic Bitcoin Reserve. The request for proposals, posted on May 7, marks a shift from the state’s current exposure through BlackRock’s iShares Bitcoin Trust into a direct custody structure arranged specifically for the State of Texas. Vendors have until June 15 to respond.
The Texas Strategic Bitcoin Reserve currently holds approximately $10 million in Bitcoin exposure through IBIT, the BlackRock ETF product that the state used as an interim structure while it prepared the systems needed for direct ownership. The transition to direct custody would place Bitcoin under a state-arranged structure rather than through a fund, giving Texas more direct control over the asset and a clearer institutional framework for managing, reporting, and eventually expanding the reserve.
Why Texas Is Moving From IBIT to Direct Bitcoin Custody
The decision to use IBIT as an interim holding structure was a practical one. ETF exposure allows a state to gain Bitcoin price exposure quickly, without needing to resolve custody arrangements, key management infrastructure, or reporting systems first. IBIT is a regulated, liquid product that gave Texas immediate access to Bitcoin’s price performance while the longer-term operational framework was being developed.
Direct custody is a different proposition. Holding Bitcoin directly means the state owns the coins outright, rather than shares in a fund that holds the coins on behalf of investors. For a state reserve, direct ownership carries advantages in terms of transparency, control, and alignment with the stated policy goal of building a genuine Bitcoin reserve rather than a fund investment. It also carries more operational responsibility — the state needs a custodian capable of managing private keys, executing transactions, maintaining security, and producing the reporting and public disclosure that a state-level asset requires.
The RFP is the formal mechanism for finding that custodian. Texas is looking for a qualified firm that can handle the full operational scope of the reserve: acquiring Bitcoin, holding it securely, managing it on an ongoing basis, and reporting holdings and values in a format suitable for both internal oversight and public accountability.
What the Texas Bitcoin Reserve RFP Requires
The request for proposals sets out a detailed scope of services that the selected provider will need to deliver. The core requirement is custody and liquidity services for the Texas Strategic Bitcoin Reserve. On the custody side, the provider must offer institutional-grade security including key management, operational controls, and secure storage in the name of the State of Texas. On the liquidity side, the provider must be able to support Bitcoin purchases and sales for the reserve when needed, giving the state the ability to adjust its holdings within the framework of the reserve’s governing rules.
The transition timeline is defined in the document. The selected firm is expected to support the move from IBIT to direct Bitcoin custody within 60 days of contract execution. That compressed timeline reflects the state’s intent to move quickly once a provider is selected, rather than allowing the transition to stretch across an extended implementation period.
The RFP also contemplates future expansion beyond Bitcoin. The reserve may include other qualifying cryptocurrencies over time, and the custody and liquidity provider will need to be capable of supporting those assets if and when they are added. However, Bitcoin remains the primary and currently named asset in the reserve structure, and the immediate focus of the procurement is on BTC custody.
One notable requirement in the RFP is the public-facing component. The selected firm must help build a public website that displays reserve holdings, current values, and educational materials for Texas residents. That transparency requirement reflects Acting Comptroller Kelly Hancock’s stated commitment to running the reserve with public accountability as a core principle alongside security and financial controls.
Advisory Committee Named to Guide Reserve Management
Alongside the RFP, Acting Texas Comptroller Kelly Hancock announced the formation of the Texas Strategic Bitcoin Reserve Advisory Committee. The panel will advise on how the reserve is managed, covering custody arrangements, risk rules, valuation methodology, reporting standards, and broader digital asset management practices.
The committee includes four members: Laurie Dotter, Jamie McAvity, Carla Reyes, and Gary Vecchiarelli. Their collective backgrounds span investment management, Bitcoin mining, digital asset law, corporate finance, and public company governance — a range of expertise designed to cover the technical, legal, financial, and operational dimensions of running a state-level Bitcoin reserve.
Hancock described the reserve’s operating principles in clear terms, saying it must be run with transparency, security, and strong financial controls. The advisory committee’s role is to ensure those principles are embedded in the specific policies and procedures that govern the reserve’s day-to-day management, rather than remaining aspirational statements without operational substance.
Texas Joins a Growing List of States Building Bitcoin Reserves
The Texas Strategic Bitcoin Reserve custody search is the operational follow-through on legislation that established the reserve in the first place. The state’s earlier policy push to create a state-level Bitcoin reserve was part of a broader wave of similar initiatives across the United States, as multiple states moved to position Bitcoin as a legitimate component of public treasury management.
At the federal level, discussions around a U.S. strategic Bitcoin reserve have also continued, with domestic Bitcoin mining policy forming part of the same broader conversation about the country’s relationship with Bitcoin as a national asset. Texas, which is home to a significant share of U.S. Bitcoin mining activity, sits at the intersection of these state and federal policy threads.
What distinguishes the current Texas development from earlier legislative milestones is that it is operational rather than political. The state has moved past the debate about whether to hold Bitcoin and into the practical work of building the systems needed to hold it properly. An RFP for custody services, an advisory committee with specific technical expertise, a 60-day transition timeline, and a public reporting website requirement are the kinds of implementation details that separate a policy announcement from a functioning reserve.
What Comes Next for the Texas Bitcoin Reserve
The immediate next step is the June 15 vendor deadline. After that date, the Comptroller’s office will review responses and select a provider capable of meeting the RFP’s requirements. The 60-day transition clock begins once the contract is executed, meaning direct Bitcoin custody could be in place before the end of summer 2026 if the procurement process moves efficiently.
The selection of a custody provider will also signal something about the direction of state-level institutional Bitcoin infrastructure more broadly. The firms that can credibly respond to an RFP of this scope — institutional-grade custody, liquidity services, reporting systems, and public disclosure infrastructure — represent the emerging category of regulated Bitcoin service providers built for government and institutional clients rather than retail users.
For Texas, the goal is straightforward: replace ETF exposure with directly held Bitcoin, managed transparently, within a structure that gives the state full accountability over its reserve and the public full visibility into how it is being run. The June 15 deadline is the next marker on that path.
