The Fed may be forced to include Bitcoin in bank stress tests

Former Bitcoin strategy director Pierre Rochard calls on the U.S. Federal Reserve (Fed) to include Bitcoin in bank stress test scenarios at the right time, as the Fed is currently soliciting public input for the 2026 scenario framework and proposing increased transparency in model development. The question is not whether the Fed “supports” Bitcoin, but whether this agency can consider Bitcoin as a risk variable without turning it into policy.

According to analysis, the issue lies in the technical aspects and the degree of Bitcoin’s integration with the banking system. The Fed will not include Bitcoin in stress tests solely based on a call, but if the exposure of banks to Bitcoin through custody, derivatives, ETF intermediaries, or brokerage services is significant enough to impact capital and liquidity, the Fed may be compelled to model Bitcoin price shocks similarly to stocks or credit spreads.

This does not imply recognition or endorsement of Bitcoin but reflects the reality that this asset has become too intertwined with the balance sheets of regulated financial institutions to ignore. In the current framework, Bitcoin may first appear as a shock in the “global market shock” scenario designed for banks with large trading and custody activities, rather than becoming a core macroeconomic variable.

If included in stress tests, Bitcoin will be standardized as a risk factor requiring management, leading to stricter limits, governance, modeling, and compliance requirements for related business areas. In other words, Bitcoin will only enter the Fed’s stress testing when regulators have no choice but to account for it.