A diagnosis has emerged that European companies' bitcoin treasury strategies will be difficult to follow exactly the Strategy model of Michael Saylor.

Cointelegraph, a blockchain media outlet, reported on Wednesday that European companies are designing separate bitcoin-linked financing structures in a stricter regulatory environment and with shallower capital markets than the United States.

At Paris Blockchain Week 2026, Thomas Vogel (토머스 보겔), a partner at Latham & Watkins' Paris and Frankfurt offices, pointed to major differences between Europe and the United States in the environment for issuing financial products. "The situation is not the same when you issue convertible bonds in the United States and when you issue them based on the financial statements of a French or European entity," he said. "Differences in market size, regulation and investors make direct replication difficult," he said.

The remarks show that even if European companies include bitcoin as a treasury asset, their funding methods are likely to be adjusted to local market infrastructure rather than directly copying the U.S. model. Alexandre Laize (알렉상드르 라이제), head of bitcoin strategy at French treasury specialist Capital B, said European companies are reviewing bitcoin exposure-linked funding options using local infrastructure such as French public markets and Luxembourg-based structures.

The number of bitcoin-holding companies in Europe is increasing, but the market remains fragmented and centered on small- and mid-cap stocks. According to BitcoinTreasuries.net, Germany's Bitcoin Group SE holds 3,605 bitcoin, worth about $268 million. It did not disclose its average purchase price or profit and loss. Capital B bought 2,925 bitcoin at an average price of $99,932, with its unrealised loss rate estimated at about 25.6 percent.

France's Sequans Communications holds 2,139 bitcoin, but did not disclose its acquisition price or performance data.

Recent volatility in the cryptocurrency market is also weighing on other European companies. The Netherlands' Treasury bought 1,111 bitcoin at an average price of $111,857, leaving it with an unrealised loss of about 33.5 percent. Sweden's H100 Group bought 1,051 bitcoin at an average price of $114,615, with its unrealised loss rate estimated at about 35.1 percent.

The scale gap with the United States is also clear. Strategy bought an additional 13,927 bitcoin over the week of April 14, spending about $1 billion, and raised its total holdings to 780,897 bitcoin. European companies continue to incorporate bitcoin into treasury strategies, but it is not easy for them to move at the same pace as the United States given differences in market structure for issuance and fund-raising capacity.

Against this backdrop, Europe's bitcoin treasury models are increasingly likely to develop in forms suited to regional regulation and market conditions rather than a U.S.-style large-scale borrowing-and-buying strategy. How European companies build financing frameworks using the French stock market and Luxembourg structures, and how quickly the dispersed market centered on small and mid-sized listed companies scales up, will be key points to watch.