Five EU Central Banks Could Quietly Mirror Czech $1M Bitcoin Experiment Using Loophole

Key Insights

• Coinbase’s Head of Institutional, John D’Agostino, predicted non-eurozone EU countries would follow the Czech National Bank’s Bitcoin experiment during a December 10 podcast appearance.
• The Czech central bank launched a $1 million digital asset pilot in October 2025, but kept the holdings separate from official reserves to avoid ECB jurisdiction.
• Five EU countries share the Czech Republic’s derogation status that enables similar experiments: Hungary, Poland, Romania, Sweden, and Bulgaria.

The Czech National Bank carved out a path for central bank Bitcoin experimentation that specific “eurozone countries” could replicate, according to John D’Agostino, Head of Institutional at Coinbase.

Speaking on the December 10 episode of the Crypto In America podcast, D’Agostino argued the Czech approach represented a qualitatively different development from previous sovereign Bitcoin adoption.

He stated:

D’Agostino’s characterization of the Czech Republic as a “eurozone country” contained a technical error that actually illuminates why the experiment worked.

The Czech Republic maintains EU membership but has not adopted the euro, operating instead under a “derogation” status under treaty law.

That distinction created the legal space for the central bank to act.

How Czech National Bank Structured Bitcoin Experiment

The Czech National Bank approved a $1 million digital asset portfolio on October 30, with the holdings disclosed publicly in mid-November.

The bank explicitly stated the portfolio was purchased outside existing international reserves and remained separated from them.

The announcement emphasized that the experiment would not change the bank’s reserves strategy or affect its ability to conduct foreign exchange interventions or monetary policy.

The portfolio composition included Bitcoin, alongside a US dollar stablecoin and a tokenized deposit.

The Czech National Bank Board set the total allocation at $1 million and committed that the volume would not be actively increased, though composition might shift during small test operations.

The stated purpose centered on building operational and risk-management expertise rather than generating investment returns or diversifying reserves. This structure mattered because it sidestepped the authority of the European Central Bank (ECB).

The European System of Central Banks (ESCB) Statute specifies that Member States with derogations from euro adoption do not fall under certain key articles that bind eurozone national central banks, including Article 14.3 on ECB guidelines and instructions, and Articles 30 and 31 governing reserve transfers and operations.

The Czech National Bank operates as part of the European System of Central Banks but not the Eurosystem, with its governor sitting on the ECB’s General Council rather than the Governing Council, where euro area monetary policy decisions occur.

Which Countries Could Follow Czech Model

Five other EU Member States share the Czech Republic’s derogation status and could, in theory, replicate the experiment: Hungary, Poland, Romania, Sweden, and Bulgaria.

Bulgaria represents a special case because it received clearance to adopt the euro on January 1, 2026, meaning its window for Czech-style experiments closes at that entry date.

Denmark does not share this status despite remaining outside the eurozone because it holds a formal treaty opt-out rather than a derogation, placing its central bank in a different legal category from the Czech National Bank.

The key constraint for these countries remains separation from official reserves. The ECB framework defines official reserve assets as monetary gold, Special Drawing Rights, IMF reserve positions, and “other reserve assets” in convertible foreign currencies.

Bitcoin fits none of these categories.

ECB President Christine Lagarde stated on January 30 that reserves must be liquid, secure, safe, and not “plagued by the suspicion of money laundering or other criminal activities,” adding that she remainedcconfident that

Eurozone Central Banks Face Tighter Restrictions

Eurozone national central banks operate under substantially tighter constraints.

Article 31 of the ESCB Statute requires that national central bank operations in foreign reserve assets above thresholds set by the ECB Governing Council require explicit approval to ensure consistency with exchange-rate and monetary policy.

The ECB can issue binding guidelines under Article 14.3 that restrict specific asset classes if they threaten policy consistency or financial soundness.

Even if a eurozone central bank attempted to hold Bitcoin outside the official reserves framework in an investment portfolio, it would still operate “within the guidelines set by the ECB to safeguard the single monetary policy.”

The same ECB that assigned a 1,250% risk weight to crypto exposures under the Capital Requirements Regulation would likely challenge any material Bitcoin position on a central bank balance sheet.

The approval process for a eurozone central bank would be lengthy.

The central bank would have to bring the proposal through Eurosystem committees into the Governing Council agenda, obtaining Article 31.3 approval for operations above the set limits.

Additionally, this could trigger Member State consultation requirements under Article 127(4) of the Treaty on the Functioning of the European Union if national law changes were involved.

The ECB could veto under Article 31.3, issue binding guidelines under Article 14.3, or ultimately refer a matter to the Court of Justice of the European Union for failure to fulfill Statute obligations.

D’Agostino’s prediction that “more Eurozone companies following suit very, very shortly” hinges on whether other derogation-status central banks view the Czech experiment as successful.

Not only that, but they need a similar institutional appetite for operational learning in digital assets.

Nevertheless, the Czech National Bank’s careful ring-fencing suggests the model remains available for non-eurozone EU members willing to accept similar constraints.