Chinese Companies Imitate Strategy Despite Bitcoin Restrictions

• Zhibao received 2,380 BTC in exchange for a private issuance of shares and warrants.
• Ten companies linked to China hold a total of 11,577 BTC in their treasuries.

While China maintains one of the most restrictive policies towards digital assets, at least ten companies linked to the country appear in the rankings of corporate bitcoin (BTC) treasuries, collectively holding 11,577 BTC.

Zhibao Technology has just become the latest to strengthen this group. It did so on August 17 through the InsurTech company, which provides digital insurance brokerage services through its operating entities in China and is listed on Nasdaq. Through this mechanism, the company closed a private placement for $154.7 million, which investors paid directly with 2,380 BTC, as reported by CriptoNoticias.

The apparent contradiction has an explanation. The Chinese government reaffirmed in February 2026 that business activities related to virtual currencies are illegal financial activities. However, several of the companies classified as Chinese in the bitcoin treasury rankings are listed on foreign markets or have corporate structures outside the mainland territory.

Zhibao does not inaugurate this strategy among Chinese companies. Next Technology Holding currently leads the ranking with 5,833 BTC, and Nano Labs holds another 1,000 BTC. This is the pathway through which the model popularized by Strategy, the company with the largest bitcoin treasury in the world, begins to find versions among companies linked to the country.

Zhibao ranks second among the companies classified as Chinese by Bitcoin Treasuries. Above it is Next Technology Holding, with 5,833 BTC, while Nano Labs occupies the third position with 1,000 BTC. In total, the ranking gathers 11,577 BTC distributed among ten companies, valued collectively at around $744 million.

The classification requires clarification. That a company appears under the "China" category does not necessarily mean it is acquiring bitcoin from a company established in mainland China. It may relate to its origin, operations, or corporate ties with the country.

Next Technology Holding illustrates this difference well. The company maintained operations through subsidiaries in China but informed the U.S. Securities and Exchange Commission (SEC) that it ended all its operations in that country during the third quarter of 2024 and moved its software services abroad. Subsequently, the acquisition and holding of bitcoin became part of its corporate strategy.

Its position of 5,833 BTC makes it the largest holder in the group and demonstrates that Zhibao's arrival does not constitute the first attempt to transfer the bitcoin treasury model to companies linked with China.

Nano Labs offers another example. The company, which is also listed on Nasdaq, appears in the ranking with 1,000 BTC in its treasury. Its presence also expands the phenomenon beyond a single sector: while Zhibao operates in InsurTech and Next Technology in software, Nano Labs is linked to integrated circuit design.

These figures are not yet comparable to Strategy's reserves. What is relevant is not the scale, but that several cases are beginning to draw the same pattern. The mechanism of using a listed company and capital markets to build a bitcoin treasury is no longer exclusively American.

Zhibao's operation has a particularity. The company did not raise dollars to subsequently go to the market to buy bitcoin.

Zhibao agreed to issue 442 million Class A ordinary shares accompanied by an equal number of warrants, at a combined price of USD 0.35 per share and warrant. Investors paid for the operation by contributing the 2,380 BTC to the portfolio designated by the company.

"The successful closure of this $154.7 million investment marks one of the most transformative moments in Zhibao's 10-year history," stated Botao Ma, the company's director.

Here, an interesting difference appears with Strategy. Michael Saylor's company popularized a mechanism based on using stock issuances, debt, and other instruments to obtain resources and allocate them to accumulate BTC.

Zhibao shortened the circuit: it issued securities and received bitcoin directly as compensation.

Moreover, the financing was carried out with non-U.S. investors under Regulation S of U.S. legislation. Therefore, describing the operation simply as "a Chinese company buying bitcoin" omits a fundamental part of the case. Zhibao's activity is linked to China, but the financial structure that allowed it to incorporate BTC goes through international markets.

This operation thus introduces a variant within a trend that other companies linked to China have already been developing. Not all follow exactly the Strategy formula nor accumulate BTC in the same way, but they share the use of corporate structures and international markets to incorporate it into their balances.

The fact that more and more companies are betting on BTC does not imply a change in position from the Chinese government.

In February, the People's Bank of China (PBOC) and other authorities reinforced the regulatory framework on digital assets. Virtual currencies continue to lack legal tender status, and business activities related to them remain prohibited as illegal financial activities on the mainland.

Precisely for this reason, it matters where and how these treasuries are being built. Zhibao is listed on Nasdaq and carried out its financing with non-U.S. investors under Regulation S of U.S. legislation. Next Technology, for its part, moved its operations outside of China.

Therefore, these treasuries are not evidence that China is accumulating bitcoin nor of state competition with the United States. The signal is more limited but more interesting: these firms use foreign structures and markets to adopt a strategy that the regulatory environment on the mainland complicates.

The corporate treasury strategy is internationalizing, but not necessarily always following the same path. In the case of these companies linked to China, the model finds space precisely where the regulatory borders of the mainland market end.