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2026 Proof of Custody. Published by Onramp Bitcoin. Editorial Independence.PrivacyTermsproofofcustody.io
Situation

I am a financial adviser choosing custody for client bitcoin. What does the rule require?

It depends on whether the custodian meets the adviser custody rule, Advisers Act Rule 206(4)-2: a bank, broker-dealer, futures commission merchant or an entity the adviser has a documented basis to treat as a qualified custodian, with client assets segregated and identifiable. Multi-institution arrangements can meet it where the keyholding institutions are themselves qualified custodians; the brief on this site tests exactly that. Read the regulatory column and the qualified-custodian column, then run the brief.

What decides it
  • Qualified custodian status of the keyholders
  • Segregation and client identification
  • Account statements and examination reports

Which custody models fit, by the published rules

Fit engine rules 0.1 (1 Nov 2026), with this situation's inputs preset. Adjust the inputs to your own case. Proof of Custody is published by Onramp Bitcoin, which appears here where its custody model fits and is scored by the same methodology as every other platform.

Multi-institution custody
fits · 90
  • The recoverer works with identity documents and institutions, not devices.
  • Built for entities: segregated accounts, named authorisers and an audit trail.
  • Long horizons favour structures that do not depend on one party staying solvent and competent.

Recovery: Identity and authority documents to the institutions; no device, seed or ceremony on the heir's side.

Onramp90publisherOnramp Lending83publisher
Qualified custodian
fits · 80
  • The recoverer works with identity documents and institutions, not devices.
  • Built for entities: segregated accounts, named authorisers and an audit trail.

Recovery: Identity and authority documents to the custodian; the custodian's own succession procedure.

Onramp Finance89publisherFidelity Digital Assets76Choice by Kingdom Trust73Choice by Kingdom Trust73BitGo71Sygnum70
Spot bitcoin ETF
fits · 70
  • The recoverer works with identity documents and institutions, not devices.

Recovery: The brokerage's beneficiary or estate process; no keys involved.

iShares Bitcoin Trust (IBIT)77Fidelity Wise Origin (FBTC)76Bitwise Bitcoin ETF (BITB)74ARK 21Shares (ARKB)70Franklin Bitcoin ETF (EZBC)70Grayscale Bitcoin Mini (BTC)69
Exchange or single-custodian account
partial · 60
  • The recoverer works with identity documents and institutions, not devices.
  • A trading account at the same company that runs the venue is the arrangement the registry's corporate losses share.

Recovery: Prove identity and, for an estate, present letters of administration to the company's support desk.

River82Swan Bitcoin80Fidelity Crypto74Strike74Strike (Global)70Cash App69
Collaborative multisig
partial · 45

Fits only where the provider documents an assisted inheritance path the recoverer can follow with support; otherwise the arrangement becomes a puzzle box the day you are gone.

  • Long horizons favour structures that do not depend on one party staying solvent and competent.

Recovery: Locate the devices and seed backups, run a signing ceremony with the provider's key; or, where the provider documents an assisted inheritance path, follow that path with the provider.

Unchained85Unchained84Casa82Unchained IRA81Unchained IRA81Unchained Lending80

Excluded by the rules: Self-managed multi-vendor multisig (Recovery floor: this model requires the recoverer to run a hardware wallet and handle a seed phrase, and the person you named cannot be expected to.); Single-signature hardware wallet (Recovery floor: this model requires the recoverer to run a hardware wallet and handle a seed phrase, and the person you named cannot be expected to.)

These are custody models that fit the situation described, by Proof of Custody's published rules, version 0.1 (1 Nov 2026). They are not a recommendation to buy, sell, move or hold anything, and not legal, tax or estate advice.

Tests to run on any provider you shortlist

RIA that must use a qualified custodian

A registered investment adviser holds client bitcoin and must satisfy the SEC custody rule for advisers, Advisers Act Rule 206(4)-2.

  • The custodian is a bank, broker-dealer, futures commission merchant or an entity the adviser has a documented basis to treat as a qualified custodian
  • Client assets are segregated from the custodian's proprietary assets and identifiable to each client
  • Independent verification of holdings on a stated cadence
  • The custody agreement prohibits lending, pledging or transferring client assets without the client's consent
Routing row BIZ-02

Agent tool: assess_custody_independence. Primary sources: sec-edgar-fts, sd-banking, nydfs-vc. Refresh: quarterly. All routes.

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