Forward Industries Proposes Three-Tier Digital Asset Treasury Framework

Forward Industries has proposed a digital asset treasury framework that classifies on-chain treasuries into three tiers based on the degree of actual management discretion exercised by operators. According to ChainCatcher, the framework urges regulators to move away from blanket treatment and instead distinguish between use, follow, and advisor models. Under the proposal, Type I treasuries function as code tools with investment and lending parameters set entirely by end users, while developers only maintain and upgrade the underlying software. Type II treasuries use pre-set automated strategies that users may choose to follow, and operators would be required to make a minimum co-investment to align incentives. Type III treasuries would be treated as active management structures, where managers have independent decision-making authority over asset allocation, rebalancing, or trading and would fall under investment adviser and stricter prudential oversight. The framework also addresses treasuries holding mixed assets, including security tokens and commodity-like digital assets such as Bitcoin and Ethereum. It recommends coordinated oversight between the SEC and CFTC through information sharing and joint filings to reduce compliance conflicts and jurisdiction gaps. In addition, the proposal calls for four baseline rules across all compliant digital asset treasuries: full disclosure of related-party transactions, public third-party smart contract audits, exclusion of bad actors under anti-money laundering and executive eligibility rules, and anti-fraud controls aligned with mature financial markets. The framework was presented as a response to regulatory uncertainty facing listed Web3 treasury companies.