333D Limited has responded to ASX queries, clarifying that its Bitcoin Treasury Management Policy approval is not price sensitive, while disclosing a $370,500 Bitcoin acquisition funded partly by R&D tax incentives.
- Bitcoin Treasury Management Policy approval deemed non-price sensitive
- Material Bitcoin acquisition of 2.0183 BTC completed in late August 2025
- Acquisition funded partly by $413,772 Research and Development Tax Incentive
- Board and management possess significant cryptocurrency experience
- Robust risk management and disclosure frameworks underpin crypto holdings
Background and ASX Query
333D Limited (ASX – T3D), a blockchain-focused technology company, recently addressed an ASX compliance query concerning its Bitcoin Treasury Management Policy and related market disclosures. The ASX sought clarity on whether the policy’s approval was material information likely to affect the company’s share price, especially given notable share price movements preceding public announcements.
In its detailed response, 333D Limited distinguished between the approval of the Bitcoin Policy itself and actual Bitcoin acquisitions, emphasizing that only the latter constitutes price sensitive information requiring immediate disclosure.
Bitcoin Treasury Management Policy and Market Reaction
The company formalized its Bitcoin Treasury Management Policy on 17 August 2025, establishing governance, control, and reporting frameworks for acquiring and holding Bitcoin. The policy aims to support the company’s broader business strategy by prudently managing treasury assets and identifying opportunities for returns on surplus cash.
Despite the policy’s approval, 333D Limited does not consider this event alone to be material information affecting share price. The company noted that investors primarily base decisions on its core business strategy rather than treasury management tactics, which evolve with economic conditions.
Following the 21 August announcement of the policy approval, the company’s shares rose from $0.007 to an intraday high of $0.014. However, 333D Limited attributed this price movement to market speculation rather than the policy approval itself, which was disclosed as non-market sensitive.
Bitcoin Acquisition and Funding
Significantly, 333D Limited completed two material Bitcoin acquisitions on 23 and 24 August 2025, totaling approximately 2.0183 BTC for AUD 370,500. These purchases were funded partly by a Research and Development Tax Incentive (RDTI) receipt of around $413,772, which the company clarified is not price sensitive information given its history of R&D grants.
The Bitcoin acquisitions were promptly disclosed to the market on 25 August 2025, prior to trading, in compliance with ASX continuous disclosure obligations. The company observed a further share price increase to an intraday high of $0.05 on 26 August, which it attributed to the Bitcoin purchase announcement.
Risk Management and Governance
333D Limited’s board and senior management bring substantial expertise in cryptocurrency and blockchain technology. Notably, Dr Richard Petty, a founding director of NASDAQ-listed EQONEX Limited, and Dr Nigel Finch, former director of Animoca Brands, provide seasoned oversight of crypto asset risks.
The Bitcoin Policy incorporates stringent risk controls, including position limits capped at 50% of treasury assets, use of regulated exchanges, cold storage custody, multi-factor authentication, and prohibitions on speculative trading. The board continuously monitors regulatory developments and market conditions to safeguard assets.
Strategic Implications
The company positions Bitcoin holdings as a long-term treasury reserve asset, complementing its digital asset portfolio and blockchain expertise. Bitcoin may also be used for operational settlement or converted to fiat currency when strategically advantageous. This measured approach reflects a balance between innovation and prudence in managing volatile crypto assets.
333D Limited confirmed full compliance with ASX Listing Rules, particularly continuous disclosure requirements, and affirmed that all responses were board-approved.
Bottom Line?
333D’s cautious yet strategic crypto treasury approach signals growing institutional acceptance but invites scrutiny on long-term value impact.
Questions in the middle?
- Will 333D expand its Bitcoin holdings beyond current policy limits amid market volatility?
- How will evolving crypto regulations in Australia affect 333D’s treasury management strategy?
- What impact will Bitcoin holdings have on 333D’s core business performance and investor perception?