Crypto Law Profile
Tennessee SB2639 would have authorized the state treasurer to invest limited eligible state funds in Bitcoin. It was not enacted before the 114th General Assembly adjourned.
The Tennessee Strategic Bitcoin Reserve Act was a 2026 Tennessee Senate bill, SB 2639, paired with House Bill 1695, that would have amended Tennessee Code Annotated, Title 9, Chapter 4 to authorize a state-managed Bitcoin reserve. As of June 4, 2026, the measure was not enacted: LegiScan lists the Senate bill as introduced and last placed on the Senate Finance, Ways and Means Committee calendar for April 21, 2026, and the 114th General Assembly’s regular session adjourned sine die on April 23. Because bills from the 114th General Assembly do not carry over to the 115th General Assembly, the proposal would need reintroduction to move forward in 2027.
SB 2639 framed Bitcoin as a decentralized digital commodity with limited supply and continuous global liquidity. The bill’s findings stated that inflation can reduce the purchasing power of state-held assets and that a fiduciary investor may diversify a long-horizon public portfolio into such a commodity. The operative intent was permissive rather than mandatory: it would have authorized, but not required, the Tennessee State Treasurer to allocate a limited portion of eligible state funds to Bitcoin, subject to custody, security, and reporting safeguards.
The bill would have allowed the Treasurer to invest money from the general fund, the revenue fluctuation reserve, and any other state fund expressly designated by the General Assembly. At purchase, Bitcoin held in or for each eligible fund could not exceed 10% of that fund’s total assets. The bill also would have limited acquisitions to 5% of a fund’s assets in a single fiscal year until the 10% ceiling was reached, while allowing passive appreciation above the cap unless the Treasurer directed otherwise.
SB 2639 was limited to Bitcoin. It defined Bitcoin separately from cryptocurrency and digital commodity, and stated that the proposed part would not authorize public funds to be invested in any digital asset, digital commodity, or cryptocurrency other than Bitcoin. It also allowed three holding routes: direct state custody through a secure custody solution, custody by a qualified custodian, or exposure through a U.S.-regulated exchange-traded product deriving value exclusively from underlying Bitcoin.
The custody provisions were detailed for a state-level crypto bill. A secure custody solution would have needed encrypted, non-network-connected hardware in at least two geographically distinct secure facilities; encrypted channels; multi-party governance; role-based controls; immutable audit logs; annual third-party code review and penetration testing; and disaster-recovery testing. Any qualified custodian would have needed ongoing supervision by its primary banking regulator, a recent SOC 2 Type II report, and insurance coverage commensurate with assets under custody.
The proposal also barred any single private person or private entity from holding or controlling a full private key or key shard that could unilaterally transfer state-owned Bitcoin. By July 1, 2028, the Treasurer would have had to design and maintain an internal self-custody process, and once operational, hold at least 10% of aggregate state-owned Bitcoin through that procedure.
SB 2639 was introduced on February 2, 2026 by Senator Kerry Roberts and was recommended for passage by the Senate Commerce and Labor Committee on March 10 with an 8-0 vote and one member not voting. The Senate bill’s last recorded action was placement on the Senate Finance, Ways and Means Committee calendar for April 21. The House companion, HB 1695, was taken off notice in the House Finance, Ways and Means Subcommittee on April 15.
If enacted, the bill would have taken effect July 1, 2026. It would have required an investment-policy statement by January 1, 2027, biennial public reporting by October 1 of each even-numbered year, and a comprehensive performance and risk evaluation by October 1, 2032. Because the bill did not become law, those implementation dates should be read as proposed deadlines only, not current Tennessee legal obligations.
Would have authorized investment in Bitcoin only, excluding other digital assets, digital commodities, and cryptocurrencies.
Would have covered the general fund, revenue fluctuation reserve, and designated state funds, capped at 10% per fund at purchase.
Would have limited acquisitions to 5% of a fund’s assets in a fiscal year until the 10% ceiling was reached.
Would have allowed direct state custody, qualified custodian custody, or U.S.-regulated Bitcoin ETP exposure aggregated into the cap.
Would have required written custody procedures, SOC 2 Type II materials, insurance, audits, and no unilateral private-key control.
Would have required biennial reports on holdings, value, activity, gains or income, and cryptographic proof of balances.
Would have let the treasurer establish a voluntary Bitcoin payment program for state taxes, fees, or other obligations.
SB2639 was filed, introduced, and passed on first consideration in the Senate.
Passed on second consideration and referred to the Senate Commerce and Labor Committee.
Senate Commerce and Labor recommended passage and referred the bill to Finance, Ways and Means.
Placed on the Senate Finance, Ways and Means Committee calendar for April 21, 2026.
HB1695 was taken off notice in the House Finance, Ways and Means Subcommittee.
The 114th General Assembly adjourned sine die; the proposal was not enacted.
Qualified custodians, Taxpayers and Payors
Bitcoin
As of June 4, 2026, this profile treats SB2639 as not enacted after the 114th Tennessee General Assembly adjourned sine die. Tennessee and LegiScan bill pages may still show the bill’s last committee action.
