What Bakkt Holdings, Inc. told the SEC could break it.

Bakkt's customer base is highly concentrated — its three largest customer balances were ~89.30% of total trade accounts receivable at year-end 2025 (99.95% in 2024) — so loss of a top crypto-trading client would materially affect revenue and collections.

“As of December 31, 2025 and December 31, 2024, the three largest customer balances represented approximately 89.30 % and 99.95 %, respectively, of total trade accounts receivable.”

Substantially all of Bakkt's net revenue each quarter comes from in-quarter crypto transactions (crypto services revenue fell 32% to $2.34B in 2025 from $3.44B), causing significant operating-result fluctuations tied to volatile digital-asset trading volumes.

“Substantially all of our net revenues each quarter come from transactions that occur during that quarter, which has resulted in, and may continue to result in, significant fluctuations in our operating results.”

Some of Bakkt's vendors are sole or one of a limited number of sources for their services — for example, only a limited number of providers can supply the credit needed for high-volume institutional trading on ECNs such as the planned BakktX ECN.

“In some cases, vendors are the sole source, or one of a limited number of sources, of the services they provide to us. For example, there are a limited number of service providers that can provide the credit needed to facilitate high-volume institutional trading on ECNs, such as the BakktX ECN we plan to launch.”

Bakkt's BFS subsidiary operates under a New York BitLicense and state money-transmitter licenses subject to evolving digital-asset regulation, AML, and OFAC sanctions requirements; non-compliance could bring enforcement actions, penalties, or loss of licenses.

“BFS holds a New York State virtual currency license (commonly referred to as a “BitLicense”) and money transmitter licenses from all states throughout the U.S. where su”