Michael Saylor, a prominent Bitcoin advocate, has published a detailed critique of BIP 110, arguing that the proposed soft fork would undermine Bitcoin's neutrality, stifle innovation, and set a dangerous precedent for protocol governance. His opposition, framed as 110 distinct reasons, challenges the technical justifications and activation mechanism of the proposal, which aims to impose seven new transaction restrictions to curb data storage on the blockchain.
The Core of the Proposal
BIP 110, which reached a "Complete" status on June 25, 2026, proposes seven rule changes: limiting new scriptPubKeys to 34 bytes (with an 83-byte exception for OP_RETURN), capping witness items at 256 bytes, banning undefined witness and Tapleaf versions, disabling Taproot annexes, restricting Taproot control blocks to 257 bytes, rejecting Tapscripts containing OP_SUCCESSx opcodes, and forbidding OP_IF and OP_NOTIF in Tapscripts. It also introduces a modified BIP 9 deployment with a 55% miner signaling threshold, mandatory signaling periods, and an expiration state after 52,416 blocks. While the proposal includes a grandfather clause for UTXOs created before activation, Saylor argues that even temporary rules carry lasting consequences for the ecosystem.
Neutrality and Fundamental Principles
Saylor contends that consensus is Bitcoin's most powerful tool and should only be used to fix clear, severe bugs, not to address controversial externalities. He argues that BIP 110 elevates value judgments into protocol law, effectively deciding what counts as a "legitimate" transaction. Bitcoin cannot distinguish between images, contracts, or future innovations, so structural restrictions inevitably harm both benign and malicious uses. He emphasizes that a permissionless system must tolerate unapproved experimentation, and that changing protocol rules to express displeasure with certain uses sets a dangerous precedent.
Failure to Meet the Burden of Proof
According to Saylor, BIP 110 fails to quantify the problems it claims to solve. It does not measure the actual node burden from data storage, nor does it model the expected reduction in fees or improvement in decentralization. The proposal asserts urgency without defining operational thresholds for what constitutes a crisis. The 256-byte limit is described as empirical, but Saylor argues it lacks rigorous justification. He also notes that bundling seven unrelated changes into one proposal forces users to accept or reject them as a package, preventing a more targeted approach.
Technical Overreach and Lost Upgrades
Saylor warns that BIP 110 closes multiple future upgrade paths, including the Taproot annex, undefined witness and Tapleaf versions, and OP_SUCCESSx opcodes, which were intentionally reserved for future improvements. The 257-byte control block limit reduces the maximum Taptree depth to seven layers, potentially complicating designs like BitVM and Miniscript. The proposal itself acknowledges that some restrictions may hinder advanced off-chain constructions. Saylor argues that shutting down these options without a pressing security reason sacrifices long-term flexibility for short-term expedience.
Complexity of Temporary Rules
Even temporary consensus rules add permanent complexity, Saylor argues. Grandfather clauses create state-dependent logic that every implementation must handle consistently. The activation and expiration boundaries introduce coordination risks, and the modified BIP 9 deployment lacks a FAILED state, making it harder for the network to reject an unpopular proposal. He points out that wallet code, operational processes, and risk controls may need changes that outlast the rule's effective period.
Economic and Security Uncertainties
Saylor questions whether BIP 110 would actually reduce fees or improve security. He notes that miners earn fees from all transactions, and suppressing certain uses could lower total fee revenue, potentially reducing miner incentives and network hash rate. The proposal does not model these trade-offs. He also highlights that users can circumvent restrictions by fragmenting data or encoding it within allowed structures, potentially increasing overall resource consumption.
Better Tools Exist
Instead of changing consensus rules, Saylor advocates for content-neutral approaches: block weight limits, fee markets, relay policies, and miner discretion. He argues that these tools can manage resource usage without requiring the protocol to judge transaction intent. He calls for more research into resource pricing that directly ties fees to measurable costs like bytes, state, and computation, rather than imposing blanket bans based on perceived purpose.
Chilling Innovation and Adoption
Saylor warns that BIP 110 could deter developers from building on Bitcoin, fearing that their applications might be banned in the future. He argues that protecting "known monetary uses" freezes the protocol at its current state, ignoring the possibility that future innovations could strengthen Bitcoin's monetary properties. He specifically mentions potential impacts on advanced contracts, Layer 2 systems, and financial applications that rely on today's upgrade hooks.
Activation Concerns
The proposed 55% miner threshold is a significant departure from the traditional 95% standard. Saylor argues that controversial restrictions require higher, not lower, consensus. The mandatory signaling period and forced lock-in height create coordination pressure that could lead to a chain split if major economic actors disagree. He warns that even a temporary split could disrupt liquidity, custody, and user confidence.
The Precedent Problem
Saylor's most fundamental objection is that BIP 110 would set a precedent for using consensus rules to suppress disfavored activities. Future groups could label any use case as "non-monetary" and seek similar restrictions. He argues that once the protocol becomes a battleground for value judgments, governance shifts from technical debate to political power struggles. The social capital needed to address real threats would be depleted by repeated fights over use cases.
A Better Path Forward
Saylor concludes by proposing alternatives: participants can choose not to use, relay, or mine data-heavy transactions without changing protocol rules. He calls for better measurement of resource costs, improved fee market transparency, and continued research into off-chain solutions. He urges the community to preserve Bitcoin's upgrade hooks and focus on content-neutral improvements rather than purpose-based restrictions.