In 1997, Bernhard Billeter proposed a harpsichord toccata original, which was deemed unlikely by Williams. However, Billeter's argument makes authorship by Bach more likely: Bach's harpsichord toccatas (most of them early works) have simplistic elements and quirks similar to BWV 565. Bach's early keyboard works, especially the free ones like Preludes and Toccatas, cannot always be clearly separated into organ pieces and harpsichord pieces. Spitta had already remarked on the similarity between a passage in BWV 565 and one in the harpsichord Prelude BWV 921; Robert Marshall compares the continuation patterns and sequences of the harpsichord Toccata BWV 911, and the Fugue theme of the harpsichord Toccata BWV 914, with the same of BWV 565.
