An allocation decision ends where the finance function's work begins. Somebody has to say which balance sheet line the tokens sit on, what runs through profit this quarter, what the note must contain, and what an auditor will accept as evidence that the holding exists and is the company's.
Those answers are set in five places by bodies that rarely appear on a conference programme, and several of the texts are less than two years old. Not all four questions have a settled answer. What follows names and dates each standard. It is not accounting advice, and no substitute for your auditor's view on your own facts.
The gap on the programme
The archived Paris programme, Louvre Palace, 2–3 June 2026, ran 77 sessions across four stages. Not one was about accounting or audit. Two speakers came close: Suzanne Morsfield, then chief financial officer of Lukka, on the panel "The Current State of Global Stablecoin Rails: Payments, Settlement and Compliance", Taostats Stage, Day 2 at 14:40; and Jean-Thomas Ledore, then a partner at PwC, on the panel "Enterprise Adoption of Bittensor", same stage at 16:15. Conferences argue about instruments; standard-setters decide line items.
United States: fair value, and only for some assets
In December 2023 the Financial Accounting Standards Board issued Accounting Standards Update No. 2023-08, adding Subtopic 350-60 to the Codification: the first Subtopic in US GAAP written specifically for crypto assets.
What it replaced matters as much as what it says. An in-scope holding was previously an indefinite-lived intangible asset on a "cost-less-impairment accounting model" in which "subsequent increases in the carrying amount of the asset and reversal of an impairment loss are prohibited". Buy at 30, watch the price fall to 10 and recover to 60, and you carried it at 10 until you sold. The reason the Update gives, summarising the stakeholder feedback that prompted it: accounting "for only the decreases, but not the increases" until sale "does not provide relevant information".
The new Subtopic requires an entity to "subsequently measure assets that meet those criteria at fair value with changes recognized in net income each reporting period". Crypto assets take their own balance sheet line, and the remeasurement its own income statement line. It is effective for fiscal years beginning after 15 December 2024, interim periods included, so 1 January 2025 for a calendar-year filer, with transition by cumulative-effect adjustment to opening retained earnings; early adoption was permitted.
For a company whose principal asset is the token, every quarter's price move is now an income statement event; we have written separately on that business model. The scope, though, is tighter than most readers assume.
The six criteria that decide whether it applies
ASC 350-60-15-1 admits an asset only if it meets all six of the following, quoted verbatim:
- "Meet the definition of intangible assets as defined in the Codification"
- "Do not provide the asset holder with enforceable rights to or claims on underlying goods, services, or other assets"
- "Are created or reside on a distributed ledger based on blockchain or similar technology"
- "Are secured through cryptography"
- "Are fungible"
- "Are not created or issued by the reporting entity or its related parties"
The second criterion does most of the work: anything conferring a claim on something else falls out, including a tokenised bond, a tokenised fund share and a stablecoin redeemable against its issuer. The sixth removes a token the entity issued itself. What is left is roughly the fungible, natively issued token that carries no claim on anything else.
The Subtopic is narrower in a second way. ASC 350-60-05-2: "This Subtopic does not address the initial measurement, recognition, and derecognition of crypto assets." Those come from elsewhere in GAAP, so a staking reward, an airdrop or a transfer raising a derecognition question is not answered here. The Board's Technical Agenda Overview, revised 2 September 2026, gives the next milestone on its project on accounting for transfers of crypto assets as an exposure draft expected in the fourth quarter of 2026. No draft exists yet, let alone a standard.
IFRS: no crypto standard, and two possible homes
The International Accounting Standards Board has never written one. The governing text is an IFRS Interpretations Committee agenda decision, Holdings of Cryptocurrencies, published June 2019. No later IFRIC agenda decision has superseded or supplemented it.
Its scope is narrow in the same way the FASB's is, covering only a holding recorded on a distributed ledger that uses cryptography for security, "not issued by a jurisdictional authority or other party", and giving rise to no "contract between the holder and another party". That last characteristic is the IFRS analogue of the FASB's second criterion. The conclusion, verbatim: "The Committee concluded that IAS 2 Inventories applies to cryptocurrencies when they are held for sale in the ordinary course of business. If IAS 2 is not applicable, an entity applies IAS 38 to holdings of cryptocurrencies." It is neither cash nor a financial asset.
So the IFRS answer turns on why you hold it, and the measurement diverges sharply from the American one. Under IAS 2 the default is historical cost, with fair value less costs to sell available only to commodity broker-traders. Under IAS 38 the default is cost; the revaluation model may be elected only where an active market exists, and then, per the staff paper written for the joint FASB and IASB education meeting of September 2022, "any changes in fair value above historic cost are recognised in other comprehensive income (OCI). Any changes in fair value below historic cost shall be recognised in profit or loss."
Read that asymmetry twice. Gains above cost never touch profit; falls below cost do. The same bitcoin, in a US filer and an IFRS filer, produces different earnings. Disclosure follows the chosen home: IAS 2 paragraphs 36 to 39, or IAS 38 paragraphs 118 to 128, with IAS 10 paragraph 21 for a material post-period price move.
The same staff paper records that the IASB "decided not to add a project on cryptocurrencies and related transactions to its workplan", routing the question to research instead: "That project on Intangible Assets will review the scope of IAS 38, including whether cryptocurrencies should remain within it." The research has not taken it up. The Intangible Assets work plan, latest milestone 22 July 2026, is developing a model for customer accounting for intellectual property licensing contracts, using software-as-a-service arrangements as its test case, and mentions cryptocurrencies nowhere.
A tokenised security is not a crypto asset
Both regimes push a claim-bearing token back into ordinary financial instrument accounting: the token is a wrapper, not an asset class. The Securities and Exchange Commission staff said the equivalent thing about the law. A joint statement of 28 January 2026 from the Divisions of Corporation Finance, Investment Management, and Trading and Markets holds that "the format in which a security is issued or the methods by which holders are recorded (e.g., onchain vs. offchain) does not affect application of the federal securities laws". It reaches that conclusion on a stated assumption, not a finding: "This statement assumes that the crypto asset created to represent the security is not itself a separate security." It also says of itself that it "has no legal force or effect", the limit our jurisdictional guide sets out for staff statements generally.
When Jenny Johnson of Franklin Templeton and Caroline D. Pham of MoonPay took the Hecto Main Stage on Day 1 at 15:35 for "21st Century Cash Optimisation: Embedding Digitally Native Money Market Funds Directly into OnChain Transactions", the accounting object was a fund share. A fund share is accounted for as a fund share. The ledger changes settlement, the register and the operational risk, not the instrument.
Stablecoins and the cash equivalents question
The instrument distinctions are set out in our piece on stablecoins, tokenised deposits and money market funds; the accounting question is narrower and still open. The AICPA's practice aid is blunt: "it is impossible to provide a general rule for accounting for stablecoins." Depending on the rights attached, a holding may fall under ASC 321, ASC 323, ASC 810 or ASC 815, and the aid adds that the accounting "is not limited to the aforementioned FASB ASC topics". What it will rarely be is an ASC 350-60 crypto asset: a redemption right against an issuer is an enforceable claim, and the second scope criterion excludes it.
Whether it can sit in cash equivalents is live. In August 2026 the FASB issued a proposed Update on cash equivalents disclosure under Topic 230. The Board's own Technical Agenda Overview carries the project and gives 19 November 2026 as the comment deadline; the Journal of Accountancy and KPMG both date the issue to 18 August. It does not change the definition of a cash equivalent; it adds illustrative examples applying that definition to certain digital assets, and would require disclosure of the significant components of cash equivalents. KPMG reads the examples as demanding three attributes of a qualifying stablecoin: an on-demand contractual cash redemption right, held directly against the issuer for known amounts of cash, and segregated reserves of at least one for one in short-term, highly liquid assets. That framing is the firm's, not the Board's. It is also the question left open on the Hecto Main Stage on Day 2 at 15:50, where Emma Landriault of J.P. Morgan, David Cunningham of Consensys and Tero Reuna of Paxos discussed "The New Architecture of Digital Cash: Stablecoins, Tokenised Deposits and Money Market Funds", moderated by Ben Schiller of Miden.
The audit problem: existence and rights
A wallet address is public, which is exactly why it proves less than it appears to. The AICPA practice aid, as of 30 September 2025, puts it in one line: "the knowledge of the private key represents control of the digital assets." It then separates control from ownership: the auditor must judge whether that demonstration of control "constitutes sufficient evidence of ownership", and "may determine that substantive procedures alone are not adequate to provide sufficient audit evidence of the rights and obligations assertion." Signing a message proves you can move the coin. It does not prove the coin is yours.
Third-party custody relocates the problem rather than dissolving it. The same aid: "the custodian may commingle assets of many customers into the same addresses and maintain the custodian's own off-chain ledger", so "the blockchain is no longer representative of the entity's holdings alone." And "there is no widely accepted confirmation form or process for digital asset custodians or exchanges, similar to what exists for cash balances held at financial institutions."
The Public Company Accounting Oversight Board arrives at the same place from inspection. Its May 2020 Spotlight named the assertions at issue, from existence and occurrence through rights and obligations, and tied controls over the generation and management of private keys to the existence of crypto asset balances. Its June 2023 Spotlight records real deficiencies: auditors who "did not evaluate the relevance and/or reliability of" information downloaded from self-custodied wallets, external providers' data, or third-party pricing information. On rights it notes that procedures may have to differ from those for other assets "because of the pseudo-anonymity ... of the transacting parties on public distributed ledgers", and that third-party confirmations "may not be available."
Neither body claims authority for this material. The 2020 Spotlight says it "is not staff guidance"; the 2023 one says it "is not a rule, policy, or statement of the Board". The practice aid is expressly nonauthoritative, representing the views of the AICPA's Digital Assets Working Group and AICPA staff and "not an official pronouncement of the AICPA". It is the best material available on existence and rights, and it is not a standard. Internationally there is less: the IAASB has no digital-asset auditing standard, its exposure draft revising the audit evidence and risk response standards only went out for comment in early August 2026, and crypto-asset audit challenges sit in its technology catalogue as a matter needing attention rather than a standard-setting project.
A proof-of-reserves report is relevant here, and insufficient: an attestation over a moment rather than a financial statement audit, and no answer to rights and obligations. We have set out what it does and does not establish. The people who live with the problem were on stage: "How Institutions Actually Access Tokenised Assets", Taostats Stage, Day 2 at 10:00, with Fabian Dori of Sygnum, Julian Sawyer of Zodia Custody, Matthew Felice Pace of Spectrum Nodes and Moritz Platt of Google, moderated by Xavier Gomez of Vancelian.
What a listed holder has to disclose
ASU 2023-08 sets two tiers. Interim and annual: the name, cost basis, fair value and number of units for each significant holding, aggregate fair values and cost bases for the rest, and, where contractual sale restrictions apply, the fair value, the nature and remaining duration of the restriction and the circumstances that could cause it to lapse. Annually, in addition: a rollforward of the period's activity, with additions and dispositions described by the activity that produced them; for disposals, the difference between disposal price and cost basis; the income statement line carrying gains and losses if they are not presented separately; and the method for determining cost basis.
The SEC layer moved the other way. Staff Accounting Bulletin No. 121, issued 24 March 2022, told an entity safeguarding crypto assets for platform users to "present a liability on its balance sheet to reflect its obligation to safeguard the crypto-assets held for its platform users", with a corresponding asset, both measured at the fair value of the assets held. Staff Accounting Bulletin No. 122, issued 23 January 2025 and effective 30 January 2025, rescinded it. In its place an entity "should determine whether to recognize a liability related to the risk of loss under such an obligation", applying the contingency requirements in ASC 450-20 or IAS 37, on a "fully retrospective basis in annual periods beginning after December 15, 2024".
The disclosure duty survived the balance sheet change. SAB 122 tells entities to "continue to consider existing requirements to provide disclosures that allow investors to understand an entity's obligation to safeguard crypto-assets held for others", pointing to Regulation S-K Items 101, 105 and 303, ASC 450-20 and ASC Topic 275. The Corporation Finance staff statement of 10 April 2025 sets expectations for an issuer's business description and risk factors, offers no crypto-specific accounting guidance, and notes that issuers "may also consult with the SEC's Office of the Chief Accountant on accounting and financial reporting questions, especially those involving unusual, complex, or innovative transactions."
Four questions to ask before the allocation, not after
- Does the holding meet all six criteria in ASC 350-60-15-1, or the characteristics in the June 2019 IFRIC decision? If it carries a claim on anything, no.
- Under IFRS, is it held for sale in the ordinary course of business? That chooses between IAS 2 and IAS 38, and whether an unrealised gain ever reaches profit.
- Can the custodian evidence rights, not only control? Ask before signing the mandate.
- Who else holds a key to the address? The answer belongs in the related party analysis.
The instruments keep changing. Line items change more slowly, and two of these questions are still open: how transfers are accounted for, and whether a stablecoin can be a cash equivalent.
Proof of Talk convenes its inaugural Gulf edition at the Louvre Abu Dhabi, Saadiyat Cultural District, on 3–4 December 2026, and returns to the Musée des Arts Décoratifs at the Louvre Palace in Paris on 2–3 June 2027. Both are capped, and admission is by application and review. The full Paris 2026 session record is published; access to Abu Dhabi is by application. Those rooms will argue about the instruments again, and somebody in each will have to book the result.