Accounting Guidance - Crypto and Digital Assets

IFRS, US GAAP, Europe and UK Perspectives (2026 Update)

Digital assets have moved from a niche investment class to a mainstream consideration for corporates, financial institutions, investment funds, and treasury functions. As organisations increasingly hold cryptocurrencies, stablecoins, tokenised assets, and participate in staking and decentralised finance (DeFi) activities, understanding the accounting implications has become essential.

While the United States has introduced dedicated accounting guidance for certain crypto assets, IFRS, the European Union, and the United Kingdom continue to rely largely on existing accounting standards and professional judgment.

This article provides an overview of the latest accounting guidance and key considerations under IFRS, US GAAP, Europe, and the UK.

IFRS

No Dedicated Crypto Accounting Standard

Currently, IFRS does not contain a standalone accounting standard for cryptocurrencies or digital assets.

Instead, entities apply existing standards based on the nature of the asset:

• IAS 38 Intangible Assets – generally applies to cryptocurrencies such as Bitcoin and Ether.

• IAS 2 Inventories – applies when digital assets are held for sale in the ordinary course of business by broker traders.

• IFRS 9 Financial Instruments – may apply to tokenised securities, certain stablecoins, and other assets that contain contractual rights.

Measurement

For digital assets classified under IAS 38:

• Initial recognition at cost (including transaction fees/acquisition costs).

• Subsequent measurement using either:

  • Cost model, or

  • Revaluation model (where an active market exists).

This often results in accounting outcomes that differ significantly from the economic value of the assets.

US GAAP

Fair Value Accounting for Crypto Assets

The most significant recent development is the introduction of ASC 350-60, following FASB's ASU 2023-08.

For qualifying crypto assets, entities must:

• Measure assets at fair value each reporting period.

• Recognise all unrealised gains and losses in net income.

• Provide enhanced disclosures regarding holdings and restrictions.

Practical Impact

Under the previous model, companies could recognise impairment losses but not unrealised gains. The new fair value approach provides more relevant financial information but introduces greater earnings volatility.

Europe

Regulatory Progress Through MiCA

The European Union has not introduced a dedicated accounting standard for digital assets.

However, the implementation of the Markets in Crypto Assets Regulation (MiCA) represents a major regulatory milestone.

MiCA establishes:

• Crypto asset classifications

• Licensing requirements

• Governance standards

• Disclosure obligations

• Stablecoin regulation

Importantly, MiCA regulates crypto markets but does not determine accounting treatment.

Companies reporting under IFRS continue to apply IAS 38, IAS 2, IFRS 9, and related standards.

United Kingdom

Existing Standards and Professional Guidance

The UK has similarly not issued a dedicated crypto accounting standard.

Entities reporting under UK GAAP continue to apply:

• FRS 102

• Existing financial reporting principles

• Professional guidance issued by the ICAEW and other bodies

The accounting treatment depends on the characteristics of the digital asset and may result in classification as:

• Intangible assets

• Inventory

• Financial instruments

• Cash equivalents (in limited circumstances)

Professional judgment remains critical.

Emerging Areas Requiring Judgment

As digital asset markets evolve, accountants increasingly encounter assets and transactions that do not fit neatly within existing standards.

Stablecoins

Depending on their structure, stablecoins may be treated as:

• Intangible assets

• Financial instruments

• Cash equivalents (rarely)

Tokenised Financial Instruments

Tokenised bonds, shares, and other securities are generally accounted for as financial instruments rather than crypto assets.

Staking Rewards

Entities must determine:

• When rewards are earned

• Whether they represent revenue or other income

• How they should be measured

  
  

Wrapped Tokens

Accounting depends on the legal rights attached to the token and whether enforceable claims exist over the underlying asset.

NFTs

NFTs are typically treated as intangible assets, although accounting depends on the rights represented by the token.

DeFi Lending and Liquidity Pools

DeFi arrangements often require complex assessments of:

• Control

• Derecognition

• Revenue recognition

• Financial instrument classification

These remain among the most challenging areas of digital asset accounting.

Key Differences Between IFRS and US GAAP

Area	IFRS	US GAAP
Dedicated Crypto Standard	No	Yes (ASC 350-60)
Common Classification	Intangible Asset (IAS 38)	Crypto Asset (Fair Value Model)
Subsequent Measurement	Cost or Revaluation	Fair Value
Gain Recognition	Often OCI under revaluation model	Net Income
Earnings Volatility	Lower	Higher
Crypto Specific Disclosures	Limited	Extensive

Conclusion

Digital asset accounting continues to evolve rapidly.

While IFRS, Europe, and the UK largely rely on existing accounting standards and professional judgment, US GAAP has moved toward a dedicated fair value model for qualifying crypto assets.

For finance professionals, the most important consideration is understanding the underlying rights and economic substance of each digital asset. This is particularly relevant for emerging areas such as stablecoins, tokenised assets, staking arrangements, NFTs, and DeFi protocols, where accounting outcomes can differ significantly depending on structure and jurisdiction.

As adoption of digital assets continues to grow, organisations should ensure that accounting policies, governance frameworks, and disclosure practices remain aligned with evolving standards and regulatory expectations.

If you'd like to discuss how we can support your accounting and financial reporting requirements, we would be delighted to to hear from you. Please reach out to paul.young@anomalyinternational.com for further information on how we can help.

*Please note that this article is intended as a general guide only and should not be relied upon as legal or professional advice. We recommend seeking tailored advice for your specific circumstances.