February 19, 2021 Reading Time: 4 minutes

Accounting standards developed for the 20th century are not equipped to deal with 21st century crypto assets. Assuming otherwise creates inaccurate and diminished financial reporting. 

Recent headlines by the likes of Tesla, Microstrategy, and BNY Mellon, as well as statements by market titans such as Ray Dalio and Jeff Gundlach illustrate one consistent point; crypto is part of the mainstream financial conversation. 

Bitcoin especially has come a long way from its early days as a cypherpunk-themed movement to create an alternative financial and payment system. In the context of 2021, bitcoin and other crypto are actually starting to become somewhat boring; just another asset class and investment opportunity for institutional investors, financial institutions, and retail investors alike versus a world changing idea.

If the story ended there, well, it would all sound pretty mundane. Unfortunately, that is only the surface, and these headlines obscure an extremely important problem that remains unaddressed; the accounting for crypto as it currently stands makes no business sense. That’s right, something as under-the-radar as accounting standards are quickly becoming a significant issue as crypto adoption and investment accelerates. 

Let’s dig in. 

The Problem 

There is currently no widely accepted authoritative accounting guidance for crypto. Certain specific countries have implemented unique approaches that stand apart, but these are not widely adopted outside of these countries. In the accounting world, the two standard setting bodies are the Financial Accounting Standards Board (FASB), and the International Accounting Standards Board (IASB). It is true that the IASB has proven more flexible in terms of crypto accounting; there are no authoritative standards to that effect. In the US, and despite worthwhile efforts by the American Institute of CPAs (AICPA) to publish non-authoritative research, the FASB has so far refused to consider the issue of crypto-specific accounting guidance. 

In the face of no authoritative standards, a consensus has developed that crypto should be treated as an indefinite lived intangible asset (like goodwill) for financial reporting purposes. At first glance this all seems fine since crypto is intangible and has no fixed expiration date. Peeling back the layers of this treatment, however, quickly reveals how inappropriate this classification is for crypto. 

Following the rules of accounting for indefinite lived intangible assets, these assets are held on the balance sheet at the price paid for them (cost) less any impairment charges. Impairment, without getting overly technical, is a process by which assets are evaluated to see whether or not the book value is reflective of market value. If the market value has decreased, the asset is written down and an expense is recorded. Under US accounting standards, there is one other wrinkle to keep in mind; once an asset has been written down it cannot be written back up no matter what the market valuation becomes. 

This accounting treatment might be fine for goodwill, an asset created due to paying more than the fair market valuation of an organization (think M&A) would imply, but does not work for crypto. Under this current treatment, any organization that invests in crypto will have to record this investment at cost, and mark it down whenever conditions trigger an impairment test, and would never be able to mark this asset back up. 

Crypto is still a volatile market, and even just in 2021 there have been double-digit percentage swings in prices for bitcoin and innumerable other crypto. Treating crypto as the current consensus would indicate creates a situation where economic realities are not accurately represented. 

Think about it, is any other widely traded and free-floating commodity or equity-like instrument treated this way? No. Why? Because it does not make business sense and diminishes the usability of financial reporting. 

Potential Solutions 

There are two possible solutions that could ultimately be implemented given the rapid proliferation of crypto on corporate balance sheets. Again, there is no widely implemented crypto-specific guidance, and these approaches do not align with current market consensus. 

Option #1 is the simplest approach, and would involve choosing to treat, record, and report crypto investments as a commodity-like instrument. This would allow the changes in market value to be reported as they occur on the balance sheet, and be reported on the income statement (or through other comprehensive income). Implementing this approach, modifying existing standards to reflect an emerging asset class, would increase the transparency and usability of financial reporting. 

A second option, and one that in a perfect world would already be in the pipeline at standard setters, is the development of entirely new standards for this entirely new asset class. Obviously this would take more time, require more input, and necessitate high levels of collaboration, but the following framework might make sense. Classifying different crypto depending on use case (currency alternative, commodity equivalent, or equity-like instrument) would allow new and more nuanced standards to enter the marketplace. 

As far fetched as this might seem, a similar attempt was made to improve crypto reporting via the proposed (not passed) Token Taxonomy Act of 2019; a refreshing attempt by policymakers to encourage innovation and adoption of new technologies. 


Crypto has rapidly moved from a fringe topic, to a relatively minor investment selection, to an investment being adopted by some of the largest corporations and asset managers in the world. This is fantastic news for wider adoption, but the accounting simply has not kept pace. Accounting professionals need to learn to live and work with crypto, and standard setters need to be proactive in the creation of crypto-specific standards. Applying standards developed for the 20th century economy to 21st crypto assets is already causing issues, and should be rectified to avoid wider market disruptions.

Sean Stein Smith

Sean Stein Smith was a Visiting Research Fellow at the American Institute for Economic Research, focusing on blockchain, cryptoassets, and the economic impact of these technologies. He is an Assistant Professor at the City University of New York (Lehman College), serves on the Advisory Board of Wall Street Blockchain Alliance, where he also chairs the Accounting Working Group, and chairs the Emerging Technology Interest Group of the New Jersey Society of CPAs.  His research has been quoted in dozens of scholarly and practitioner publications, and he is a regular speaker at accounting and technology conferences. Follow him on Twitter.

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