Before December 2023, a US company holding crypto had to recognize impairment losses when prices fell but couldn't recognize gains until it sold. That asymmetric accounting treatment was a real reason to avoid holding digital assets on a balance sheet at all, independent of any view on the assets themselves. ++FASB's ASU 2023-08++, effective for fiscal years beginning after December 15, 2024, replaced that with fair-value accounting under US GAAP: both gains and losses now flow through net income every reporting period.
It removed the specific accounting disincentive that made this decision harder than it needed to be for US entities. Which is why building an actual framework is timely now, though the picture looks different depending on which accounting framework actually applies to your business.
Start with accounting treatment, not custody
Under US GAAP, ASU 2023-08 applies to crypto assets meeting six specific criteria: intangible, no enforceable claim on other assets, residing on a blockchain, secured by cryptography, fungible, and not issued by the reporting entity itself. The scope excludes NFTs, wrapped tokens, and anything classified as a security. In-scope assets are measured at fair value each reporting period, with the change recognized in net income.
++IREN Ltd's own 10-K filing++ shows that the company early-adopted ASU 2023-08 effective July 1, 2024, but because its policy is to liquidate digital assets nearly immediately, typically within a day, the adoption had no material impact on its financial statements, and it held no digital assets at all as of the end of its most recent fiscal year. That's a useful illustration of how an operational-float approach and a fair-value accounting standard interact in practice.
Under IFRS, there's no dedicated crypto asset standard as of 2026. Most reporters apply IAS 38 as intangible assets, and ++most default to the cost model++ rather than the optional revaluation model. Even where a company elects the revaluation model, gains go through other comprehensive income rather than net income, while losses go through profit and loss directly, an asymmetric treatment not unlike what US GAAP replaced in 2023.
If your business reports under IFRS rather than US GAAP, don't assume the fair-value treatment described above applies to you; check with your own accounting advisors specifically.
Two different reasons to hold digital assets
A treasury policy needs to be explicit about which of these it's actually addressing, because they carry different risk profiles and different governance needs.
Operational float is digital assets held briefly as part of moving money, receiving a stablecoin payment before converting to fiat, or holding working capital in a stablecoin between settlement legs. The relevant risks here are custody and operational security during the holding window, not long-term market exposure.
Strategic reserve is a deliberate balance-sheet allocation, holding Bitcoin or another digital asset as a treasury position over months or years. This carries market risk that shows up directly in reported earnings under fair-value accounting where it applies, and it requires a different governance conversation entirely: how much, why, and under what conditions the position changes.
A single policy document trying to cover both without distinguishing them tends to produce vague rules that don't actually constrain either use case well.
Position sizing and governance
For a strategic reserve specifically, the practical questions a written policy needs to answer are straightforward to state and genuinely important to actually decide in advance: what percentage of total treasury this allocation is capped at, who has authority to approve an initial allocation versus who can approve adding to it, what triggers a rebalancing decision, and how often the board or finance committee reviews the position.
Real filed policies follow this structure. One recent example, a company's SEC-filed Treasury Reserve Fund Policy, sets out its purpose and objectives, its investment mandate, and its risk limits as distinct, explicit sections rather than a general statement of intent. Deciding these in a calm moment, before there's a live position moving in either direction, produces better decisions than a reactive call made during a drawdown or a rally.
Custody is a separate decision, deliberately not covered here
How a business actually holds digital assets, self-custody, exchange custody, shared-control arrangements, or a qualified third-party custodian, is a distinct decision with its own risk trade-offs, covered in full in our custodial vs. non-custodial decision guide. A treasury policy should reference which model it uses and why, but this framework isn't the place to re-litigate that choice.
Risk management basics
Beyond custody and accounting, a few things belong in any written policy. Insurance coverage and its actual exclusions matter more than whether coverage exists at all, a point covered in the custody guide linked above. Screening incoming and outgoing transactions for sanctions or illicit-activity exposure is a real compliance obligation under ++FATF's guidance on virtual asset service providers++, not an optional extra, and it applies whether the digital assets in question are operational float or a strategic reserve.
A minimal policy checklist
- Accounting framework: confirm whether US GAAP, IFRS, or another standard governs your reporting, since the treatment differs meaningfully
- Scope: which specific assets are covered, and confirmation of which fall under the applicable fair-value or cost-model treatment
- Purpose: operational float, strategic reserve, or explicitly both, treated as separate sub-policies
- Sizing: a defined cap as a percentage of total treasury, for any strategic reserve specifically
- Approval authority: who can initiate, add to, or reduce a position
- Custody model: which model is used, and why, referencing a separate custody decision
- Compliance: sanctions and illicit-activity screening built into the process, not bolted on after
- Review cadence: how often the board or finance committee revisits the policy itself, not just the position
Related reading: Treasury on Regulated Rails · Family Offices: Custody and Execution for Wealth · Custodial vs Non-Custodial Crypto: A Business Decision Guide