Bitcoin disclosure requirements depend on the reporting framework. Under US GAAP, the FASB standard on digital assets (ASU 2023-08) prescribes specific disclosures, some required every reporting period and some only in annual financial statements. Under IFRS there is no Bitcoin-specific list, but general requirements in IAS 1, IAS 38, IAS 36 and IFRS 13 still produce a substantial note.
This article is a practical guide to building that note: what goes in it, how often, and the data behind each line. For where Bitcoin sits in the primary statements, see how Bitcoin appears on the balance sheet.
Bitcoin disclosure requirements under US GAAP
ASU 2023-08 added a disclosure section to ASC 350-60. The requirements fall into two groups.
Every reporting period (interim and annual)
- Significant holdings. For each significant holding: its name, cost basis, fair value and number of units held.
- Other holdings. The aggregate fair value and aggregate cost basis of holdings that are not individually significant.
- Restrictions. For holdings subject to contractual sale restrictions: their fair value, the nature and remaining duration of each restriction, and the circumstances that could cause it to lapse.
Annual only
- Roll-forward. A reconciliation of opening to closing balances, showing additions, dispositions, gains and losses, with a description of the activities behind additions and dispositions.
- Income statement location. The line item in which gains and losses are reported.
- Realised amounts. For dispositions in the period, the difference between sale proceeds and cost basis.
- Cost basis method. The method used to determine cost basis, such as specific identification, first-in first-out or average cost.
On top of these, ASC 820 requires the usual disclosures for assets measured at fair value on a recurring basis, including the level in the fair value hierarchy. Bitcoin generally qualifies as Level 1. In the year of adoption, the transition disclosures for the cumulative-effect adjustment also apply.
"Significant" is a judgement. A company holding only Bitcoin will treat it as a significant holding. A company holding several assets needs a documented threshold, applied consistently.
What IFRS reporters disclose
The IFRS Interpretations Committee's June 2019 agenda decision on holdings of digital currencies reminded preparers of their general disclosure obligations. For a company applying IAS 38, these typically include:
- Accounting policy. The model applied (cost or revaluation) and why.
- Significant judgements. Under IAS 1, the judgements made in classifying Bitcoin, such as concluding that IAS 38 rather than IAS 2 applies.
- Indefinite useful life. The carrying amount and the reasons supporting the indefinite life assessment.
- Impairment. Under IAS 36, impairment losses and reversals recognised, and the key assumptions behind recoverable amount.
- Revaluation model. The effective date of revaluation, the carrying amount that would have applied under the cost model, and movements in the revaluation surplus.
- Fair value hierarchy. Under IFRS 13, the level of fair value measurements recognised or disclosed.
- Restricted and pledged assets. The existence and carrying amounts of intangibles with restricted title or pledged as security.
- Events after the reporting period. Under IAS 10, material changes in fair value after the reporting date where non-disclosure could influence users' decisions.
Many IFRS reporters with material holdings go further and voluntarily disclose units held, cost and fair value in a format similar to US GAAP. That helps investors compare them with US peers. See Bitcoin under IFRS vs US GAAP.
A note structure that works
The table sets out a practical structure for a US GAAP note. IFRS reporters can adapt it.
| Note section | Content | Frequency | Data source |
|---|---|---|---|
| Policy | Framework, scope, measurement, cost basis method | Annual (policy update if changed) | Accounting policy manual |
| Holdings | Units, cost basis, fair value | Every period | Lot register, pricing policy |
| Restrictions | Fair value, nature, duration, lapse conditions | Every period | Legal and treasury contracts register |
| Roll-forward | Opening, additions, disposals, gains, losses, closing | Annual | Lot register, general ledger |
| Realised results | Proceeds less cost basis on disposals | Annual | Lot register |
| Fair value level | Hierarchy level and pricing basis | Every period | Principal market analysis |
CFO tip: build the roll-forward every quarter, even though ASU 2023-08 only requires it annually. A roll-forward that ties to the ledger at each quarter-end is the quickest way to catch missing transactions before year-end.
The data behind the disclosures
Each disclosure depends on records that must exist from the first trade.
- Lot register. Acquisition date, units, price and costs for every lot, and the matching of disposals to lots. This drives cost basis, realised amounts and the roll-forward. See cost basis methods for corporate Bitcoin holdings.
- Restrictions register. Any Bitcoin pledged as collateral, lent, locked in a structured product or otherwise restricted, with the contract terms.
- Pricing file. Principal market analysis, pricing source and the cut-off time used. See measuring Bitcoin fair value.
- Activity classification. Additions split between purchases, receipts as payment and other sources; disposals between sales, payments and transfers out.
- Custody reconciliation. Units in the register agreed to custodian statements and on-chain balances at each period-end.
Gaps in any of these surface as disclosure problems at year-end, when they are most expensive to fix.
Beyond the financial statement note
Bitcoin holdings often require explanation outside the note itself.
- Management commentary. Explain how fair value gains and losses affected earnings, separately from operating performance. See Bitcoin and earnings volatility under fair value.
- Risk disclosures. Listed companies should consider describing price, custody, counterparty and regulatory risks in the risk factors or principal risks section.
- Custody arrangements. Where relevant to understanding risk, describe whether holdings sit with a third-party custodian or under the company's own key control, without revealing security details.
- Going concern and liquidity. Where Bitcoin is a large share of assets, consider whether liquidity disclosures need to address it.
Securities regulators in several markets have also issued guidance on how listed companies describe digital asset holdings. Listed companies should check the requirements that apply to them. Companies should take their own accounting, tax and legal advice.
How The Bitcoin World helps
We help finance teams design the records and processes that produce reliable disclosures, including execution reports and confirmations that feed the lot register directly. We work alongside your auditors and advisers. Execution and custody are carried out by licensed third-party institutions. See our corporate treasury and board advisory services, or the glossary.