Accounting for tokens you issue: why your own token is not an asset

Issuers sit outside ASU 2023-08. What you record depends on the promises attached to the token: equity, a liability, revenue or none of these.

2026-10-17 · 6 min read

If your company or a related party created a token, the fair value rules most crypto holders now use do not apply to it, and neither US GAAP nor IFRS has a standard written for issuers. The accounting starts with the documents: what did you promise the people who paid you, and what do you still owe them?

Out of scope of ASU 2023-08

ASC 350-60, added by ASU 2023-08, only covers crypto assets that meet six criteria. The sixth is that the asset was not created or issued by the reporting entity or its related parties [1]. The FASB explained that it had not been asked for issuer guidance and that issuers did not support fair value measurement of their own tokens [1]. The exclusion survives a round trip: a token the entity created, sold and later bought back in the market still falls outside the fair value model and is accounted for under the older intangible asset model [1].

Two details matter in practice. The related-party net is wide, so a foundation, labs company and token issuer that are related to each other should each check whether they are caught. And an entity that only mines or validates, receiving newly created tokens as payment, is not treated as their creator [1]. As of October 2026 we are not aware of any FASB or IASB project dedicated to issuer accounting.

The credit side of the raise

When you sell tokens for cash or crypto, the debit is easy: you have received an asset. The hard part is the credit. IFRS staff, in a 2018 paper for the Interpretations Committee, said there is no one-size-fits-all answer, and that the issuer must first analyse the obligations it took on, reading the white paper and considering the legal environment [2]. They identified four possible outcomes [2]:

• Equity, if the token is a residual interest with no contractual obligation to deliver cash or other financial assets, for example a token that entitles holders to distributions out of reserves. It must pass the IAS 32 equity tests.
• Financial liability, for example where the issuer may have to pay cash to holders in specified circumstances, accounted for under IFRS 9.
• Revenue or a contract liability under IFRS 15, where the token is really a prepayment for the issuer's own goods or services, such as free or discounted access later. Revenue follows delivery of those goods or services.
• A non-financial obligation under IAS 37, for example a promise to build a platform for token holders.

Where the issuer has no further obligation and the buyer is not a customer, staff noted that no standard may apply and the issuer must develop a policy using the IAS 8 hierarchy [2]. Whatever the outcome, they suggested disclosing the transaction, the rights and obligations attached to the token, and how it was accounted for [2]. US GAAP has no equivalent paper, so US issuers usually work through the same questions using the liability, equity and revenue guidance in the Codification.

SAFTs: cash today, tokens later

A simple agreement for future tokens is a contract in which an investor pays now and the company promises tokens if a trigger event, usually a network launch, occurs [3]. Until then the company has taken cash and owes something, so a SAFT is commonly recorded as a liability rather than income. Its exact classification depends on its terms, including refund rights if the launch never happens.

Regulatory risk can turn into accounting risk. In 2020 Telegram agreed to return more than 1.2 billion dollars to investors who had bought rights to its Gram tokens, after a court found the SEC was likely to prove the sales were part of a scheme to distribute the tokens to the public market [4]. A refund obligation of that kind is a liability, however the original raise was booked.

Tokens you keep

Issuers usually retain a large allocation for the treasury, the team and ecosystem grants. Whether unissued or retained own tokens are an asset at all is not answered by either framework, and practice is to avoid writing up something you created to a market price. Hiro Systems, for example, disclosed that tokens it delivered to staff had a zero carrying amount [5]. When retained tokens are spent on grants or pay, the expense comes from the obligation you settle, not from a balance sheet write-down. See our piece on paying staff in tokens for that side.

What to do

• List every token your group or its related parties created, and confirm none is being measured under ASC 350-60.
• For each token sale, map the promises in the white paper and agreements to equity, liability, contract liability or no obligation, and write the conclusion down.
• Track SAFTs and other future-token agreements as obligations until delivery, with launch conditions and refund terms.
• Disclose the token's terms, the rights of holders and your accounting policy, even when no standard compels it.
• Revisit the analysis when the protocol, the governance or the regulatory status of the token changes.

Sources

1. 2.3 Crypto Assets Within the Scope of ASU 2023-08 (Deloitte (DART))
2. Staff paper, Agenda ref 4C: Cryptocurrencies, Initial Coin Offerings (September 2018) (IFRS Foundation)
3. Why there is no safety in SAFTs (Clyde & Co)
4. Telegram to Return $1.2 Billion to Investors and Pay $18.5 Million Penalty to Settle SEC Charges (U.S. SEC)
5. Hiro Systems PBC, Form 1-K for fiscal year 2022 (Part II) (U.S. SEC (EDGAR))

General information for finance teams, current as of publication. Not legal, tax or accounting advice.

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