ASC 350-60 crypto disclosures, line by line
What ASU 2023-08 asks you to disclose about crypto holdings each quarter and each year, and which system each number has to come from.
If you report under US GAAP and hold in-scope crypto assets, a calendar 2025 year end was the first annual period under ASU 2023-08 for entities that did not adopt early, and the disclosure note is where the work concentrates. Each line needs a defined data source, because several of the numbers cannot be read off the balance sheet.
The standard took effect for fiscal years beginning after December 15, 2024, including interim periods, for all entities [3][4]. It measures in-scope crypto at fair value through net income and adds four groups of disclosure: significant holdings, restrictions, a rollforward of activity, and realized gains and losses [4]. Industry-specific reporters, such as investment companies, still give the disclosures to the extent they are not duplicative [2].
Every quarter and every year
- Significant holdings. For each significant holding, judged by fair value, disclose its name, cost basis, fair value and number of units [1][2]. There is no bright-line threshold; significance is a management judgment [1].
- Everything else, aggregated. Holdings that are not individually significant are shown as one aggregate cost basis and one aggregate fair value [1][2].
- Contractual sale restrictions. For crypto subject to a contractual restriction on sale at the balance sheet date, disclose its fair value, the nature and remaining duration of the restriction, and the circumstances that could cause it to lapse [1][2].
Annual statements only
- Cost basis method. The method used to determine cost basis for computing gains and losses, such as first-in first-out, specific identification or average cost [1][2].
- Where gains and losses sit. The income statement line item, if remeasurement gains and losses are not presented separately [1][2].
- The rollforward. A reconciliation from opening to closing balance showing additions, dispositions, gains and losses, with a description of what the additions and dispositions were, for example purchases or staking rewards [1][2]. KPMG reads the standard as requiring gains and losses gross, holding by holding, using the same breakdown as the significant holdings table [2].
- Realized results. The total cumulative realized gains and, separately, realized losses on dispositions that occurred during the period [1].
Two practical carve-outs matter. Crypto received as noncash consideration in the ordinary course of business and converted to cash nearly immediately can be left out of the rollforward [1][2]. KPMG describes nearly immediately as a matter of hours or days, not weeks, which is the same window that drives operating cash flow classification for those receipts [2].
Remeasurement gain is not realized gain
The most common error is assuming the rollforward gain and the realized gain should agree. They measure different things. Realized gain is sale price minus original cost basis. Remeasurement gain is the change in fair value since the last measurement date [2]. KPMG's example: buy at 100, fair value 115 at year end, sell at 105 in the next year. That year shows a remeasurement loss of 10 in the rollforward but a realized gain of 5 [2]. Your lot engine produces one number and your fair value process produces the other.
| Line | Units | Amount (USD) |
|---|---|---|
| Opening fair value | 1,000 | 3,000,000 |
| Additions: purchases | 200 | 700,000 |
| Dispositions: sales | (300) | (1,200,000) |
| Remeasurement gains | 1,000,000 | |
| Remeasurement losses | (80,000) | |
| Closing fair value (900 ETH at 3,800) | 900 | 3,420,000 |
- Opening lot: 1,000 ETH with cost basis 2,000,000 (2,000 per ETH); policy is FIFO
- Sale of 300 ETH for 1,200,000; FIFO cost relieved = 300 x 2,000 = 600,000
- Realized gain disclosed = 1,200,000 - 600,000 = 600,000
- Net remeasurement in the rollforward = 1,000,000 - 80,000 = 920,000 (gains and losses shown gross)
- Closing cost basis = 700 x 2,000 + 200 x 3,500 = 2,100,000; closing fair value = 3,420,000
- Significant holdings line: ETH, 900 units, cost basis 2,100,000, fair value 3,420,000
Where each number comes from
- Units held: wallet and custodian balances at the cut-off time, reconciled to the ledger. A unit count that does not match on-chain or statement balances is the first thing a reviewer will test.
- Cost basis: the lot or pool records under the method you disclose. If the cost basis method changes, the disclosure changes with it, so the method needs to be fixed in policy, not chosen per report.
- Fair value: the price in your principal market at the period-end timestamp, with the source and time recorded. The same price drives the balance sheet, the significant holdings table and the closing line of the rollforward.
- Additions and dispositions by type: transaction classification. Purchases, rewards, receipts for services, sales, payments to vendors and network fees all need a category, because the standard asks you to describe the activity, not just total it.
- Restrictions: contracts, not chain data. Lockups in token purchase agreements and similar terms live in legal documents, so someone has to maintain a register of them with fair value at each reporting date.
What may change next
As of October 2026 the FASB has voted to issue a proposal on transfers and loans of crypto assets. Its staff told the Accounting Standards Advisory Forum the proposal would expand the scope of Subtopic 350-60 to cover wrapped-type tokens, keep lent crypto on the lender's books as an encumbered asset, and clarify certain existing disclosure requirements. The proposal is expected in the first quarter of 2027 with a 60-day comment period [4]. A separate proposal on when stablecoins can be cash equivalents was issued in August 2026 with comments due November 19, 2026 [4]. Neither changes today's requirements.
What to do
- Write down your significance judgment, including the fair value level at which a holding is shown separately, and apply it consistently each quarter.
- Produce the realized gain from the lot engine and the remeasurement gain from the fair value process, and reconcile both to the general ledger before drafting the note.
- Make sure every crypto transaction carries an activity category that maps to a rollforward line.
- Keep a restrictions register sourced from contracts, with lapse conditions and dates.
- Watch for the FASB transfers proposal in 2027; it may alter what counts as in scope and how some disclosures are worded.
Sources
- 6.3 Disclosures About Crypto Assets Within the Scope of ASU 2023-08 (Deloitte DART)
- FASB issues ASU: Accounting for and disclosure of certain crypto assets (Defining Issues, December 13, 2023) (KPMG)
- Accounting standard update on accounting and disclosure of crypto assets (Baker Tilly)
- Accounting for Crypto Assets: Feedback and Standard-Setting Updates (ASAF, October 2026) (FASB / IFRS Foundation)
General information for finance teams, current as of publication. Not legal, tax or accounting advice.