Lending crypto under IFRS: does it leave your balance sheet?

IFRS has no crypto lending rule. The answer turns on IAS 38 control, and the receivable usually is not an IFRS 9 financial asset.

2026-10-17 · 5 min read

If you lend tokens under IFRS, there is no standard written for it, and practice is diverse. You will need a documented policy on two questions: have you given up the asset, and if so, what is the right to get it back?

Start with what the asset is

The IFRS Interpretations Committee concluded in 2019 that a holding of cryptocurrency is an intangible asset under IAS 38, or inventory under IAS 2 if held for sale in the ordinary course of business. It is not cash and not a financial asset under IAS 32, because it gives no contractual right to receive cash or another financial asset [1]. That framing drives everything that follows.

Question 1: has control passed to the borrower?

IAS 38 derecognizes an intangible asset on disposal, and the date of disposal is when the recipient obtains control, applying the IFRS 15 control requirements [2]. Lending is not an obvious sale, so the analysis cuts both ways. In a 2023 discussion of a typical unsecured bitcoin loan, Canada's IFRS Discussion Group set out the arguments [3].

• Against derecognition: the borrower must return the same quantity, so the lender keeps the price risk and arguably substantially all the risks and rewards; the arrangement resembles a repurchase agreement [3].
• For derecognition: the borrower can sell, pledge, rehypothecate, lend or stake the tokens freely, so it directs their use; it may have to buy equivalent tokens in the market to repay [3].

The group did not reach a consensus and noted views are diverse [3]. In practice, the contract terms decide it: whether the borrower can actually use the tokens, whether they are held in a segregated or controlled account, collateral, and recall rights.

Question 2: what is the receivable?

If you derecognize, you recognize a right to receive tokens back. Most members of the discussion group thought this right does not meet the IAS 32 definition of a financial asset in most cases, because it is settled by delivering a non-financial item rather than cash [3]. That means IFRS 9, including its expected credit loss model, does not apply directly. Options discussed included treating it by analogy as a financial asset, as an intangible asset, or developing a policy under IAS 8, and members leaned towards fair value so that both price and credit risk are reflected, while noting this is hard to support under current standards [3].

Note the effect of Policy B on an IAS 38 cost-model reporter: lending can crystallize a gain that holding never would. That is one reason auditors will look closely at the control conclusion.

How US GAAP compares

Under current US practice, SEC staff views led lenders that transfer control to derecognize and recognize a crypto loan receivable at the fair value of the lent tokens, with a credit loss allowance [4]. The FASB is moving the other way. Its tentative decisions say a lender should not derecognize crypto transferred in a lending arrangement, but reclassify it as encumbered and keep measuring it at fair value, including the borrower's credit risk [5][6]. A proposed update is expected in the first quarter of 2027 with a 60-day comment period [6]. These are tentative decisions and could change.

IFRS has no equivalent project yet. The IASB lists crypto assets only as a possible future project, while it reconsiders IAS 38 more broadly in its Intangible Assets research [7]. As of October 2026, IFRS reporters should expect to rely on judgment for some time.

What to do

• Read each lending agreement for the borrower's rights to use, sell, pledge or restake the tokens, segregation, collateral and recall terms, and document the control conclusion per arrangement.
• Choose and write down a policy for the receivable (classification and measurement), and apply it consistently across counterparties.
• Assess borrower credit risk even though IFRS 9 impairment may not apply directly, and disclose concentrations.
• Disclose the judgments made, the carrying amount of lent tokens, and counterparties, under the general IFRS requirements to disclose significant judgments.
• If you also report under US GAAP or to a US parent, track the FASB transfers proposal, since the two frameworks may diverge.

Sources

1. Holdings of Cryptocurrencies, IFRS Interpretations Committee agenda decision (June 2019) (IFRS Foundation)
2. IAS 38 Intangible Assets (IFRS Foundation)
3. IFRS Discussion Group meeting, May 2023 (crypto asset lending) (FRAS Canada)
4. Roadmap: Digital Assets, 8.2 Crypto Asset Lending (Deloitte DART)
5. FASB makes progress on crypto asset transfers project (KPMG)
6. Accounting for Crypto Assets: Feedback and Standard-Setting Updates (ASAF, October 2026, Agenda Paper 7B) (FASB staff via IFRS Foundation)
7. IASB Update (World Standard-setters Conference, September 2026) (IFRS Foundation)

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

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