About This Template
As crypto assets have moved from speculative holdings to operational infrastructure for a growing number of technology and Web3 companies, the accounting and tax treatment of those assets has become a first-order finance function responsibility. HMRC has published detailed guidance for companies holding cryptoassets (most recently updated in 2024), and the FRC and ICAEW have issued technical guidance on how UK GAAP and IFRS reporters should account for digital assets. Despite this, many companies — particularly those in their first years of holding crypto — have inadequate records that make year-end accounting painful, impairment testing impossible to document, and HMRC disposal calculations unreliable.
This template provides the record-keeping infrastructure that makes year-end accounting manageable and audit-ready. It is designed for UK-incorporated companies holding crypto assets — either because they operate in the Web3 sector, hold crypto as part of their treasury strategy, or receive crypto as payment or mining income. The template covers four areas: the asset register (what you hold and at what cost), the transaction log (every acquisition, disposal, and other event), the disposal schedule (HMRC section 104 pool calculations for each asset), and an accounting reference covering the key IFRS and UK GAAP positions.
What's Included
- Instructions sheet — Overview of crypto asset accounting requirements, IFRS vs UK GAAP positions, and HMRC guidance for corporate holders
- Asset Register sheet — 20 rows covering each discrete asset holding, with columns for: Asset ID, Asset Name, Asset Type, Custody method, Wallet/Account Reference, Acquisition Date, Acquisition Quantity, Acquisition Cost (£), Cost per Unit, Fair Value Date, Fair Value per Unit, Current Fair Value (£), Unrealised Gain/Loss (£), Impairment Required (Y/N), Impairment Amount (£), and Notes. Summary rows calculate total cost, total fair value, total unrealised gain/loss, and total impairment
- Transaction Log sheet — 50 rows for logging every transaction, with columns for: Date, Transaction Type, Asset, Quantity, Price (£), GBP Value, Cost Basis (£), Gain/Loss (£), Tax Pool, Wallet Reference, Exchange Reference, and Notes. Transaction types include Buy, Sell, Transfer In, Transfer Out, Mining, Staking Reward, Fee, DeFi Income, and Airdrop
- Disposal Schedule sheet — HMRC Section 104 pool calculations for each asset, with disposal rows showing quantity disposed, proceeds, Section 104 cost allocated, and gain or loss. Includes a 30-day bed-and-breakfasting rule flag column to identify transactions subject to the anti-avoidance rules
How to Use This Template
- Categorise each asset before recording it in the Asset Register. The asset type classification drives the accounting treatment. Cryptocurrencies (BTC, ETH, etc.) are most commonly classified as intangible assets under IAS 38 for IFRS reporters or under FRS 102 for UK GAAP reporters. Stablecoins may be financial assets under IFRS 9 depending on their structure. NFTs may be inventory (IAS 2) or intangibles (IAS 38) depending on whether they are held for sale or use. Make the classification decision once, document it, and apply it consistently.
- Record every acquisition in the Transaction Log immediately. Log each purchase, mining receipt, staking reward, airdrop, or transfer in on the date it occurs. The most important fields are: the date (for HMRC timing), the quantity, and the GBP value at the date of receipt (this is the acquisition cost for both accounting and tax purposes). For assets received as income (staking rewards, mining), the GBP fair value at the date of receipt is also treated as income for Corporation Tax purposes.
- Update the Asset Register after each transaction. After logging a transaction, update the relevant Asset Register row. For acquisitions, update the quantity and cost. For disposals, reduce the quantity and update the cost basis remaining. For fair value updates, enter the current market price and date — the Unrealised Gain/Loss column will calculate automatically.
- Perform impairment testing at each period end. For assets classified as intangibles under IAS 38, you must compare the carrying value (cost less accumulated impairment) to the recoverable amount (typically fair value for crypto assets). If the carrying value exceeds recoverable amount, you must impair. Mark the Impairment Required column as Y and enter the impairment amount. Under IAS 38 cost model, impairment losses cannot be reversed when the price recovers.
- Maintain the HMRC Section 104 pool for each asset. In the Disposal Schedule, each asset should have its own pool. When you acquire more of an asset, increase the pool quantity and cost. When you dispose, calculate the proportion of the pool cost that relates to the disposed quantity — that is your cost of disposal for Corporation Tax. The gain or loss is proceeds minus the allocated pool cost. The 30-day rule flag should be set where a disposal is followed by a reacquisition of the same asset within 30 days — in this case, HMRC requires matching the disposal against the reacquisition cost rather than the pool cost.
- Reconcile transaction log to exchange and wallet records periodically. At least quarterly, reconcile the quantities in your Transaction Log against exchange account statements and blockchain wallet transaction histories. Differences will arise from fees (which are separately recordable events), network gas costs, and timing of transfers between wallets. Unreconciled differences at year end are a significant audit risk for digital asset holdings.
Frequently Asked Questions
What is the HMRC Section 104 pool method?
The Section 104 pool is the method UK tax law requires companies to use when calculating taxable gains on disposal of shares and, by extension under HMRC guidance, cryptoassets. The basic principle is that all acquisitions of the same asset type are pooled together into a single cost pool, rather than matched on a first-in-first-out or specific identification basis. The pool has two components: a running total of the number of tokens held, and a running total of the total acquisition cost. When you dispose of tokens, you calculate what proportion of the pool is being disposed of (disposed quantity divided by total pool quantity), apply that proportion to the total pool cost to get the cost of disposal, and calculate the gain or loss as disposal proceeds minus the allocated cost. Any remaining pool cost and quantity carries forward for future disposals. This method effectively averages the cost basis across all acquisitions of the same asset.
Is crypto subject to impairment testing under IFRS?
Yes, if the crypto asset is classified as an intangible asset under IAS 38. Under the IAS 38 cost model, the asset is carried at cost less accumulated amortisation and accumulated impairment losses. Cryptoassets are not amortised (as they have indefinite useful life), but they are subject to impairment testing under IAS 36 whenever there is an indication that the asset may be impaired — and a significant fall in market price is an obvious indicator. If the asset's carrying value (original cost) exceeds its recoverable amount (essentially its current fair value for a non-cash-generating asset), an impairment loss must be recognised in P&L. The critical point is that this impairment is one-directional: when the price subsequently recovers, the carrying value cannot be written back up under the cost model. This asymmetry means that companies holding crypto through a significant price downturn will carry very low book values that do not reflect current market prices. If the IAS 38 revaluation model is applied instead, the asset can be carried at fair value — but this requires the existence of an active market and the application of consistent revaluation at each balance sheet date.
Do we need to disclose crypto holdings in our financial statements?
Yes — for any company where crypto holdings are material to the financial statements (either in absolute value or relative to total assets), specific disclosures are required. Under IFRS, these include: the accounting policy applied to each class of digital asset, the carrying value at the balance sheet date, the fair value and the basis for determining it, any impairment losses recognised in the period, significant judgements made in classification, and any restrictions on the company's ability to access or dispose of the assets. Auditors will increasingly require companies to disclose their custody arrangements and demonstrate that controls over private keys are adequate — this is a growing area of audit focus. Under UK GAAP (FRS 102), the disclosure requirements are broadly similar, though the specific standards cited will differ. The ICAEW has published a Technical Release on crypto assets that provides practical guidance on disclosures and is worth reviewing with your auditor.
How do I account for staking rewards received by our company?
Staking rewards received by a corporate entity are treated as income at the fair value of the tokens received on the date they are received. The fair value at receipt becomes both the recognised income and the cost basis of the newly acquired tokens for future accounting and disposal purposes. HMRC's Cryptoassets Manual confirms that staking rewards are taxable as income (not capital gains) for Corporation Tax purposes when received, and the income amount is the sterling value of the tokens at the date of receipt. This means your Transaction Log should record each staking receipt separately with the GBP value at the date of receipt — a lump-sum entry at year end is not acceptable for HMRC purposes if the rewards were received on multiple dates throughout the year. For accounting purposes, if staking rewards are material, you may need to consider whether they represent a separate revenue stream requiring its own IFRS 15 analysis.
What is the 30-day bed-and-breakfasting rule and when does it apply?
The 30-day rule (sometimes called the bed-and-breakfasting rule, from its original context in share dealing) is an anti-avoidance rule that prevents companies from crystallising a tax loss on a disposal and then immediately reacquiring the same asset at a lower cost, effectively resetting the cost basis without a genuine change in economic position. The rule provides that where a company disposes of a cryptoasset and then reacquires the same asset within 30 days of the disposal, the disposal is matched against the cost of the reacquisition rather than the Section 104 pool cost. This means the anticipated loss may not be realised for tax purposes, or the gain may be calculated differently. The Disposal Schedule in this template includes a flag column for 30-day rule matches — any disposal where a same-asset purchase occurs within 30 days should be flagged and the gain or loss recalculated accordingly. This applies symmetrically to gains and losses.
How should we categorise transfers between our own wallets?
A transfer of a crypto asset from one wallet or exchange account to another that is wholly owned by the same company is not a disposal event for tax purposes and should not trigger a gain or loss calculation. However, it should be logged in the Transaction Log for completeness, using the Transaction Type fields Transfer In and Transfer Out. The critical requirement is that you can evidence the ownership of both the sending and receiving wallets — HMRC will treat a transfer as a disposal if you cannot demonstrate that both wallets are under the control of the same legal entity. Maintain a wallet ownership register as a companion to this asset register, documenting each wallet address, the custody method, who holds the private keys, and how access is controlled. Gas fees paid in connection with transfers are separately chargeable events — they are effectively disposals of a small quantity of ETH or other native token and should be logged as such.
