Other than SAB 121 there is no authoritative guidance that specifically addresses the accounting for crypto assets, therefore reporting entities should consider disclosures based on the relevant accounting standard applied (e.g., indefinite-lived intangible, financial asset). See CA 3.7.1 for additional considerations related to the scope of SAB 121 and CA 5.2 for the SAB 121 disclosure requirements.
Figure CA 5-1 summarizes some of the more common topics for disclosure. However, this list is not exhaustive and will need to be tailored to develop disclosures that are specific to the entity and the relevant facts and circumstances.
Figure CA 5-1
Frequently required disclosures
Accounting guidance
Additional information
ASC 235, Notes to Financial Statements
Disclosures should include the accounting policies and principles followed in accounting for the crypto assets and the method of applying them.
ASC 275, Risks and Uncertainties
Given the risks and uncertainties associated with certain crypto assets, reporting entities should consider the need for disclosures about the nature of the crypto asset activities they are undertaking, the use of estimates for fair value, and any vulnerabilities due to concentration of risk due to a lack of diversification.
ASC 350, Intangibles – Goodwill and Other
When an impairment is recognized on crypto assets accounted for as intangible assets, include a description of the circumstances leading to the impairment, the amount of the impairment, the caption in the income statement that includes the impairment loss, and the segment in which the impaired asset is reported.
ASC 606, Revenue from Contracts with Customers
To the extent the crypto transaction is classified as a sale to a customer, include the relevant revenue disclosures, tailoring as appropriate based on whether the entity is a principal or agent.
ASC 820, Fair Value Measurement
When the crypto asset is a financial asset, include the relevant disclosures for an instrument that is recorded at fair value on a recurring basis.
For crypto assets that are recognized as intangible assets, include the fair value disclosure for assets recorded at fair value on a non-recurring basis.
ASC 855, Subsequent Events
Reporting entities may need to disclose significant subsequent events related to crypto assets, such as significant changes in the value of the crypto assets after period end or significant changes in the amount or nature of the crypto asset transactions.
Additional considerations for SEC registrants
Regulation S-X Article 5 requires registrants to separately state each class of intangible asset that is in excess of 5% of total assets. The amount of significant additions or deletions related to these assets should be disclosed in a footnote.

Registrants should also consider additional disclosures outside of the financial statements, including any material information that may be necessary to ensure the financial statements are not misleading. In meeting their disclosure obligations, registrants should consider disclosures related to the description of the business, risk factors, and management’s discussion and analysis. For additional information and illustrative examples of comments, refer to the SEC’s Sample Letter to Companies Regarding Recent Developments in Crypto Asset Markets.
Regulation S-X Article 5-02

Securities Act Rule 408 and Exchange Act Rule 12b-20
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