Ask any finance executive why it took so long to consider Bitcoin on the balance sheet and, before mentioning volatility, they will mention accounting. For years, the accounting rules treated Bitcoin in a way that artificially penalised holders. In 2025 that changed in the United States, but not in the EU. Understanding that difference is essential before adding Bitcoin to a company's treasury.
The historical problem: only losses counted
Under both US GAAP and IFRS, Bitcoin was classified as an intangible asset (it is not cash, nor a financial instrument, nor inventory for most companies). The problem was the measurement model: cost less impairment. It meant that if Bitcoin fell, the company recorded an impairment loss; but if it rose, it could not recognise that gain until selling. An asymmetric treatment that made the balance sheet always reflect the asset's worst moment and never its recovery. A textbook accounting disincentive.
FASB (US): fair value since 2025
The FASB corrected this with update ASU 2023-08, which created subtopic ASC 350-60 and is mandatory for fiscal years starting after December 15, 2024. From then on, US companies must measure eligible crypto-assets at fair value at each close, recognising both unrealised gains and losses in the income statement. The balance sheet now reflects the real value of Bitcoin in real time, and the asymmetry disappears. It is no exaggeration to say this rule unlocked corporate Bitcoin adoption in the US.
IFRS and the EU: still the intangible model
Here is the nuance rarely told. The European Union does not follow the FASB but IFRS (and, in individual accounts, national charts of accounts with analogous logic). Under IAS 38, Bitcoin remains an intangible asset measured under cost less impairment. There is technically a "revaluation model" for intangibles with an active market, but its application is limited and, when used, revaluations go to other comprehensive income (OCI), not the income statement, unlike the US fair-value approach.
The practical consequence: a company reporting under IFRS does not today enjoy the same favourable treatment as a US one. The IASB has not yet issued a crypto-specific standard equivalent to the FASB's, and the treatment by analogy via IAS 38 keeps much of the original friction. It is a real regulatory divergence worth knowing and planning for.
The audit: verifying what's on the balance sheet
Whatever the framework, Bitcoin on the balance sheet must be auditable. A digital-asset audit verifies three things: existence and ownership (control of the keys, usually via proof of reserves or a custodian review), valuation under the applicable standard, and the soundness of custody controls. For a listed treasury, this independent verification is what turns a stated figure into a credible one.
What it means for your company
If your company reports under US GAAP, ASC 350-60 gives you a clean, symmetric treatment. If you report under IFRS or national rules — the case for most European companies — you must work with the intangible treatment and plan its balance-sheet impact with your auditor. The difference does not change the investment thesis, but it does change how it appears in your financial statements, and that matters to the board, the banks and the shareholders.
This article is education, not accounting or tax advice. Rules evolve and their application depends on the specific case: always validate with your auditor.
Summary
The 2026 picture is two-speed: the US values corporate Bitcoin at fair value (FASB ASC 350-60) while the EU keeps it as an intangible under IFRS. Knowing which side you are on is the first step to adding Bitcoin to the treasury without accounting surprises. At SatsIntel we track regulatory developments and how they affect the Bitcoin treasuries we cover.
