Accounting standards & regulatory requirements

Which accounting standards are applicable to my project?

Country&RegionAccounting standards*Note



Since 2002, SFRS has been moving towards convergence with IFRS and is almost identical to IFRS - the only exception being that IFRIC 2 (certain specific provisions regarding put options held in joint ventures) has not been adopted by Singaporean standards.

Hong Kong


A set of accounting rules developed by the Hong Kong Institute of Certified Public Accountants (HKICPA). This framework follows the Financial Reporting Standards (FRS) implemented in Hong Kong since January 2005. The FRS model is based on the International Financial Reporting Standards (IFRS) under the International Accounting Standards Board (IASB).

United States


*This form does not distinguish between listed companies/non-listed companies/small and medium-sized enterprises, because in the same country/region, the criteria applied are all within the same framework.

How are different standards used to account for cryptocurrency assets?


The holding of a cryptocurrency is accounted for as inventory under FRS 2 Inventories if an entity holds it for sale in the ordinary course of business or if the entity is a broker-trader of cryptocurrencies. If FRS 2 is not applicable, the holding is accounted for as an intangible asset under FRS 38 Intangible Assets.

Purpose of holdingApplicable StandardsClassificationSubsequent measurement basis

For sale




Lower of cost and net realisable value

Inventory held by broker trader

Fair value less costs to sell

Not for sale

IAS 38

Intangible Assets

Intangible asset – cost model

Cost less accumulated impairment losses

Intangible asset - revaluation model

Fair value less subsequent accumulated impairment losses


The new proposal by FASB suggests that the fair value of the entity's holdings of crypto assets and the net increase in value during the accounting year must be disclosed. In addition, the cost expenses of crypto assets, such as transaction cost and related fees, should also be disclosed.

Applicable StandardsClassificationSubsequent measurement basis

ASC 350-60

Crypto Assets(Proposal)

Crypto Assets

Fair value on reporting day

ASC 946

Financial Services


Fair value on reporting day

What are the differences between IFRS and US GAAP?


Scope of applicable crypto assets

Meet the definition of intangible asset as defined in the Codification Master Glossary. Do not provide the asset holder with enforceable rights to, or claims on, underlying goods, services, or other asset. Are created or reside on a distributed ledger based on blockchain technology. Are secured through cryptography. Are fungible. Are not created or issued by the reporting entity or its related parties.

A digital or virtual currency recorded on a distributed ledger that uses cryptography for security, Not issued by a jurisdictional authority or other party, and Does not give rise to a contract between the holder and another party.

When to use fair value measurement

Require fair value measurement of encrypted assets (a subset of intangible assets).

The revaluation model is an election for intangible assets

Fair value measurement method

Require fair value measurement for crypto assets

Requires reference to an active market for measuring at fair value


Require the recognition of all changes in the fair value of crypto assets in net income

Require recognition of any gains above original cost in other comprehensive income without recycling to net income

What are the regulatory requirements and policies for the business I am operating?

Country & RegionRegulation & PolicyAgencyRegulated BusinessKey Points


Securities and Futures Act


Digital tokens are classified as Capital Markets Products(Digital token offerings)

If digital tokens are classified as Capital Markets Products (CMP) under the Securities and Futures Act (SFA), they will be regulated by the MAS.


Payment Services Act,PSA


Digital payment token service(DPT transfer, DPT wallet custody, decentralized DPT trading.)

Any person or business carrying out DPT-related services obtain a standard or major payment institution license.

Hong Kong

Securities and Futures Ordinance


Security Token Offering

Any individual or institution engaged in activities related to security-type tokens must obtain a license from the SFC or register with the SFC.

Hong Kong

Passage of Anti-Money Laundering and Counter-Terrorist Financing (Amendment) Bill 2022


Virtual asset trading platform

All central virtual asset trading platforms that operate in Hong Kong or actively promote their services to Hong Kong investors will need to be licensed and regulated by the Securities and Futures Commission.

United States

Staff Accounting Bulletin No. 121


Custodial type activities

Stakeholders would benefit from the inclusion of a crypto-asset safeguarding liability, recognized and remeasured at fair value, and a related asset.

United States

Internal Revenue Bulletin: 2014-16


Trading of virtual currencies

The notification recognizes virtual currencies that can be exchanged for legal tender as "assets" and further clarifies that tax principles related to assets apply to the process of mining, holding, and trading virtual currencies.

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