Accounting standards & regulatory requirements

Which accounting standards are applicable to my project?

Country&Region	Accounting standards*	Note
Singapore	IFRS/SFRS	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	IFRS/HKFRS	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	US GAAP

*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?

IFRS

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 holding	Applicable Standards	Classification	Subsequent measurement basis
For sale	IAS 2 Inventories	Inventory	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

US GAAP

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 Standards	Classification	Subsequent measurement basis
ASC 350-60 Crypto Assets（Proposal）	Crypto Assets	Fair value on reporting day
ASC 946 Financial Services	Inventory	Fair value on reporting day

What are the differences between IFRS and US GAAP?

	US GAAP	IFRS
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
Recognition	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 & Region	Regulation & Policy	Agency	Regulated Business	Key Points
Singapore	Securities and Futures Act	MAS	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.
Singapore	Payment Services Act，PSA	MAS	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	SFC	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	SFC	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	SEC	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	IRS	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.