How to Build a Digital Assets Policy for Your Finance Function

Introduction

If your organisation holds, transacts in, or is considering any involvement with digital assets, you need a policy. Not because it is a nice-to-have governance document, but because without one, individual team members will make inconsistent decisions about accounting treatment, valuation, compliance, and risk — decisions that could expose your organisation to financial, legal, and reputational harm.

This guide provides a practical framework for finance leaders building a digital assets policy from scratch. It is designed for CFOs, Finance Directors, Head of Finance, and senior finance managers who need to establish clear, workable governance in this area.

Step 1: Define the Policy Scope

Start by clearly defining what digital assets are in scope. Your policy should explicitly list the categories of digital asset it covers. A practical scope definition might include:

• Cryptocurrencies (Bitcoin, Ether, and named alternatives)
• Stablecoins (including fiat-collateralised, crypto-collateralised, and algorithmic)
• Utility tokens and security tokens
• Non-fungible tokens (NFTs) held as investments or business assets
• Any digital asset received as payment for goods or services
• Any digital asset held on behalf of third parties (if applicable)

The policy should also state what is explicitly excluded — for example, CBDCs once issued may be treated as cash equivalents and covered under your cash management policy rather than a digital assets policy.

Step 2: Accounting Treatment Decisions

Your policy must establish the accounting treatment your organisation will apply consistently. Key decisions to document:

Classification

State how each category of digital asset is classified — most commonly as intangible assets under IAS 38 / FRS 102 Section 18. Note any exceptions (e.g. if the organisation is a broker-trader, certain holdings may be inventories under IAS 2).

Measurement Model

State whether the organisation applies the cost model or revaluation model. For most organisations, the cost model is simpler and lower risk from an estimation uncertainty perspective. The revaluation model requires the existence of an active market and consistent application.

Valuation Methodology

Document the source and methodology for determining the value of digital assets at each reporting date. Specify:

• Which price source(s) are used (e.g. CoinGecko closing price, exchange spot price)
• The time of day at which the price is taken
• How the methodology is applied for less liquid assets
• How the source and timestamp are evidenced and retained

Impairment Process

Document the triggers for impairment review, the process for calculating recoverable amount, and the sign-off required before impairment is recognised. Given crypto price volatility, consider requiring a monthly rather than annual impairment review for material holdings.

Currency Translation

If digital assets are priced in a non-functional currency, document how IAS 21 is applied — specifically confirming that crypto is treated as a non-monetary item and translated at the historical rate.

Step 3: AML Controls

Your digital assets policy must integrate with your AML framework. Specific requirements to include:

• Client/counterparty onboarding: Any counterparty from whom digital assets are received, or to whom they are paid, must be subject to CDD/EDD as appropriate
• Exchange and custody provider approval: Only pre-approved exchanges and custodians that are HMRC-registered (or equivalent under MiCA in the EU) should be used. Document the approval process
• Source of funds documentation: For acquisitions above a defined threshold, document the source of funds
• Transaction monitoring: Define how digital asset transactions are monitored for suspicious activity and who is responsible for raising SARs
• Record retention: Digital asset transaction records must be retained for at least five years under MLR 2017

Step 4: Staff Training Requirements

Specify the training that staff with digital asset responsibilities must complete. This should include:

• Basic digital assets literacy (what they are, how they work)
• Your organisation's accounting policy and how to apply it
• AML obligations specific to digital assets
• How to identify and escalate red flags
• Frequency of refresher training (annually as a minimum)

Training completion should be documented and records retained. This is not just good practice — it provides evidence of compliance in the event of a regulatory review.

Step 5: Governance and Sign-Off

Document the governance structure for digital asset activity:

• Who has authority to approve new digital asset holdings or transactions (and at what value thresholds)
• Who is responsible for the accounting treatment and policy compliance
• The frequency of management reporting on digital asset holdings and performance
• Who is responsible for keeping the policy current (recommend annual review)
• Board or audit committee sign-off requirements

Digital Assets Policy Outline Checklist

Use this checklist to confirm your policy covers all the essential areas:

• Policy scope — which digital assets are covered
• Classification framework — how each type is classified
• Measurement model — cost or revaluation, and rationale
• Valuation methodology — price source, timestamp, evidence
• Impairment process — triggers, methodology, sign-off
• Currency translation approach
• Disclosure requirements — what goes in the financial statements
• Approved exchanges and custodians
• AML risk assessment and EDD triggers
• Transaction monitoring and SAR procedures
• Record retention requirements
• Staff training requirements and records
• Delegated authority and approval thresholds
• Management reporting framework
• Policy review date and owner

Build the Knowledge Your Policy Needs with Learnsignal

Writing a digital assets policy is one thing — ensuring your team has the knowledge to implement it is another. Learnsignal's CPD courses cover digital assets accounting, AML compliance, MiCA regulation, and the technical treatment of crypto under IFRS and UK GAAP. Browse our CPD library and ensure your finance team has the expertise to make your policy work in practice.