Accounting for digital assets: Practical guidance for navigating this rapidly evolving landscape

Talking points

• Rapid regulatory shifts and ongoing innovation have fueled historic digital asset growth in 2025.
• Amid this expansion, finance and accounting teams are confronting new compliance and reporting challenges.
• Deloitte’s Digital Assets Roadmap delivers practical digital asset accounting guidance for confidently navigating this fast-changing environment.

Just two years ago, the digital asset market faced growing skepticism and an uncertain future. Now, in Q4 2025, the sector stands out as one of the most dynamic and attractive opportunities for investors. So, what changed? Let’s dive in.

First, consider these striking milestones: Centralized cryptocurrency exchanges hit an all-time-high trading volume of $75.8 trillion in 2024.¹ The trend continued in 2025 with the strongest half-year volume since 2021.² Meanwhile, crypto commerce payments in USD Coin (USDC) during the first six months of 2025 were 337% higher than in 2024.³ And digital asset mergers and acquisitions (M&A) and US public listings tripled year over year, signaling strong market momentum ahead.⁴

This rapid evolution is attracting many new investors and raising questions for finance and accounting teams grappling with the accounting, compliance, and reporting challenges of this fast-changing asset class. In this blog, we share practical guidance from Deloitte’s Digital Assets Roadmap to help you navigate this complex landscape.

The early crypto accounting landscape

When cryptocurrencies first began trading, entities holding these assets accounted for them as indefinite-lived intangible assets under ASC 350-30—a model poorly suited for tracking fair value or the nuances of this new asset class. Accounting standards hadn’t anticipated digital assets, making compliance feel like playing a board game without all the instructions.

The impact of SAB 121 and ASU 2023-08

Major regulatory changes came in 2022 when the SEC published SAB 121 to help registrants accommodate obligations to safeguard crypto assets.⁵ SAB 121 represented a shift in crypto accounting and financial reporting because it required entities to record the fair value of safeguarded crypto assets as a liability, with a corresponding asset.⁶ Adding to its complexity, the rule lacked a definition for safeguarding, requiring entities to use significant judgment to determine in-scope transactions.⁷

The following year, FASB’s ASU 2023-08 clarified that certain digital assets should be subsequently measured at fair value. While this moved accounting practices forward, some questions remained, and prior guidance still applies to certain assets.⁸

This year’s transformative shift

The SEC’s 2024 approval of spot Bitcoin and Ethereum ETFs marked a major milestone,⁹ sparking strong institutional interest and driving Bitcoin ETF inflows past $36.4 billion by year-end.¹⁰ But this was just a precursor for even bigger changes ahead. Following the 2024 election, a series of SEC moves signaled a shift from enforcement to innovation and capital creation. Here’s a quick rundown of some of the year’s standout regulatory developments:

• Crypto Task Force: The SEC launched a new Crypto Task Force in January for the purpose of developing a comprehensive and clear regulatory framework for crypto assets.¹¹
• SAB 122: Two days later, the SEC issued SAB 122, which rescinded SAB 121, ending ambiguity around crypto asset safeguarding (for details on SAB 122, see The Pulse blog, “The SEC changes accounting rules for safeguarding crypto assets with its SAB 121 repeal”).¹²
• Presidential Working Group on Digital Asset Markets: An executive order created this group to strengthen US leadership in digital finance and to create a federal regulatory framework governing the issuance and operation of digital assets in the United States.¹³
• DeFi: Congress overturned the IRS’s DeFi (decentralized finance) broker rule, easing digital asset reporting requirements seen as unworkable by the crypto industry.¹⁴
• Stablecoins: The GENIUS Act, enacted in July, brought stability and regulatory oversight to payment stablecoins (PSCs), bridging the gap between traditional and decentralized finance.

Where we are now

The SEC’s shift toward regulatory clarity, capital creation, and innovation—highlighted by repealing SAB 121 and the FASB’s issuance of ASU 2023-08—has fueled market growth by easing compliance and encouraging wider institutional participation. Now, 86% of institutional investors have or plan to invest in digital assets this year, according to a recent industry survey.¹⁵

Looking ahead

What’s next? We see a number of important developments on the near-term horizon. They include the arrival of the President’s Working Group’s recommendations and the continued rise of real-world asset (RWA) tokenization. Picture real estate, commodities, and private equity transformed into blockchain tokens for better liquidity. Analysts project the RWA market will exceed $50 billion in 2025 and soar to $18.9 trillion by 2033.¹⁶ Plus, ongoing advances in DeFi and deeper AI–blockchain integration in 2025 are set to further speed up adoption.

Deloitte’s Digital Assets Roadmap: Lifting the fog on digital asset accounting

Deloitte’s Digital Assets Roadmap provides comprehensive accounting and reporting guidance to help simplify complexities of digital asset accounting and manage risk. The roadmap covers a wide range of accounting and financial reporting topics—from tax considerations on digital asset gains and losses to the intricacies of crypto asset lending, borrowing, and derecognition.

What role can Deloitte play?

Deloitte can advise you on the accounting, reporting, and regulatory complexities of the rapidly evolving digital assets space. Our Audit & Assurance specialists have deep experience with the digital asset ecosystem. For more information, download Deloitte’s “On the Radar: Digital Assets” guide. You can also visit our DART Digital Assets Roadmap website.

Endnotes

1. Blockchain News, “Centralised exchanges reach record trading volume of $75.8 trillion in 2024,” January 22, 2025.
2. Fintech Finance News, “Crypto exchange trading volume surges to $9.36 trillion in H1, highest since 2021,” July 21, 2025.
3. Vilius Barbaravičius, “CoinGate H1 2025 crypto payments report: MiCA’s shakeup and the rise of USDC,” CoinGate, September 3, 2025.
4. Houlihan Lokey, FinTech Group: Digital assets market update, Fall 2025.
5. Amy Park and Reza van Roosmalen, “On the Radar: Digital Assets,” Deloitte Accounting Research Tool (DART), May 2025.
6. Amy Park et al., “SEC signals new direction for US crypto regulation: 4 considerations,” Deloitte CFO Journal for the Wall Street Journal, January 28, 2025.
7. Amy Park and PJ Theisen, “The SEC changes accounting rules for safeguarding crypto assets with its SAB 121 repeal,” Deloitte’s The Pulse blog, April 9, 2025.
8. Park et al., “On the Radar: Digital Assets,” DART, May 2025.
9. Alexandra Andhov, “Ethereum ETFs approved: Insights into the SEC’s decision,” Forbes, last updated May 24, 2024.
10. Citigroup, “Digital Asset Take: 2025 outlook — A new hope,” January 13, 2025.
11. US Securities and Exchange Commission (SEC), “SEC Crypto 2.0: Acting Chairman Uyeda announces formation of new crypto task force,” press release, January 21, 2025.
12. Park et al., “The SEC changes accounting rules for safeguarding crypto assets with its SAB 121 repeal.”
13. The White House, “Fact Sheet: Executive Order to Establish United States Leadership in Digital Financial Technology,” January 23, 2025.
14. Hannah Lang, “Trump signs bill to nullify expanded IRS crypto broker rule,” Reuters, April 10, 2025.
15. Brett Tejpual et al., 2025 Institutional Investor Digital Assets Survey, EY-Parthenon and Coinbase, March 2025.
16. Ripple, “Global financial infrastructure entering a new era as tokenized assets set to surge to $19 trillion by 2033,” press release, April 7, 2025.

The services described herein are illustrative in nature and are intended to demonstrate our experience and capabilities in these areas; however, due to independence restrictions that may apply to audit clients (including affiliates) of Deloitte & Touche LLP, we may be unable to provide certain services based on individual facts and circumstances.

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