Now trending: SPAC cryptocurrency investments

Contributors: Emily Matthews, Capital Markets Transactions Partner, Deloitte & Touche LLP; Matthew Behar, Audit & Assurance Senior Manager, Deloitte & Touche LLP

Talking points:        

• Amid accelerated enterprise adoption of crypto, we’re seeing the rise of a new type of special-purpose acquisition company (SPAC) investment, focused on holding cryptocurrencies.       
• Digital asset treasury SPACs carry the same risks as traditional SPACs, including the chance they won’t be acquired by an operating company.
• This new trend is happening as crypto prices rise and new laws are being discussed.

It’s an exciting time to be a SPAC. But before we dive into the reasons why, let’s start with the basics. A SPAC is a business set up to raise money through an initial public offering (IPO) with the goal of merging with or acquiring a private company. Back in 2021, SPACs made up 63% of new US listings, but that number dropped to 30% last year as the market continued to cool from its 2021 high.¹

Now, as more companies are exploring crypto, SPAC activity
is picking up again—especially around what’s being called “digital asset treasury SPACs.” These are like traditional SPAC investments but instead focus on giving investors exposure to cryptocurrencies. They do this by aiming at companies that already hold crypto assets or ones that plan to invest in crypto. Some SPACs are also looking at businesses that support the broader crypto ecosystem.

There’s a new digital asset treasury strategy in town

Digital asset treasury management of SPAC investments works much like it does for traditional SPACs. After their IPO, most of their raised funds are kept in a trust through investments in safe assets like US government securities or money market funds. They have a set window—usually 24 months—to complete a merger or acquisition. If they don’t, they must return the SPAC cryptocurrencies to investors.

So, what sets digital asset treasury SPACs apart? The difference is what happen after the merger. Once the deal is done, the new company can use the funds to build its digital asset treasury and buy or manage crypto itself. The merged company could also use its funds to invest in a promising crypto startup, for example, or pursue other ways to generate returns. In this way, investors get exposure to both the operating company and its crypto holdings.

Crypto treasury strategies

Wondering if this trend signals a broader comeback for SPACs or is just limited to crypto’s resurgence? We think it’s both. Some public companies have already adopted a digital asset treasury strategy without using a SPAC. And for those looking to go public with a crypto focus, SPACs aren’t the only option. Another popular route is a reverse takeover (RTO), where a private company with a crypto or digital asset treasury merges with a public company that doesn’t have much activity.

Complexities abound

Even though markets and regulations are maturing, digital asset treasury management is still new and evolving. Public companies should move quickly and maintain strong back-office systems to address reporting requirements. That leaves little time to sort through crypto’s unique accounting, tax, and regulatory challenges. Not all crypto assets are treated the same for accounting purposes. Some, like “wrapped” assets—tokenized representations of a real-world or cryptocurrency asset that lives on a different blockchain—have different rules.

Digital asset treasury risk management is also complicated. Companies need solid controls for things like custody, access, and auditability. Designing and testing these controls is tough, especially when relying on third-party service providers, and the challenges don’t stop after the merger. SPACs are supposed to acquire operating businesses, not just assets. If a SPAC’s main acquisition is crypto, it could face extra regulatory scrutiny and hurdles.

Rising momentum

This renewed interest in digital asset treasury strategies comes as crypto prices rise, and lawmakers focus more on the industry. Three recent bills are shaping the landscape:

• The GENIUS Act regulates stablecoins (cryptos attached to the US dollar) and became law on July 18, 2025.²
• The CLARITY Act sets up a market structure for crypto. It passed the House on July 17, 2025, and is awaiting Senate review.³
• The Anti-CBDC Surveillance State Act aims to stop the Federal Reserve from issuing a retail digital dollar. It also passed the House on July 17, 2025, and is with the Senate.⁴

One thing is clear: these These developments show that crypto is changing fast. SPAC investments are making a comeback, with this year’s IPO proceeds already topping those from 2022. Crypto and its investment vehicles are moving from the fringes to the mainstream. Still, there are plenty of risks and complexities to navigate—especially for those using SPAC cryptocurrencies to speed up their market entry.

What role can Deloitte play?

Considering a SPAC crypto investment? Deloitte can advise you on navigating the accounting, tax, and regulatory complexities of investing in this fast-moving market. Our audit and assurance specialists have experience in SPACs, IPOs, and crypto investing. For more information, check out our corporate crypto investing perspective, download our Stablecoin/GENIUS Act guide, or visit our SPAC website. You can also reach out to us directly. 

Endnotes

1. Lyle Daly, “SPAC statistics for 2025,” Motley Fool, July 11, 2025.

2. The White House, “Fact Sheet: President Donald J.
Trump signs GENIUS Act into law,” July 18, 2025.

3. Julian Mark and Shannon Najmabadi, ”House passes first major regulation
for crypto industry,” Washington Post, July 17, 2025.

4. Ibid.

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