IAS 38 and Crypto: The IFRS Intangible-Asset Treatment

There is no IFRS standard written for crypto. What governs instead is an IFRS Interpretations Committee agenda decision from June 2019, which routes a crypto holding into either intangible-asset or inventory accounting and rules out cash and financial-asset treatment. This article is the IFRS hub for crypto accounting: the 2019 decision, the IAS 38 cost and revaluation models, the active-market constraint on fair value, and why IFRS and US GAAP now produce different numbers. The US-GAAP counterpart, where fair value through net income is mandatory, is FASB ASU 2023-08.

The IFRS position in brief

• There is no crypto-specific IFRS standard; the IFRS IC June 2019 agenda decision governs.
• Crypto held for sale in the ordinary course of business falls under IAS 2; everything else falls under IAS 38 as an intangible asset.
• A crypto holding is neither cash nor a financial asset.
• The IAS 38 default is the cost model (cost less impairment, no write-up). Fair value is available only through the revaluation model, and only where there is an active market, with gains routed to OCI rather than profit or loss.
• This diverges from US GAAP: ASU 2023-08 mandates fair value through net income, while IFRS does not (see FASB ASU 2023-08 and IFRS vs US GAAP).
• Disclosures draw on IAS 38 ¶118–128, IAS 2 ¶36–39, and IFRS 13 ¶91–99 where holdings are fair-valued.

The governing text: the June 2019 agenda decision

There is no IFRS standard written for crypto. The authority is the IFRS Interpretations Committee's June 2019 agenda decision, "Holdings of Cryptocurrencies." It addresses a defined subset: a digital or virtual currency on a distributed ledger, secured by cryptography, not issued by a jurisdictional authority or other party, and conferring no contract between holder and another party.

The decision reaches three conclusions:

1. A crypto holding is not cash — no cryptocurrency is used as a medium of exchange and unit of pricing to the extent all transactions would be measured in it.
2. It is not a financial asset — not cash, not another entity's equity, not a contractual right to cash/another financial asset.
3. It therefore meets the IAS 38 intangible-asset definition: it is separable (can be sold/transferred) and is not a right to a fixed or determinable number of units.

The IAS 2 / IAS 38 fork

The first question is the business model:

Most corporates holding crypto on treasury or as a strategic asset are in IAS 38. The broker-trader path is the exception, not the norm.

IAS 38: cost vs revaluation

Within IAS 38 there are two measurement models:

• Cost model (the default): cost less accumulated impairment. Impairments are recognised; no write-up when value recovers. This is the IFRS analogue of the legacy US-GAAP problem (see crypto impairment vs fair value).
• Revaluation model: carry at fair value only if there is an active market for the asset. Revaluation increases go to other comprehensive income (a revaluation surplus); they do not flow through profit or loss (decreases reverse a surplus first, then hit P&L).

The active-market condition is restrictive: it must be met for the specific asset, and many tokens will not qualify. So IFRS fair value for crypto is conditional and OCI-routed, not the mandatory P&L fair value of US GAAP.

Why IFRS and US GAAP now diverge

US GAAP's ASU 2023-08 mandates fair value through net income for in-scope crypto. IFRS has no equivalent mandate. A dual-reporting Web3 entity will therefore show different crypto carrying amounts and different earnings under each framework — IFRS often at cost-less-impairment, US GAAP at full fair value in net income. This is one of the largest framework differences in the space (see IFRS vs US GAAP for crypto).

Disclosures

• IAS 38 holdings: disclosures in IAS 38 ¶118–128.
• IAS 2 (held for sale in ordinary course): IAS 2 ¶36–39.
• If holdings are measured at fair value: IFRS 13 ¶91–99.
• Plus the judgements made in determining which standard applies.

Practical guidance

1. Classify by business model first — broker-trader (IAS 2) vs everything else (IAS 38).
2. Default to the IAS 38 cost model unless an active market supports revaluation.
3. If revaluing, route gains to OCI (revaluation surplus), not profit or loss.
4. Track impairment under the cost model — recognised on decline, no reversal to a write-up.
5. Document the standard-selection judgement and give the ¶118–128 / ¶36–39 / ¶91–99 disclosures.
6. Reconcile to the US-GAAP number if dual-reporting — the gap is expected, not an error.

Choosing a tool for IFRS crypto

The IAS 38 / IAS 2 boundary and any revaluation decision are accounting judgements, but the carrying amounts and disclosure data come out of a subledger. If you are evaluating one — Cryptio and Request Finance are common choices — confirm it can:

• carry a cost-less-impairment basis per asset with an impairment history;
• hold a separate fair value where an active market supports the revaluation model, or for a parallel US-GAAP set;
• distinguish IAS 38 holdings from IAS 2 broker-trader inventory;
• export the IAS 38 ¶118–128, IAS 2 ¶36–39, and IFRS 13 ¶91–99 disclosure data.

IFRS and US GAAP need different numbers from the same underlying records, so a tool that only stores one basis will not serve a dual reporter.

How Wag3s fits in

Wag3s Ledger carries crypto at an IAS 38 cost-less-impairment basis with an impairment trail, supports a revaluation or fair-value parallel where an active market exists, and produces the IAS 38, IAS 2, and IFRS 13 disclosure data, plus the reconciliation to a US-GAAP ASU 2023-08 set for dual reporters. The standard-selection and active-market judgements stay with your auditor; Ledger supplies the figures and audit trail they review. See the Ledger product page and the Wag3s for accountants page.

Further reading

• FASB ASU 2023-08: Fair-Value Crypto Accounting
• IFRS vs US GAAP for Crypto
• Crypto Held as Inventory (IAS 2)
• Crypto Impairment vs Fair Value Accounting
• Stablecoin Accounting Treatment
• Crypto Audit Readiness

Sources

• IFRS Interpretations Committee — Holdings of Cryptocurrencies, June 2019 agenda decision: a crypto holding is not cash and not a financial asset; IAS 2 applies if held for sale in the ordinary course of business, otherwise IAS 38.
• IFRS — IAS 38 Intangible Assets: cost model, revaluation model conditional on an active market, and the ¶118–128 disclosures.
• IFRS — IAS 2 Inventories: held for sale in the ordinary course of business; ¶36–39 disclosures.
• IFRS — IFRS 13 Fair Value Measurement: ¶91–99 disclosures where holdings are measured at fair value.