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Upgrading subledgers: SEC and FASB compliance for Bitcoin miners in 2024

Upgrading subledgers: SEC and FASB compliance for Bitcoin miners in 2024

Regulatory bodies like the Securities and Exchange Commission (SEC) and the Financial Accounting Standards Board (FASB) are increasingly focusing on ensuring transparent and compliant financial practices within the industry. 

For Bitcoin miners, this means upgrading their accounting systems, specifically their subledgers, to meet the new guidelines and standards set forth for 2024. This blog explores the importance of these upgrades and what Bitcoin miners' finance teams need to know to stay compliant and efficient.

The latest guidelines and standards for Bitcoin miners

The SEC and FASB have been actively developing and updating guidelines to ensure the transparent and compliant handling of digital assets. For Bitcoin miners, these guidelines are crucial as they impact how financial activities related to mining operations are recorded, reported, and audited.

Below, we highlight some of the latest guidelines from the SEC and the FASB that affect the daily operations of Bitcoin mining companies.

Image 1_SEC & FASB

SEC Guidelines

  1. Disclosure requirements:
    • The SEC mandates detailed disclosures of digital asset holdings and transactions. Miners must provide comprehensive reports on the volume of mined Bitcoin, the valuation methods used, and the financial impact of these assets on their balance sheets.
    • Enhanced transparency in reporting significant risks associated with digital assets, including market volatility and security concerns.

  2. Internal controls and procedures:
    • Miners are required to implement robust internal controls to ensure the accuracy and integrity of financial reporting. This includes procedures for tracking and verifying Bitcoin transactions and safeguarding digital assets.
    • Regular audits and reviews of internal controls to comply with the Sarbanes-Oxley Act (SOX), which ensures the reliability of financial disclosures.

  3. Anti-money laundering (AML) and know your customer (KYC) compliance:
    • Stricter enforcement of AML and KYC regulations to prevent illicit activities involving digital assets. Miners must ensure they have adequate systems in place to verify the identity of parties involved in transactions and report suspicious activities.

FASB Standards

  1. Fair value measurement:

    • The FASB emphasizes the use of fair value measurement for digital assets under ASU 2023-08. Miners must accurately determine the fair value of mined Bitcoin, taking into account market conditions and using appropriate valuation techniques.
    • Regular revaluation of digital assets to reflect current market prices, ensuring that financial statements present a true and fair view of the company's financial position.

    To learn how to do to Fair Market Value (FMV) accounting for your Bitcoin mining company read our comprehensive guide in partnership with Marcum – a leading accounting and advisory firm.

  2. Revenue recognition:

    • Updated guidelines on revenue recognition require miners to recognize revenue from Bitcoin mining activities when it is probable that economic benefits will flow to the entity and the revenue can be reliably measured.
    • Clear criteria for recognizing revenue from the sale of mined Bitcoin, including considerations for transaction costs and market liquidity.

  3. Presentation and disclosure:

    • The FASB requires clear presentation and disclosure of digital assets in financial statements. Miners must separately present digital assets from other financial instruments and provide detailed notes on valuation methods, market risks, and impairment testing.
    • Enhanced disclosure requirements for digital asset transactions, including the nature and purpose of the transactions, parties involved, and any associated risks.

Challenges Bitcoin miners face to ensure compliant crypto accounting

Bitcoin mining is a complex process and with the new SEC guidelines and FASB standards staying compliant with your digital asset accounting can prove challenging. Additonally, traditional accounting systems are not equipped to handle the unique characteristics of digital assets, leading to several challenges:

  1. Valuation and pricing: The volatile nature of Bitcoin prices makes it difficult to consistently value mined assets. Accurate pricing models are essential for compliance with FASB standards, which require precise valuation methods.

  2. Transaction tracking: Bitcoin miners often deal with numerous transactions daily. Tracking these transactions in a transparent and compliant manner is a significant challenge, especially when considering the decentralized nature of cryptocurrencies.

  3. Regulatory compliance: As mentioned earlier, the SEC and the FASB have stringent guidelines and standards for digital asset financial reporting and disclosure. Miners must ensure their accounting practices adhere to these guidelines, which can be complex and require specialized knowledge.

  4. Auditability: Ensuring that all transactions are easily auditable is crucial for compliance. Traditional systems may lack the transparency and traceability needed to satisfy auditors and regulators.

Key features Bitcoin mining companies should look for in a digital asset accounting solution

To overcome compliance and regulatory challenges, Bitcoin miners need to adopt specialized crypto accounting solutions that offer the following key features:

  1. Complete data integration: the ability to integrate with various platforms and automatically pull transaction data is essential. This includes on-chain wallets, centralized exchange trading, lightning channels, L2 activity and OTC trading. This reduces manual entry errors and ensures data accuracy.

  2. Real-time & historical reporting: Real-time reporting features allow miners to track their financial positions accurately at any moment. But it is essential to have historical reporting capabilities with proof of completeness and accuracy assurances.

  3. Compliance tools: robust compliance tools that align with SEC guidelines and FASB standards are critical. These tools should offer audit trails, compliance checks, and regulatory reporting features.

  4. Scalability: as mining operations grow, the accounting solution should be able to scale accordingly, handling increased transaction volumes without compromising performance.

  5. Security: given the high value of digital assets, security is paramount. The solution should offer advanced security features (e.g. SOC compliant) to protect sensitive financial data.

  6. Principal market pricing: ensure your mined assets are accurately valued. The accounting solution should utilize pricing data from the primary markets where your cryptocurrencies are actively traded, reflecting true market conditions in your portfolio's valuation.

  7. FMV automation: fair value accounting is essential in the unpredictable crypto market. The chosen software should offer strong support for fair value pricing, ensuring accurate reporting of your crypto holdings' value, even during significant market fluctuations.


Cryptio: the leading digital asset accounting platform for Bitcoin miners

Cryptio offers a comprehensive digital asset platform designed for the unique needs of Bitcoin miners. With its robust set of features and focus on compliance, Cryptio is well-positioned to help Bitcoin miners navigate the complexities of crypto accounting in 2024 and beyond.

Our platform will help you with:

  1. On & Off chain Data Aggregation: Cryptio serves as the source of truth for your transaction data. You can ingest all your on-chain activity including Multi-sigs, and custody implementations with complex derivation paths. And in-addition to on-chain data you can ingest your OTC, Trading and Lightning data from off-chain sources.  

  2. Automated transaction labeling: Cryptio automates tagging transactions using a flexible rule based labeling system. You can automate the tracking of mining revenue, trading activity, expenses, internal transfers and break this down by mining site or business entity.

  3. General Ledger Sync and Trial Balance: by leveraging your labels, Cryptio can automatically book journal entries to segregated chart of accounts both on your balance sheet as well as your income statement. Our in-app Trial Balance then allows you to track performance across various miners on a period-to-period basis.

  4. FMV Module: Cryptio’s fair market value module can automatically revalue all assets in a compliant approach with FASB’s new fair value rules. Revaluations can be scheduled to occur at various time intervals with corresponding mark-to-market and unrealized journal entries booked simultaneously.

  5. FP&A module: our FP&A module allows users to build detailed analysis around revenues and expenses based on our labeling system. This includes comparison of related fee expenses to rewards generated for an understanding of potential profitability within each miner.

  6. Reporting suite: our comprehensive reporting suite will provide flexibility for all reporting needs including inventory management, journal entry reporting, transaction details, and more.

Cryptio is trusted by 400+ leading enterprises in crypto and beyond, including The Govt. of El Salvador, Luxor, Rainbow Energy, Pega Pool, Gridless, Green Mining DAO. Join the ranks, and book a demo today.

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