compliance20 min read

Ethereum Accounting Under US GAAP: ASC 350-60 Explained

Ethereum accounting under US GAAP: ASC 350-60 scope test, fair value, native staking, gas and transaction costs, derecognition, disclosures and ASC 740.

M

Maksym Buhai

Accounting Engineer

August 12, 2026 · 20 min read

Cover reading "ASC 350-60 does not tell you how the ETH got there", beside a solid charcoal panel stacked above an empty panel of the same size drawn in a dashed violet outline

Native ETH sits within a specific US GAAP cryptoasset model, but that does not mean every Ethereum transaction is answered by ASC 350-60. The correct starting point for Ethereum accounting under US GAAP is the scope test. After that, ASC 350-60 governs subsequent fair-value measurement and specified presentation and disclosures for in-scope crypto assets.

Important questions remain outside the Subtopic, including initial recognition, many transaction-cost questions, staking-reward accounting, and parts of derecognition.

This article therefore separates the four strands of Ethereum accounting under US GAAP:

  • what ASC 350-60 expressly requires;
  • what other Codification guidance supplies;
  • what major interpretive guidance concludes; and
  • what remains judgement or an unresolved gap.

Guidance date: US GAAP and FASB project information were refreshed through 31 August 2026. The FASB's project on transfers of crypto assets is active and includes possible expansion of ASC 350-60 to certain wrapped and receipt tokens plus clarification of derecognition. Tentative project decisions do not change current GAAP.

Ethereum accounting under US GAAP: does native ETH meet ASC 350-60?

ASC 350-60-15-1 lists six criteria. An asset is in scope if it meets all of them. It meets the definition of an intangible asset. It does "not provide the asset holder with enforceable rights to or claims on underlying goods, services, or other assets". It is "created or reside[s] on a distributed ledger based on blockchain or similar technology". It is "secured through cryptography". It is fungible. And it is "not created or issued by the reporting entity or its related parties". The reach of the Subtopic sits in a separate paragraph, ASC 350-60-15-2, rather than in the criteria list: the guidance "applies to all entities that hold crypto assets".

Native ETH satisfies all six - this article's own application of the criteria, since no authoritative source located names ether, and that is worth stating plainly. But KPMG's April 2026 handbook says "crypto assets like BTC, ETH and SOL do not grant enforceable rights to their holder for any other goods, services or underlying assets", and every operating-company registrant examined applies ASC 350-60 to its ETH. The exchange-traded products examined point the same way, subject to one condition stated below. They are in scope: ASC 350-60-15-2 applies to all entities that hold crypto assets, and the basis for conclusions records the Board deliberately putting investment companies inside that scope - "the Board decided that it is beneficial to include those entities within the scope of the amendments in this Update", primarily because "investors will benefit from enhanced disclosures" (BC27) - and then not providing the exemption a trade group requested for certain Topic 946 investment companies from the significant-holdings disclosure, observing instead that "an entity is not required to duplicate the significant holdings disclosure if that information is presented or disclosed elsewhere in the financial statements", and that an entity giving the information outside the financial statements "must provide the required disclosures within the financial statements" (BC62). The accommodation is non-duplication, not exemption. The Update amends no Subtopic of Topic 946 and carves nothing out of ASC 350-60. What ASC 946 changes for an exchange-traded product is presentation, not scope: the Board "decided that investment companies should continue to present amounts related to crypto assets … in accordance with that industry-specific guidance". So an exchange-traded product that gives ASC 350-60 disclosures has already concluded that its ETH meets the criteria in ASC 350-60-15-1 - this article's own reading of what such a disclosure implies, and it is stated as a conditional, because no examined product's disclosures were tested against ASC 350-60-50 for this purpose. Where the condition holds, that is corroboration rather than silence. Criterion (f) is satisfied for an entity running its own validator, with a condition worth carrying: the Board's basis for conclusions (BC17) records that such an entity "is not the creator of the crypto assets that it receives as consideration for performing services if mining or validating is the only involvement that an entity has in the creation of the asset".

Measurement is unambiguous. ASC 350-60-35-1, first sentence: "An entity shall measure crypto assets at fair value in the statement of financial position"; second sentence: "Gains and losses from the remeasurement of crypto assets shall be included in net income." Presentation is prescribed, but more narrowly than the words first suggest. ASC 350-60-45-1: "Crypto assets shall be presented separately from other intangible assets in the statement of financial position", and its second sentence adds that "[a]n entity is permitted to present crypto assets on a more disaggregated basis (for example, by individual crypto asset holding or intangible asset class)". ASC 350-60-45-2: "Gains and losses from the remeasurement of crypto assets shall be included in net income and presented separately from changes in the carrying amount of other intangible assets." Read the last clause closely. What has to be kept apart is the remeasurement of crypto and the carrying-amount movements of other intangible assets - not the remeasurement result and everything else in the income statement. There is no requirement for a dedicated income-statement caption - 45-1's separate line is a balance-sheet requirement, and a different one - and the standard says so itself: ASC 350-60-50-2(b) calls for annual disclosure of, "[i]f not presented separately, the line item in which gains and losses are reported in the income statement", which would be meaningless if separate presentation were compulsory. The guidance is "effective for all entities for fiscal years beginning after December 15, 2024, including interim periods within those fiscal years" (ASC 350-60-65-1(a)). So for a calendar-year entity, 2025 was the first mandatory year and the old cost-less-impairment model is gone.

It does not tell you how the ETH got there. ASC 350-60-05-2 says so, and says where to look instead: "This Subtopic does not address the initial measurement, recognition, and derecognition of crypto assets. Reporting entities shall account for the initial measurement, recognition, and derecognition of crypto assets in accordance with other generally accepted accounting principles (GAAP)." The codified hinge that makes the initial-measurement half of that work is ASC 350-30-15-4(e), amended by ASU 2023-08, which takes out of ASC 350-30 "[c]rypto assets accounted for in accordance with Subtopic 350-60, except for recognition and initial measurement of crypto assets". Both halves of that qualifier do work. Only in-scope crypto leaves, which is what keeps the out-of-scope receipt tokens of the next subsection inside ASC 350-30; and even in-scope crypto stays there for recognition and initial measurement, which is why ASC 350-30-30-1 applies at all. From there initial measurement runs to ASC 805-50-30-1, under which "Assets are recognized based on their cost to the acquiring entity, which generally includes the transaction costs of the asset acquisition". ETH received from a customer runs through ASC 606, which unlike IFRS fixes the measurement date: under ASC 606-10-32-21, "an entity shall measure the estimated fair value of the noncash consideration at contract inception". Where no Topic applies, ASC 105-10-05-2 requires the entity to "first consider accounting principles for similar transactions or events within a source of authoritative GAAP". Its second sentence is the limit on that, and it matters wherever this section reaches for an analogy: "An entity shall not follow the accounting treatment specified in accounting guidance for similar transactions or events in cases in which those accounting principles either prohibit the application of the accounting treatment to the particular transaction or event or indicate that the accounting treatment should not be applied by analogy."

Disclosure is specific and easily missed. At interim and annual dates - ASC 350-60-50-1 opens "At interim and annual reporting periods" and 50-6 "For interim and annual reporting periods", and ASU 2023-08 added ASC 270-10-50-7(p) as a signpost to them - disclose for each significant holding the name, cost basis, fair value and number of units, plus aggregates for the rest, and the fair value, nature, remaining duration and lapse conditions of any contractual sale restrictions. Annually, also disclose the cost-basis method used, for which the standard's own examples are "first-in, first-out", "specific identification", "average cost", or "other method used"; "[i]f not presented separately, the line item in which gains and losses are reported in the income statement" (ASC 350-60-50-2(b)); the "[t]otal amount of cumulative realized gains and cumulative realized losses from dispositions that occurred during the period" (ASC 350-60-50-4(b), the companion to the 50-4(a) disposition detail); and a rollforward "of activity from the opening to the closing balances" separately showing additions, dispositions, gains and losses.

Two mechanics inside those requirements are worth pulling out. The rollforward's gain and loss lines, ASC 350-60-50-3(c) and (d), are determined on a "crypto-asset-by-crypto-asset basis". An entity holding both ETH and BTC therefore cannot net a BTC loss against an ETH gain in the disclosure: the unit of account is the individual crypto asset, which is the same problem the complete Ethereum journal-entry example runs into from the measurement side. And ASC 350-60-50-5 carries an exemption for the same nearly-immediate conversions that ASC 230-10-45-27A addresses below; without it, that treatment is only half told.

Note the word contractual in the restriction disclosure. A validator exit queue is a protocol restriction, not a contractual one. Whether it falls inside ASC 350-60-50-6 is a question no source located answers. What Accounting Standards Still Do Not Answer About Ethereum records it.

Native ETH in the holder's own validator

There is no authoritative guidance on ETH that an entity has staked natively, but practice and interpretation are aligned and the reasoning is the same as under IFRS. KPMG: "In general, staked tokens are not derecognized by the staking entity" because "no other entity obtains the right or ability to direct their use". A registrant staking large amounts of ETH puts it this way in its audited financial statements: "Native staked ETH are not derecognized because their deposit into the smart contract does not give any other entity the right or ability to direct their use … and the staked ETH may be withdrawn at any time by the delegator through the use of private withdrawal keys, subject only to protocol-defined withdrawal and exit queue mechanics."

Receipt tokens are the opposite case and are a different token type, outside this article. It is worth knowing only that the boundary is real, and that it is not drawn uniformly. Three of the registrants examined derecognise the ETH and conclude the token itself fails ASC 350-60-15-1(b) because it does give enforceable rights to other assets, so it sits at cost less impairment under ASC 350-30 instead of at fair value. But the AICPA's answer to its own question, "Are 'wrapped tokens' in the scope of FASB ASC 350-60?", is "It depends", because "the conclusion as to scope may differ from one wrapped token to the next" on the facts and circumstances. And one registrant examined reaches a third answer entirely, placing its liquid staking tokens "within the scope of ASC 310 and ASC 815-15" and accounting for them "as a non-monetary receivable with an embedded derivative", the host contract carried at cost and the embedded derivative measured at fair value each reporting date - and saying so in terms: "There is diversity in industry practice regarding the measurement and recognition of liquid staking tokens and related rewards."

Staking rewards: no explicit US GAAP model and no single market practice

This is the largest open question in Ethereum accounting under US GAAP, and it is worth being blunt about how open it is.

KPMG's April 2026 hot topic states the position: "There is currently no explicit US GAAP that directly addresses the accounting for crypto intangible asset staking." The AICPA's practice aid, non-authoritative in any case, has no staking question and answer at all in the edition checked for this article, the one "as of Sept. 30, 2025", which is the most recent edition that downloads without a member login. Its accounting chapters cover proof-of-work mining, and staking appears only in the auditing chapters as something to confirm. The landing page carries a "2026 Update" heading over that same download, so a newer text may sit behind that login; it has not been inspected here, and the negative is stated as at the September 2025 text. The FASB has no project on staking, staking rewards or crypto revenue recognition.

What the practice aid does have is the nearest available analogy, and it splits the question the way the protocol does. Mining Q&A 27: "Transaction fees earned by a miner should be recognized as revenue from customers in accordance with FASB ASC 606 … The requester meets the definition of a customer", while "Block rewards earned by a miner are generally recognized as revenue, but an evaluation is required …", and then, a few lines later, "a miner could apply by analogy the revenue recognition guidance in FASB ASC 606". What the practice aid puts between those two block-reward sentences is a condition, and it is the operative one: it works through whether the block rewards are revenue from a contract with a customer, and the analogy is available only where the miner concludes they are not. That is the execution-layer and consensus-layer split of Ethereum for Accountants in accounting language; carrying it across from proof of work to proof of stake is this article's own reading, not the AICPA's. One consequence travels with the by-analogy route: "If analogizing to FASB ASC 606, the revenue from block rewards would be presented separately from FASB ASC 606 revenues from contracts with customers on the statement of comprehensive income or separately disclosed in the notes to the financial statements", which is the requirement in ASC 606-10-50-4(a).

What fills the gap is ASC 606, and the threshold judgement is the one IFRS poses in the same place: is there a customer? KPMG gives a sentence that looks like an answer - "We believe the 'customer' for the validation services is the blockchain network" - but gives it inside the principal-agent analysis; when it turns to revenue classification it lists the network as one of several possible customers and records that entities often conclude a decentralised network "cannot, as a non-entity, be a customer and, therefore, the staking rewards are most appropriately characterized as 'other revenue'". The route then follows whatever that answer turns out to be: "we believe it will typically be appropriate to apply the Topic 606 revenue guidance, either directly (if the rewards are revenue from a contract with a customer) or by analogy (if the rewards are other revenue or other income)". Direct application and application by analogy are not the same thing, and the results diverge either way. Nine SEC registrants were examined. Individual registrants are described rather than named where the point is the spread of positions rather than any one company's; a name is given where a specific filing is itself the point, as with BitMine below and with the exchange-traded products. Eight of them stake, and among those eight there are seven different positions on when an ETH staking reward is recognised and how it is measured. Six of the seven come from audited annual financial statements and one from an unaudited quarterly report. (The ninth registrant, an exchange-traded product, "is not permitted to engage in Staking Activities" at all.) That position is no longer the uniform one among Ether exchange-traded products, though it is still the larger one by assets: Grayscale's ETHE and ETH Mini have staked since 6 October 2025, 21Shares' TETH was enabled on 8 October 2025, BlackRock's ETHB listed on about 12 March 2026, Morgan Stanley's MSSE launched on NYSE Arca on 28 July 2026 intending to stake "50 to 80% of the Trust's ether", and Fidelity's FETH was cleared to stake on 21 August 2026, ten days before this article's date. Enablement is not earning, and the gap is the validator entry queue: ETHB's ether "became actively staked and earning rewards" only on 4 May 2026, and TETH booked $1,121 of staking income across the whole of the fourth quarter of 2025 against $62,288 in the first quarter of 2026. Counting products, staking is roughly half the field. Counting assets it is the minority, because BlackRock's ETHA still does not stake, per its Form 424B3 of 6 August 2026, and ETHA is more than half the category by itself: $4,292,908,953 of the $8,390,726,363 in net assets that the ten single-asset US ether ETPs with a 30 June 2026 quarter end reported, or 51.2%. That share is this article's computation from those ten filings, not a statement in any of them, and it clears half by just over one percentage point - another $195 million anywhere else in the field would take it back to half. MSSE, which listed after that quarter end, has reported no net assets at all. The ETP row below is a snapshot of a line that is still moving.

Registrant typeTimingMeasurement instantGross or net
Large exchange, own ETH"in the period received"not separately statedrecognised in other income, not revenue
Large exchange, customer staking businesswhen validation completes and rewards reach a wallet it controlscontract inceptiongross
ETH treasury company A"at a point in time as each validation event occurs". The contract term "corresponds to the duration of each staking epoch"contract inceptiongross, as principal node operator
ETH treasury company B"at the point in time when the Ethereum network confirms that the validation is complete"contract inceptionnet (concluded it is not the principal)
ETH treasury company Con confirmation "and the awards are deposited to our address"time of receipt, daily close pricesgross
ETH treasury company Don confirmation, when awards are "available for transfer"fair value when earned, hourly spot for cost basisgross for own nodes
Ether ETPratably over the contract term, the term being "the length of each staking epoch"fair value "at the inception of each contract (i.e., the beginning of each staking epoch)"net of validator fees
Seven positions on when an ETH staking reward is recognised and how it is measured.

Two of those deserve emphasis. One large exchange books rewards on its own investment ETH in other income rather than revenue, while every ETH treasury company examined books its own rewards as revenue. That first choice is not the anomaly it looks like: the AICPA presentation sentence above puts block-reward income recognised by analogy apart from ASC 606 revenue from contracts with customers, whether on the face of the statement or in the notes, and other income is one of the places it can sit. And two entities reach opposite gross-versus-net answers on the same protocol, but on genuinely different facts, which is the useful part. One operates the nodes and presents gross as principal node operator. The other stakes as a delegator and presents net, concluding that "it is the validators that control the service". The divergence is in the role, not in the reasoning, and an entity cannot pick whichever answer it prefers without first settling which role it is in.

The cost-basis methods diverge just as widely. Four methods appear across the same nine filers: specific identification, FIFO (in one case expressly applied wallet by wallet), LIFO and average cost. So do the pricing conventions: midnight UTC, hourly spot at receipt, 4:00 p.m. New York, and, in one ETP, 11:59 p.m. Eastern for the GAAP financial statements while the published net asset value uses a 4:00 p.m. Eastern benchmark.

The practical consequence for a preparer running its own validator is that there is no "market practice" to fall back on. There is a documented policy, or there is an exposure.

Gas and transaction costs

Gas paid to acquire crypto is capitalised - and that is this article's own reading of a chain of codified paragraphs, not an answer ASC 350-60 gives. The Subtopic does not address transaction costs, the exposure draft proposed the opposite answer, and the Board then decided not to give one at all. ASU 2023-08 BC33 records the proposal: "The Board proposed that transaction costs to acquire crypto assets … should be expensed as incurred unless an entity capitalizes those costs in accordance with industry-specific guidance (for example, investment companies within the scope of Topic 946)" - the proposal was never absolute, and the carve-out is the same Topic 946 discussed above. BC36 records where it landed: "the Board decided not to provide guidance on how to recognize or present transaction costs to acquire crypto assets." Capitalisation comes instead from the chain set out above - ASC 350-30-15-4(e) into ASC 350-30-30-1 into ASC 805-50-30-1 - and from the two interpreters that read it that way. The AICPA practice aid answers the question directly, and KPMG is explicit that "'gas fees' and other similar costs are transaction costs and should, therefore, be capitalized as part of the initial measurement of a crypto asset". The effect is usually short-lived: KPMG notes that "capitalized transaction costs … will generally be immediately written off" at the first remeasurement, because fair value does not include them.

Gas paid in ETH is a disposal of the ETH used. ASC 350-60 does not say how to measure that disposal; ASC 350-60-05-2 sends the entity to other GAAP, which for a disposal that is not a sale to a customer means ASC 350-10-40-1 and ASC 610-20. ASC 350-10-40-3(d) - added by ASU 2023-08 - directs the entity to "recognize gains and losses from remeasurement", but it governs the case where the transfer contract fails ASC 606-10-25-1 and the asset is therefore not yet derecognised; it is not the measurement rule for an ordinary disposal. And the route has a limit the article should state rather than hide: ASC 610-20 presupposes a contract and a counterparty, and a burned base fee has neither, so the codified chain runs out exactly where jurisdiction-specific tax authority can also run out. What is prevailing firm interpretation rather than codified rule is the narrower step used here: remeasure the departing units to fair value immediately before derecognition, then derecognise at that fair value, with the result that a disposal at the principal-market price generally produces no separate gain. ASC 350-60-50-4(a) expressly names "use as payment for services" as a disposition for rollforward purposes.

Gas paid on anything else (an own-wallet transfer, a native staking deposit, a failed transaction) has no specific guidance identified. Nor is there a stand-alone gas-fee policy paragraph in any filing reviewed. The treatment has to be inferred from cost-basis wording, from transaction-expense component lists, from an MD&A sentence netting gas against staking revenue, and in one case from a cash-flow line reading "Blockchain network fees (non-cash)".

Custody, presentation, disclosures, and cash flows

SEC Staff Accounting Bulletin 122 rescinded the SAB 121 guidance effective 30 January 2025. It is staff guidance rather than a rule, and its verb says so: entities "should effect" the rescission "on a fully retrospective basis in annual periods beginning after December 15, 2024", with earlier application permitted, so it is not simply a prospective change from the effective date. A safeguarding entity now applies the ordinary contingency guidance (ASC 450-20 or IAS 37), and the rescission does not decide who recognises the ETH. Each party still analyses control and contractual rights. The AICPA's formulation is the useful one, and it opens by conceding exactly that: "It depends. The digital asset should be recognized on the financial statements of the entity that has control over the digital asset."

ASC 230-10-45-27A is mandatory where its conditions are met: crypto in scope of ASC 350-60 "received as noncash consideration in the ordinary course of business … and converted nearly immediately into cash" produces a cash receipt that "shall be classified as operating activities", where nearly immediately means "within hours or a few days, rather than weeks". One registrant told the SEC staff that "[d]uring the nine months ended September 30, 2024, the Company's weighted average turnover of crypto assets held for operations was less than eight days, which the Company believes is consistent with the term 'near immediately.'" Where the conditions are not met, ordinary ASC 230 classification applies and ETH-only activity remains non-cash.

Auditors are testing control of keys, not just balances. Among the registrants examined, existence and rights dominate the critical audit matters written about ETH. The procedures described include obtaining evidence "that management has control of the private keys required to access crypto assets in cold storage through a combination of decoding cryptographic messages signed using selected private keys or through observing the movement of selected crypto assets", and, for a staking entity, confirming "digital assets held in custody and staked". Neither fragment is one firm's signature: both recur as template language across multiple filings. Nor is the pattern universal even inside the examined set. One registrant whose audited note shows 140,008.6 ETH has two critical audit matters and neither is about existence or rights - they are the recognition of digital-asset mining revenue and the valuation and classification of convertible notes, with custody confirmation appearing only as a bullet inside the revenue matter. A valuation critical audit matter appears nowhere in the examined set at all, which is a statement about these filings and not about the market: a full-text search of 2026 annual filings for the phrase "valuation of digital assets" returns thirteen registrants, but in none of the thirteen is that phrase the title of a critical audit matter: it sits variously in a risk factor, an accounting-policy or use-of-estimates heading, an income-statement caption, an internal-control discussion and a procedure bullet, and in the two filings whose auditors do head a matter for the valuation of digital assets, the heading pairs valuation with presentation and disclosure. Four of the thirteen report no critical audit matters at all. Nor is there an audit-firm pattern to read into it: two of the thirteen are signed by a Big Four firm and the rest by smaller practices. One name sits outside this survey and should be flagged: BitMine (BMNR) reported digital assets of $8,281,530 thousand for the year ended 31 August 2025 - on its own unaudited description, the largest ETH treasury in the world - and its lead critical audit matter is titled "Valuation of Digital Assets", the only matter located whose heading is valuation alone. A survey of ETH accounting that does not include it should say so, and this one does. What these filings do support is narrower than "valuation is easy": among them, with a Level 1 price, the question the auditor's reported effort concentrates on is not what the ETH is worth but whether it is the entity's.

One premise worth correcting alongside it, because it is widely assumed and wrong: critical audit matters are not confined to accelerated filers. The Note to PCAOB Auditing Standard 3101.05 exempts brokers and dealers, registered investment companies other than business development companies, "employee stock purchase, savings, and similar plans", and emerging growth companies. Filer status governed only an effective-date phase-in, which expired for fiscal years ending on or after 15 December 2020; the word "accelerated" appears nowhere in the standard. Five of the non-accelerated filers examined here carry critical audit matters, and the one accelerated filer with none has none because it is an emerging growth company.

ASC 740: deferred tax follows tax basis, not fair value

ASC 740 uses the same asset-and-liability approach. ASC 740-10-25-20 defines a temporary difference as one where "a difference between the tax basis of an asset or a liability and its reported amount in the statement of financial position will result in taxable or deductible amounts in some future year(s)."

Under ASC 350-60 the divergence is structural rather than occasional. ETH is marked to fair value through net income every period, while US tax basis stays at cost until a realisation event. Every unrealised gain is a taxable temporary difference and every unrealised loss a deductible one. The deferred tax asset is then subject to the valuation-allowance analysis, and for a loss-making holder that analysis often bites: one ETH treasury company's FY2025 disclosures show gross deferred tax assets of $160.8 million, of which the two crypto lines are $154.7 million ($133.4 million from crypto assets at fair value and $21.3 million from crypto assets at cost) and the balance comes from elsewhere, fully offset by a valuation allowance of the same amount. Uncertain positions are evaluated under the more-likely-than-not threshold: recognition applies "when it is more likely than not, based on the technical merits, that the position will be sustained upon examination", where more likely than not "means a likelihood of more than 50 percent".

No crypto-specific ASC 740 guidance exists: not in ASU 2023-08, not in the AICPA practice aid, not in the major firm guides.

Derecognition needs scope discipline

Ethereum accounting under US GAAP is easy to overread here, because ASC 350-60 is a crypto-specific Subtopic. Its existence does not turn every protocol movement into a prescribed derecognition event.

For each event, first identify whether the entity actually transferred control of the in-scope ETH.

A native staking deposit can move 32 ETH out of an execution-layer address and into consensus-layer validator state without transferring that ETH to a counterparty. A validator withdrawal can later return ETH to an execution address without creating a sale. Slashing can reduce quantity without any sale contract. These facts do not fit neatly into a generic sale narrative.

Where Codification text was written for a contract or a transfer to another party, do not cite it as though it directly addresses a protocol event with no counterparty. If the conclusion is interpretive, label it as interpretive.

The FASB's current crypto-transfer project itself demonstrates that derecognition questions remain live. It does not give preparers permission to anticipate a future standard.

Cost-basis disclosure is not the tax-basis ledger

ASC 350-60 requires disclosures involving cost basis and realized gains and losses. That book cost information is not automatically the same as federal tax basis. Ethereum accounting under US GAAP and the federal tax ledger are separate records.

US federal tax rules now use wallet-or-account-specific basis tracking for covered post-2024 digital-asset rules, with specific-identification requirements and a FIFO fallback when adequate identification is not made. Those rules are tax rules, not ASC 350-60 measurement rules.

Maintain separate fields for:

  • protocol quantity;
  • US GAAP carrying amount at fair value;
  • book cost history needed for disclosures;
  • federal tax basis;
  • any state or other jurisdictional tax basis where different.

The tax article explains the current US rules in full: Ethereum Tax in the United States.

US GAAP close checklist

Twelve steps close Ethereum accounting under US GAAP for a reporting period.

  1. Reperform the six-part ASC 350-60 scope test for the asset actually held.
  2. Confirm that wrapped, bridged, receipt, or custodial positions have not been mislabeled as native ETH.
  3. Reconcile exact quantity before valuation.
  4. Identify the principal market under ASC 820.
  5. Measure in-scope ETH at fair value with changes in net income.
  6. Treat transaction-cost conclusions as interpretive where the Codification does not prescribe them.
  7. Analyze native staking control separately from reward recognition.
  8. Document the staking revenue or other-income model and principal-agent conclusion.
  9. Assess restrictions and required disclosures.
  10. Prepare the required cryptoasset rollforward and realized-gain/loss information.
  11. Apply the cash-flow requirements, including the specific nearly-immediate-conversion rule where applicable.
  12. Compute ASC 740 from jurisdictional tax basis, not from book cost or fair value.

US GAAP analysis for native ETH

Start by proving whether the asset satisfies every ASC 350-60 scope criterion.

  1. Scope testIs native ETH in scope?
  2. Initial recognitionWhat event created it?
  3. ASC 820 fair valueObservable fair value
  4. Net-income remeasurementEach reporting period
  5. Derecognition and disclosureApply relevant transfer guidance
ASC 350-60 does not answer every transaction, transfer, staking, or gas question. Other GAAP and judgement can still be required.

For the mechanics behind the accounting, see Ethereum Staking Rewards. For fee mechanics, see Ethereum Gas Fee Accounting.

How Tokenbooks helps with Ethereum under US GAAP

US GAAP under ASC 350-60 is one of four functional reporting frameworks, alongside tax only and two IAS 2 dealer-inventory presets, and the choice is a per-portfolio setting. Fair-value remeasurement runs at period close. It posts to an adjunct asset account against unrealised gain or loss and leaves the cost-basis lots untouched, which keeps the fair-value carrying amount and the book cost history apart. Journal entries post against an editable hierarchical chart of accounts with a general ledger view, and the reports include balance sheet, profit and loss, income and expenses, capital gains and losses, and trial balance, exported to Excel or JSON.

See the Ethereum integration page.

More in this series

Accounting Token Anatomy: Native ETH. This article stands alone, but the series builds in order.

Previous (01.2.8): Ethereum Staking Rewards: Recognition, Measurement, and Revenue

Next (01.2.11): Ethereum Journal Entries: A Complete Worked Example

All fourteen articles

Sources and authority map

  • FASB ASU 2023-08 (ASC 350-60 and ASC 230-10-45-27A). storage.fasb.org
  • FASB ASU 2011-04 (ASC 820), ASU 2016-12 (ASC 606 non-cash consideration), ASU 2009-01 (ASC 105). 820
  • FASB technical agenda and the crypto-transfers project page. agenda
  • SEC Staff Accounting Bulletin 122. sec.gov
  • AICPA, "Accounting for and auditing of digital assets" practice aid. aicpa-cima.com
  • KPMG, "Crypto assets" handbook, April 2026, and "Accounting for staking activities", April 2026. handbook
  • PwC, "Crypto assets guide", August 2025, and EY Technical Line, updated 28 March 2025. PwC
  • Sharplink, Inc., Form 10-K for FY2025. sec.gov
  • BTCS Inc., Form 10-K for FY2025. sec.gov
  • Bit Digital, Inc., ETHZilla Corporation (now Forum Markets Inc) and BitMine Immersion Technologies, Inc., Forms 10-K. Bit Digital 10-K
  • SEC staff comment letters and registrant responses on crypto accounting. comment letter to Coinbase, 18 October 2024
  • Exchange-traded-product filings on staking and on slashing. ETHE 10-K

Research status. Protocol mechanics and published guidance were refreshed through 31 August 2026. Where a source is interpretive rather than authoritative, the text says so. This article is educational research, not accounting, tax, legal, valuation, or investment advice.

Frequently Asked Questions

Is native ETH in the scope of ASC 350-60?
On this article's own application of the six criteria in ASC 350-60-15-1, yes, and that is worth stating plainly because no authoritative source located names ether. KPMG's April 2026 handbook says crypto assets like BTC, ETH and SOL do not grant enforceable rights to their holder for any other goods, services or underlying assets, and every operating-company registrant examined applies ASC 350-60 to its ETH.
Does ASC 350-60 tell you how to record ETH when it first arrives?
No. ASC 350-60-05-2 states that the Subtopic does not address the initial measurement, recognition, and derecognition of crypto assets, and sends the entity to other GAAP. Initial measurement runs through ASC 350-30-15-4(e) into ASC 350-30-30-1 and then ASC 805-50-30-1, while ETH received from a customer runs through ASC 606, which measures noncash consideration at contract inception.
How are Ethereum staking rewards recognised under US GAAP?
There is no explicit model. KPMG's April 2026 hot topic states that there is currently no explicit US GAAP that directly addresses the accounting for crypto intangible asset staking, the AICPA practice aid edition checked here has no staking question and answer at all, and the FASB has no project on staking. Among nine SEC registrants examined, eight stake, and among those eight there are seven different positions on when a reward is recognised and how it is measured.
Is gas paid to acquire ETH capitalised?
This article reads the codified chain that way, and labels it as its own reading rather than an answer ASC 350-60 gives. The Subtopic does not address transaction costs, and BC36 records that the Board decided not to provide guidance on how to recognize or present transaction costs to acquire crypto assets. KPMG treats gas fees as transaction costs capitalised into initial measurement, and notes that they will generally be immediately written off at the first remeasurement.
Does staking ETH natively derecognise it?
There is no authoritative guidance, but practice and interpretation are aligned. KPMG says that in general staked tokens are not derecognized by the staking entity because no other entity obtains the right or ability to direct their use, and a registrant staking large amounts of ETH says its native staked ETH are not derecognized because the deposit into the smart contract does not give any other entity that right or ability.

Related articles

This is not tax, legal, or accounting advice.
Tokenbooks builds accounting software; we are not a CPA firm and not a tax adviser. Treatment varies by jurisdiction, by entity, and over time, and the rules described here can change after publication. Confirm any position with your own accountant or tax adviser before you rely on it.