FASB Flags Crypto Assets as an Emerging Project in Q2 2026: What Accounting Firms and CFOs Must Assess Now
FASB's standard-setting calendar moved quickly in the second quarter of 2026, and crypto assets sit squarely on the agenda. A quarterly financial reporting update published by Forvis Mazars on 31 July 2026 identifies digital assets and crypto assets among the board's active emerging projects, alongside a cluster of exposure drafts covering fair value measurement and hedge accounting. For accounting firms advising corporate clients and for CFOs whose balance sheets carry any form of digital asset, the direction of travel is clear: US GAAP treatment of crypto is under active review, and preparation needs to start before final standards land.
What FASB Signalled in Q2 2026
The Forvis Mazars update characterises Q2 2026 as a period of significantly increased FASB standard-setting activity. The board advanced work across several fronts simultaneously, with two broad categories directly relevant to digital asset holders and their advisers.
Finalised and Proposed Standards
On the standards side, FASB issued Accounting Standards Updates covering paid-in-kind dividends on equity-classified preferred stock and environmental credits. It also released exposure drafts on three targeted topics: the discount rate applied in measuring benefit obligations under pension plans, targeted improvements to hedge accounting, and targeted improvements to the fair value measurement of equity securities subject to contractual sale restrictions.
The hedge accounting and fair value exposure drafts are particularly worth tracking for digital asset portfolios. Any refinement to how fair value is measured for equity securities with contractual restrictions could have read-across implications for certain token structures, especially where lock-up arrangements or vesting schedules restrict immediate sale. Firms should monitor the comment process closely and assess whether client holdings fall within the scope of the proposed changes.
Emerging Projects: Crypto Assets and Digital Assets on the Active List
The update explicitly lists digital assets and crypto assets as active emerging projects on FASB's agenda. Other items on the emerging projects list include debt classification, equity method accounting, and private credit disclosures, placing crypto alongside some of the more consequential open questions in US GAAP reporting.
FASB adopted ASC 350-60 in late 2023, requiring fair value measurement for certain crypto assets with gains and losses recognised in net income each period. That was a significant departure from the previous indefinite-lived intangible asset model. The fact that crypto assets remain on the emerging projects list suggests the board is not done. Whether that means scope expansion, further definitional clarity, or guidance on more complex structures such as staking, lending, or tokenised securities remains to be seen. What is clear is that the accounting treatment for digital assets in US GAAP continues to evolve.
Why the Timing Matters for Financial Statements
Corporate adoption of digital assets has accelerated. Treasury teams at publicly traded companies now hold bitcoin and other cryptocurrencies as part of their capital allocation strategies. Privately held businesses and investment funds have followed. The financial statement implications range from balance sheet classification and measurement to income statement volatility and disclosure. With FASB actively reviewing the space, any new guidance could affect comparative periods, require retrospective application, or demand new disclosures that need systems and processes in place well before effective dates.
The ASC 350-60 Baseline and Its Gaps
ASC 350-60 settled the measurement question for in-scope crypto assets: fair value through net income, with disclosure of fair value levels, units held, and cost basis. But the standard has defined scope boundaries. Assets that do not meet the definition of a crypto asset under ASC 350-60, including certain non-fungible tokens, tokenised real-world assets, and digital securities, remain outside the rule and default to older guidance that can produce significantly different accounting outcomes.
The emerging projects designation signals that FASB is aware of these gaps. Accounting firms advising clients with diverse digital asset portfolios need to document the basis for each classification decision now. If future guidance shifts the boundary, well-documented contemporaneous analysis will be essential for auditors and for management to demonstrate that prior period accounting was reasonable.
Fair Value Measurement Complexity
The exposure draft on fair value measurement of equity securities subject to contractual sale restrictions has potential implications beyond traditional equity. Some digital assets, particularly those issued under simple agreements for future tokens or structured token purchase agreements, carry lock-up or vesting provisions that restrict transferability. The question of whether and how such restrictions affect fair value measurement is live under existing guidance. A final standard clarifying the treatment of contractual restrictions could resolve that ambiguity, or create new classification questions, depending on its final scope.
CFOs and their audit teams should flag any digital asset holdings with contractual transfer restrictions and assess them against both current guidance and the proposed changes as the exposure draft process concludes.
IFRS Considerations for Cross-Border Entities
The Forvis Mazars update focuses on US developments, but many US-headquartered groups have subsidiaries reporting under IFRS, and many foreign private issuers filing with the SEC apply IFRS as issued by the IASB. The IFRS treatment of crypto assets remains unsettled at the standard level. IAS 38 (intangible assets) and IAS 2 (inventories) have historically been applied by analogy, with the specific accounting depending on how an entity holds or uses the asset. The IASB has an active agenda project on crypto assets and digital assets that is developing dedicated guidance, but no final standard has been issued.
This creates a divergence risk for groups that report under both frameworks. A US subsidiary applying ASC 350-60 will record fair value gains and losses through net income. A foreign subsidiary under IFRS applying IAS 38 with the cost model will not. Consolidation adjustments, deferred tax implications, and segment reporting disclosures all become more complex when the measurement bases differ. For multinational groups, aligning internal reporting policies and building reconciliation workflows now is considerably less painful than retrofitting them after a standard takes effect.
Accounting and Disclosure Implications for Firms and CFOs
The Q2 2026 signals from FASB carry concrete action items for both advisory firms and in-house finance functions.
For Accounting Firms and Auditors
Client portfolios that include digital assets need to be reviewed at the engagement level. The key questions are: which assets are in scope under ASC 350-60, which fall outside it, and what basis has management used for classification? Audit teams should be testing fair value hierarchies, reviewing the adequacy of price sources, and ensuring that disclosure requirements under ASC 350-60 have been fully met in the most recent financial statements.
Emerging project status at FASB also means that comment periods will open. Firms with deep client exposure to digital assets have both an opportunity and a professional obligation to engage with the standard-setting process, either directly or through professional bodies such as the AICPA. Influencing the scope and transition provisions of future standards is far more efficient than managing client disruption after the fact.
The AICPA Engage 2026 conference, highlighted in the Forvis Mazars update, focused heavily on the growing role of artificial intelligence and automation in financial reporting. For digital asset practices specifically, this is relevant: the volume and complexity of on-chain transaction data makes manual reconciliation impractical at scale. Firms building or advising clients on digital asset accounting workflows should factor automation capacity into their service models now, not after client demand forces the issue. Our article on Going Public as a Digital Asset Company: Six Factors CFOs and Auditors Must Address covers several of the preparation steps that apply equally to private companies anticipating regulatory change.
For CFOs and Finance Teams
If your organisation holds any form of digital asset, the accounting policy note in your financial statements needs to be both technically accurate under current guidance and flexible enough to accommodate change. A rigid policy written narrowly around the existing ASC 350-60 scope may require amendment when FASB finalises further guidance. Work with your auditors and legal counsel to draft policy language that acknowledges the evolving nature of the standards and commits to reassessment as new guidance is issued.
Tax provisioning is a second pressure point. ASC 350-60 creates income statement volatility through unrealised fair value gains and losses. Those movements feed into the deferred tax calculation. Finance teams need to confirm that their tax provision models are capturing fair value movements correctly and that temporary differences are being tracked at the asset level. This is particularly important for entities in tax jurisdictions that do not tax unrealised gains, creating a timing difference that must be reflected in the deferred tax asset or liability.
Internal controls over financial reporting also need attention. The measurement of crypto assets at fair value requires documented price sourcing procedures, controls over the selection and validation of pricing inputs, and clear escalation paths when markets are thin or prices diverge across exchanges. If these controls are not already formalised, they should be, before the next audit cycle.
For a broader view of how regulatory developments across multiple jurisdictions are reshaping digital asset compliance requirements, see our coverage of the Global Crypto Regulation: Compliance and Enforcement Outlook for Accounting Firms and CFOs.
What to Watch in the Second Half of 2026
FASB's emerging projects list does not carry fixed timelines, but the board's elevated activity level in Q2 suggests momentum. Key milestones to track include: any discussion papers or exposure drafts specifically addressing digital assets beyond the current ASC 350-60 scope, the finalisation of the fair value measurement exposure draft and its implications for restricted token holdings, and updates from the IASB on its parallel crypto assets project.
Firms and CFOs should also watch for SEC staff guidance or comment letter themes related to digital asset disclosures. SEC staff have historically used comment letters to shape disclosure practice ahead of formal rulemaking, and digital asset disclosures in public company filings remain an area of active staff focus.
Early engagement with these developments, whether through monitoring, comment letter participation, or internal policy review, is the most effective way to manage the transition risk that comes with evolving standards.
Frequently Asked Questions
What does ASC 350-60 currently require for crypto assets?
ASC 350-60 requires entities to measure in-scope crypto assets at fair value at each reporting date, with changes in fair value recognised in net income. The standard also requires specific disclosures covering fair value, units held, and cost basis. It applies to a defined category of crypto assets and does not cover all digital assets.
Why does FASB still list crypto assets as an emerging project if ASC 350-60 is already in place?
ASC 350-60 resolved the measurement question for a specific category of assets, but significant gaps remain. Assets outside that definition, including certain NFTs, tokenised securities, and digital assets used in lending or staking arrangements, do not have dedicated guidance. The emerging project designation indicates FASB is actively considering whether and how to address those gaps.
How does the IFRS treatment of crypto assets differ from US GAAP?
Under IFRS, there is currently no dedicated standard for crypto assets. Entities typically apply IAS 38 (intangible assets) or IAS 2 (inventories) by analogy. This can result in a cost model with impairment-only write-downs, which differs materially from the fair value through net income model under ASC 350-60. The IASB has an active project to develop dedicated guidance, but no final standard has been issued.
What should CFOs do if digital asset holdings include tokens with contractual transfer restrictions?
CFOs should document the nature and terms of any restrictions, assess whether they affect the fair value measurement under current guidance, and monitor the FASB exposure draft on fair value measurement of equity securities subject to contractual sale restrictions. Legal counsel should review the token agreements to establish whether the restrictions are contractual or regulatory in nature, as that distinction may affect the accounting analysis.
How should accounting firms respond to FASB's active standard-setting on digital assets?
Firms should review client digital asset portfolios for classification accuracy under current guidance, ensure disclosure requirements are being met, and consider participating in the comment process when FASB publishes exposure drafts on digital assets. Building internal technical expertise and scalable digital asset accounting workflows now will position firms to advise clients effectively as further guidance is finalised.
Source: Forvis Mazars