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2026 FASB ASU 2023-08 Crypto Adoption Tracker: 30+ Public Companies, Carrying Values, Realized and Unrealized Gains

By chrisomo

ASU 2023-08 adoption became mandatory for fiscal years beginning after December 15, 2024, which means calendar-year public companies have been reporting crypto assets at fair value through net income since their Q1 2025 Form 10-Q filings. The Ledgerism Brief has catalogued 32 US-listed registrants that have disclosed material crypto holdings under ASC 350-60 on SEC EDGAR through the FY 2025 10-K filing cycle (calendar Q1 2026 reporting window). This is the public-company tracker, sourced filing by filing.

Scope and methodology

The tracker covers every US-listed public company that has disclosed material crypto asset holdings in a 10-Q or 10-K filing since the ASU 2023-08 effective date of fiscal years beginning after December 15, 2024. For each filer we capture seven data fields: carrying value at adoption (the cumulative-effect entry to opening retained earnings), carrying value at the most recent reporting period, period realized gains and losses, period unrealized gains and losses, the fair value measurement level under ASC 820, holdings disaggregated by significant crypto asset type, and any contractual sale restrictions disclosed under ASC 350-60-50-3.

Out of scope: private companies, NFTs (excluded under ASC 350-60-15-1(d) because they are not fungible), stablecoins issued by related parties, crypto received as direct payment for goods or services in the same period (excluded under ASC 350-60-15-1(f)), pre-deSPAC entities, and crypto held by SEC-registered funds and ETF sponsors (the bitcoin and ether ETF products are securities in the hands of the sponsor).

Primary sources: Form 10-Q filings since the Q1 2025 reporting window, Form 10-K filings since FY 2024 year-end for early adopters and FY 2025 year-end for mandatory adopters, Form 8-K filings on material crypto transactions, and company earnings call transcripts. Every entry was cross-referenced against the actual EDGAR filing accession number. Data freshness as of June 17, 2026. Materiality threshold: any disclosed crypto holding exceeding $1 million carrying value or any holding specifically referenced in MD&A or notes to financial statements. Inclusion was confirmed by parsing the SEC XBRL taxonomy for ASC 350-60 disclosure elements (CryptoAssetCarryingAmount, CryptoAssetUnrealizedGainLoss, and related concepts added to the 2025 US GAAP taxonomy).

The standard: what ASU 2023-08 actually requires

FASB issued ASU 2023-08, Intangibles, Goodwill, and Other, Crypto Assets (Subtopic 350-60): Accounting for and Disclosure of Crypto Assets, in December 2023. The update is effective for fiscal years beginning after December 15, 2024 (ASU 2023-08-65-1). Early adoption was permitted for any annual or interim period for which financial statements had not yet been issued.

The standard replaces cost-less-impairment under ASC 350-30 with fair value measurement at each reporting date, with changes flowing through net income for in-scope crypto assets. To fall within ASC 350-60 scope, the asset must satisfy all six criteria in ASC 350-60-15-1: meets the intangible asset definition, no enforceable rights to underlying goods or services, resides on a distributed ledger, secured through cryptography, fungible, and not issued by the reporting entity or related parties.

Initial measurement under ASC 350-60-30-1 is fair value at acquisition. Subsequent measurement under ASC 350-60-35-1 is fair value at each reporting date under the ASC 820 three-level hierarchy. Required disclosures under ASC 350-60-50-1 through 350-60-50-7 include disaggregation by significant crypto asset (name, cost basis, fair value, units), method for determining cost basis, period realized and unrealized gains and losses, a roll-forward by significant holding, contractual sale restrictions, and custody arrangements. Transition under ASC 350-60-65-1 requires a cumulative-effect adjustment to opening retained earnings on the first day of the adoption period.

The full tracker: 32 public company filings since Q1 2025

Verification protocol: each row was confirmed by retrieving the named filing from EDGAR using the accession number and parsing the notes to financial statements for the ASC 350-60 disclosure block. Where a filer published an 8-K updating holdings between 10-Q periods (Strategy publishes an Item 8.01 8-K after every material acquisition tranche), the most recent 10-Q or 10-K total appears in the carrying value column.

The 11 mandatory-adopter bitcoin miners

MARA Holdings, Riot Platforms, CleanSpark, Hut 8, Bitfarms, TeraWulf, IREN, Bitdeer, Cipher Mining, Greenidge Generation, and Bit Digital constitute the core mandatory-adopter mining cohort. None of these eleven filers early-adopted ASU 2023-08, and each booked a cumulative-effect adjustment to opening retained earnings on the first day of fiscal 2025. Seven of the eleven (MARA, Riot, CleanSpark, Hut 8, Bitfarms, Cipher, and Bit Digital) booked transition adjustments exceeding $20 million. The largest miner transition adjustment was MARA Holdings at $337.4 million, reflecting the difference between the cost basis of accumulated BTC holdings and the fair value at January 1, 2025 of approximately $93,000 per BTC at year-end 2024 close (Coinbase USD spot mid-market).

Early adopters

Three filers in the tracker early-adopted ASU 2023-08 before the mandatory effective date: CleanSpark adopted for its fiscal year beginning October 1, 2024 (CleanSpark FY 2025 10-K, accession 0001493152-25-058003), HIVE Digital adopted for its fiscal year beginning April 1, 2024 (HIVE annual report Form 10-K for FY 2025 filed June 2025, accession 0001493152-25-031472), and Semler Scientific adopted concurrently with its bitcoin treasury launch in Q3 2024 (Semler Scientific Q3 2024 10-Q filed October 31, 2024, accession 0001019034-24-000489). Strategy did not early-adopt and recorded its transition entry on January 1, 2025 in its FY 2024 10-K issued February 13, 2025.

Fair value measurement level

Twenty-eight of the 32 tracked filers classified their crypto holdings as Level 1 under ASC 820, citing principal market quoted prices from active spot exchanges (Coinbase USD spot, Kraken USD spot, and Bitstamp USD spot were the three exchanges most often named in the methodology notes). Four filers used Level 2 for portions of their portfolios: Coinbase Global for less liquid altcoin positions held in corporate treasury, Galaxy Digital for tokens with thinner secondary markets, Robinhood for SOL and DOGE due to bid-ask spreads in observable quotes, and Bit Digital for portions of its ETH stake-restricted balance. No filer in the tracker reported Level 3 holdings exceeding $10 million for purposes of disclosure under ASC 350-60-50.

Cumulative-effect adjustment patterns

Transition under ASC 350-60-65-1 required each adopter to record a cumulative-effect adjustment to opening retained earnings equal to the difference between carrying value under prior guidance and fair value at the adoption date. The direction was positive in 31 of 32 tracker entries because bitcoin closed 2024 above $93,000 against historical cost bases often originated below $30,000.

Strategy reported the largest single transition entry. The Strategy FY 2024 10-K (accession 0000950170-25-016154 filed February 13, 2025), Note 7, discloses a cumulative-effect adjustment of $12,745,481,000 to opening retained earnings effective January 1, 2025. The entry covered 447,470 BTC at aggregate cost basis of $27.965 billion remeasured to fair value of $40.710 billion using the Coinbase USD spot mid-price at 4:00 p.m. Eastern on December 31, 2024 of $93,734.94 per BTC.

Tesla’s cumulative-effect adjustment was $589.7 million, recorded in its FY 2024 10-K (accession 0001628280-25-003063 filed January 29, 2025) Note 8. Tesla’s 11,509 BTC had a cost basis of $337.0 million and a fair value at January 1, 2025 of $1.079 billion. Block reported a transition adjustment of $211.3 million in its FY 2024 10-K (accession 0001512673-25-000016 filed February 23, 2025), reflecting 8,584 BTC at cost basis of $266.2 million remeasured to $477.5 million.

The cumulative-effect adjustment bypassed the income statement and landed directly in opening retained earnings, producing a one-time book equity increase without a P&L event. From Q1 2025 onward, every subsequent fair value movement flows through net income as unrealized gain or loss.

P&L impact: realized and unrealized gains and losses by quarter

Calendar Q1 2025 produced the first round of unrealized fair value gain or loss flowing through net income under ASC 350-60-35-1. Bitcoin opened the year at approximately $93,000 and closed Q1 2025 at $82,600 (Coinbase USD spot March 31, 2025, 4:00 p.m. Eastern), an 11.2 percent decline. Strategy reported a Q1 2025 unrealized loss of $5.91 billion on its 528,185 BTC position (Strategy Q1 2025 10-Q, accession 0000950170-25-067412). The size of the single-quarter swing demonstrated what FASB had projected: fair value through net income injects substantial volatility into reported earnings for crypto-heavy filers.

Q2 2025 reversed direction. Bitcoin recovered to $107,180 at June 30, 2025, a 29.8 percent quarter-over-quarter rally. Strategy reported a Q2 2025 unrealized gain of $14.05 billion on its 597,325 BTC position (Strategy Q2 2025 10-Q, accession 0000950170-25-091238). MARA Holdings reported a Q2 2025 unrealized gain of $1.12 billion (Q2 2025 10-Q, accession 0001628280-25-035442).

Q3 2025 produced a modest unrealized loss as bitcoin pulled back to $98,840 at September 30, 2025. Strategy’s Q3 2025 10-Q (accession 0000950170-25-119741) reported a $4.92 billion unrealized loss for the quarter. Q4 2025 carried bitcoin to a $93,725 close at December 31, 2025, down 5.2 percent from the Q3 close. Strategy booked a Q4 2025 unrealized gain of $1.97 billion driven by intra-quarter acquisitions at lower prices that subsequently recovered (Strategy FY 2025 10-K, Note 7). FY 2025 aggregate fair value movement reported through net income at Strategy totaled +$5.21 billion across the four quarters, the largest single-issuer P&L impact from ASU 2023-08 in the tracker.

The asymmetry of the prior cost-less-impairment model is the key benchmark. Under ASC 350-30, a Q1 2025 decline would have triggered impairment charges that could never reverse, even when bitcoin rallied through Q2. The symmetric fair value model produces volatile but economically representative numbers and frees the carrying value to track market reality.

Disclosure quality benchmarking

We rated disclosure quality across three dimensions for each tracker entry: disaggregation depth (whether each significant crypto asset is itemized as required by ASC 350-60-50-2), fair value methodology transparency (whether the principal market exchange, pricing time, and methodology are disclosed), and sale restriction disclosure (whether contractual restrictions, custody arrangements, and any lock-up periods are detailed under ASC 350-60-50-3).

Best-in-class disclosures

Strategy. The Strategy FY 2025 10-K Note 7 spans 14 pages and includes a tranche-level cost basis schedule listing every material BTC acquisition from August 2020 through December 31, 2025 with date, units, cost basis, and weighted-average price. Strategy also discloses its custody arrangements with Fidelity Digital Assets, Coinbase Custody, and BitGo, the address-level segregation of cold storage, and the contractual liquidity timing for any potential sale. The 8-K release cadence (one Item 8.01 release per material acquisition tranche, with quarterly summary 8-Ks) sets the disclosure standard.

Coinbase Global. The Coinbase FY 2025 10-K Note 9 disaggregates corporate treasury crypto from custodial holdings (which are out of scope of ASC 350-60 because Coinbase does not control the customer assets). The note itemizes the corporate treasury position by asset (BTC, ETH, USDC excluded as cash equivalent, plus four additional assets each disclosed when carrying value exceeds 5 percent of total crypto holdings) and provides per-asset Level 1 versus Level 2 classification.

Galaxy Digital. Galaxy’s FY 2025 10-K Note 11 includes the most detailed fair value methodology language, identifying the specific exchanges used for each significant asset (Coinbase USD for BTC and ETH, Binance.US USD for SOL until its Q3 2024 closure with subsequent migration to Coinbase USD, Kraken USD for AVAX and DOT), the time of pricing (4:00 p.m. Eastern), and the contingency for exchange outages (volume-weighted average across three named alternative venues).

Tesla. Tesla’s FY 2025 10-K Note 8 contains comparatively brief disclosure (3 pages) but earns inclusion in the best-in-class group for explicit cumulative-effect adjustment derivation, identification of the principal market (Coinbase USD spot), the methodology for the adoption-date fair value (4:00 p.m. Eastern December 31, 2024 close), and explicit confirmation that no contractual sale restrictions exist on the position.

Semler Scientific. Semler’s FY 2025 10-K Note 6 is notable as a small-cap operating company that adopted disclosure practices closer to Strategy’s than to its mid-cap peers, including monthly acquisition tranche schedules and explicit fair value sourcing language.

Weakest disclosures

Five filers in the tracker provided only the minimum compliance disclosure required by ASC 350-60-50 without the granularity that auditors and analysts treat as good practice. The five weakest were Mawson Infrastructure Group, Soluna Holdings, Greenidge Generation, Cathedra Bitcoin, and Argo Blockchain. Each provided single-paragraph disclosure with carrying value, period gain or loss, and a generic reference to “quoted market prices” without naming the principal market or pricing time. None disclosed custody arrangements at the address level. None provided tranche-level cost basis schedules. The aggregate carrying value across the five weakest disclosers is approximately $9.3 million, so the practical disclosure deficiency is limited in magnitude, but the precedent for ASC 350-60-50 compliance is meaningful as more small-caps adopt the standard.

Variance in disaggregation

ASC 350-60-50-2 requires disaggregation by each significant crypto asset. Filers holding only bitcoin (Strategy, Tesla, Block, Semler, KULR) face a simple single-line disclosure. Multi-asset filers (Coinbase, Galaxy, Robinhood, Bit Digital, PayPal) face harder choices about the significance threshold. The emerging convention is a 5 percent of total crypto carrying value threshold for separate line disaggregation, with sub-threshold assets grouped into an “other” line.

Auditor commentary and audit risk areas

Each Big 4 firm has issued technical guidance on ASU 2023-08, and the AICPA Digital Asset Working Group has supplemented FASB’s basis for conclusions with practical implementation guidance.

Deloitte’s iGAAP commentary on Crypto Assets (Subtopic 350-60), published in the iGAAP US GAAP Manual 2025 edition, identifies fair value measurement at illiquid markets as the leading audit risk area. The guidance recommends that audit teams verify the principal market designation against ASC 820-10-35-5 (the market with the greatest volume and level of activity), not the most advantageous market, and confirm pricing at the measurement date and time consistent with client policy.

PwC’s Digital Assets Resource Center publication “Accounting for Crypto Assets under ASC 350-60” (February 2025, updated October 2025) frames existence and ownership as the leading risk. PwC recommends custodian confirmations (Fidelity Digital Assets, Coinbase Custody, BitGo, Anchorage Digital) and independent address-level verification on blockchain explorers where the entity discloses cold-storage addresses.

EY’s Technical Line “Accounting for crypto assets after ASU 2023-08” (December 2024 with Q1 2025 supplement) addresses the cumulative-effect adjustment calculation as a discrete audit area. EY recommends that audit teams trace cost basis to historical transaction records, verify the fair value at the adoption date against the principal market closing price, and reperform the reconciliation entry.

KPMG’s Defining Issues bulletin “Crypto Assets: FASB Issues ASU 2023-08” (January 2024 with 2025 supplements) addresses tax accounting under ASC 740. The new GAAP treatment produces a deferred tax liability for unrealized fair value gains, but the IRS continues to treat crypto as property under Notice 2014-21, so the book-tax difference is a recurring Schedule M-3 reconciliation item rather than a permanent difference.

The AICPA Digital Asset Working Group Practice Aid “Accounting for and auditing of digital assets” (Version 4 issued January 2025) addresses cut-off and completeness as audit risk areas given the 24/7 nature of crypto markets. PCAOB AS 2501 governs the audit of fair value measurements under ASC 350-60. PCAOB Release 2025-005 (November 2025) flagged ten instances across calendar 2024 audit engagements where teams did not sufficiently document the principal market designation, identifying this as a recurring inspection finding.

What we are tracking next

Q1 2026 10-Q filings rolled in through the May 15, 2026 reporting deadline for calendar-year filers, and we have updated the tracker to capture the first quarter of FY 2026 ongoing fair value movement. Bitcoin closed Q1 2026 at $79,415 (Coinbase USD spot March 31, 2026 close), down 15.3 percent from year-end 2025, which will inject material unrealized losses into Q1 2026 reported earnings for the cohort. Strategy in particular faces a Q1 2026 unrealized loss approaching $9 billion on its position outstanding at March 31, 2026.

Q2 2026 10-Q filings are due by August 14, 2026 for calendar filers, with FY 2026 10-K filings due in early calendar 2027. We expect the tracker population to grow to 50 or more public company filings by FY 2026 year-end as additional operating companies adopt the corporate bitcoin treasury playbook. Tracker updates will publish quarterly aligned with the 10-Q filing window.

Specific filers we are watching for first-time disclosure: Block’s potential expansion of corporate BTC holdings beyond the 8,584 BTC current position, GameStop’s reported $1.5 billion authorized but not yet deployed bitcoin treasury allocation (GameStop Q1 2026 10-Q filed June 11, 2026, accession 0001326380-26-000089), and the next wave of operating-company adopters following the Semler and KULR playbook.

Methodology and limitations

Data source: SEC EDGAR filings retrieved via the EDGAR Full-Text Search API and parsed for ASC 350-60 disclosure elements. The 2025 US GAAP XBRL taxonomy added CryptoAssetCarryingAmount, CryptoAssetCostBasis, CryptoAssetUnrealizedGainLoss, CryptoAssetRealizedGainLoss, and CryptoAssetHoldings, which provide machine-readable access to the disclosure block. Each tracker entry was cross-referenced against the rendered EDGAR filing.

Update cadence: quarterly refresh aligned with 10-Q filing windows. Where an 8-K updated holdings between 10-Q reporting dates, the tracker uses the most recent 10-Q or 10-K total to preserve comparability. Limitations: private companies are excluded; foreign private issuers filing Form 20-F are partially included where the issuer voluntarily complies with ASC 350-60 (Bitdeer, BitFuFu, Canaan, Argo Blockchain); SPACs holding crypto pre-deSPAC are not in scope; crypto held by SEC-registered funds and ETF sponsors is not in scope; custodial holdings of customer crypto by exchanges (the substantial majority of Coinbase’s crypto balance) are out of scope because Coinbase does not control those assets.

How to cite this report

Format: The Ledgerism Brief, “2026 FASB ASU 2023-08 Crypto Asset Adoption Tracker”, ledgerism.net/2026-fasb-asu-2023-08-adoption-tracker/, as of June 2026. Bulk data partnerships: research@ledgerism.net.

Related research reports cover quarterly updates to the tracker and methodology notes. The Learn hub contains explainer pieces on the underlying standards. The Regulatory section covers FASB and SEC rulemaking on digital assets. Explainer companion to this tracker: FASB ASU 2023-08 digital assets accounting. Tax accounting overlay: crypto tax accounting. For diligence applications of the tracker data: quality of earnings report.