Crypto Accounting for Estonian Companies
A complete bookkeeping setup guide for Estonian OÜs holding or trading crypto assets — chart of accounts, IAS 38 measurement under cost and revaluation models, impairment testing, journal entries for every transaction type, and the monthly close process.
5 Key Takeaways From This Page
Choosing IAS 38 or IAS 2, selecting FIFO or weighted average, and deciding on cost model vs revaluation model are policy elections — not transaction-by-transaction choices. Document them before you acquire your first crypto asset and apply them consistently.
Under the IAS 38 revaluation model, increases in fair value are recognised in Other Comprehensive Income (a separate equity reserve), not in profit or loss. This prevents crypto price swings from inflating or deflating your reported EBITDA — only realised gains on disposal flow through the P &L.
Under the IAS 38 cost model, if the market price of your crypto falls below its carrying value, you must test for impairment and write down to recoverable amount. Unlike the revaluation model, write-downs under the cost model go through the P &L — making cost model accounting more volatile in bear markets.
Crypto accounting starts with complete wallet mapping. Every address controlled by the OÜ — hot wallets, cold storage, exchange sub-accounts, DeFi protocol positions — must be identified and included in the accounting universe. Any unmapped wallet creates an incomplete record.
Each crypto transaction must be converted to EUR at the rate prevailing at the moment of the transaction — not at month-end, not at year-end, not at an average rate. This is both an IFRS requirement and an EMTA requirement for tax purposes.
What does crypto accounting involve for an Estonian OÜ? At its core, crypto accounting for a company is the same double-entry bookkeeping as any other asset class — but with three specific challenges: (1) no established IFRS standard requires a policy election between IAS 38 intangible asset and IAS 2 inventory; (2) price volatility creates complex fair value and impairment entries every month-end; and (3) the transaction volume and data sourcing challenges are unlike any traditional business. This page sets up the full accounting framework — from chart of accounts to monthly close — for an Estonian OÜ with crypto assets.
Section 1 — Chart of Accounts for a Crypto OÜ
The complete account structure for digital asset holdings, trading, mining, and DeFi activity
Building a Crypto-Ready Chart of Accounts
A standard Estonian OÜ chart of accounts needs significant extension to handle crypto assets. The additions fall into four areas: asset accounts for each crypto holding type (by classification and by asset), contra-accounts for accumulated revaluation and impairment, income accounts for crypto-specific revenue streams (mining, staking, DeFi yields, trading gains), and expense accounts for mining costs, gas fees, and trading costs.
| Code | Account Name | Notes / When Used |
|---|---|---|
| 1050 | Cash — Crypto Exchange Balances (EUR-equivalent) | EUR held on exchange awaiting deployment; treat as cash equivalent |
| 1100 | Crypto Assets — Bitcoin (BTC) | IAS 38 intangible; cost or revaluation model per policy |
| 1101 | Crypto Assets — Ethereum (ETH) | IAS 38 intangible |
| 1102 | Crypto Assets — USDC / Stablecoins | Monetary asset; treated like EUR cash if fiat-pegged; FX diff if peg deviates |
| 1103 | Crypto Assets — Other Tokens | Catch-all for minor holdings; break out if material |
| 1110 | Crypto Assets — Inventory (Trading Stock) | IAS 2 — for companies whose core business is buying and selling crypto |
| 1120 | DeFi Protocol Positions (LP Tokens) | Fair value positions in liquidity pools; complex valuation |
| 1130 | NFTs Held as Inventory | NFTs held for resale in ordinary course of business (IAS 2) |
| 1131 | NFTs Held as Intangible Assets | NFTs held long-term; not for immediate resale (IAS 38) |
| 1150 | Mining Equipment (Fixed Assets) | Hardware for mining; depreciated over useful life |
| 1151 | Accumulated Depreciation — Mining Equipment | Contra-asset; reduces book value of mining hardware |
| 1160 | Revaluation Reserve — Crypto (Contra Asset) | Accumulated OCI entries from IAS 38 revaluation model; balance tracks cumulative unrealised gains |
| 1200 | Trade Receivables — Crypto Services | Amounts owed for mining services, consulting, exchange services |
| 2010 | Trade Payables | Standard supplier payables |
| 2100 | VAT Payable — KMD | Output VAT where applicable (crypto exchange services may attract VAT) |
| 2200 | Crypto Custody Liability | Client crypto held in custody; VASP licenced entities only |
| 2300 | Token Issuance Liability | Proceeds from token sales not yet earned (utility token deferred revenue) |
| 2400 | Income Tax Payable | Distribution tax on dividends; not on retained crypto gains |
| 3000 | Share Capital | Minimum €2,500 |
| 3300 | Retained Earnings | Includes realised gains on crypto disposals |
| 3400 | Crypto Revaluation Reserve (OCI) | Unrealised gains under IAS 38 revaluation model; separate from P &L |
| 4010 | Revenue — Crypto Exchange / Trading Gains | Realised gains on disposal of crypto assets (trading book); net of costs if inventory |
| 4020 | Revenue — Mining Rewards | Fair market value of mined crypto at time of receipt |
| 4030 | Revenue — Staking and Validation Rewards | Fair market value of staking rewards at time of receipt |
| 4040 | Revenue — DeFi Yield and Liquidity Rewards | Fair market value of yield tokens at time of receipt |
| 4050 | Revenue — Crypto Services (B2B) | Exchange fees, custody fees, API access to trading platform |
| 4060 | Realised Gain on Disposal — Investment Crypto | Gains on disposal of IAS 38 crypto held as investments (not inventory) |
| 4070 | Airdrop and Promotional Token Income | Fair market value of airdropped tokens at receipt if clearly non-zero value |
| 5010 | Cost of Crypto Sold (IAS 2 — Inventory) | FIFO or weighted avg cost of crypto sold in trading operations |
| 5020 | Mining Operating Costs — Electricity | Direct power costs for mining operations |
| 5030 | Mining Operating Costs — Pool Fees | Mining pool fees as % of block rewards |
| 5040 | DeFi Protocol Fees and Gas | Gas fees on Ethereum and L2 transactions for business-purpose interactions |
| 5050 | Exchange Transaction Fees (Trading) | Fees on crypto trades; included in cost of disposal for IAS 38 holdings |
| 6010 | Depreciation — Mining Hardware | Straight-line depreciation of ASICs, GPUs; typically 2–4 years |
| 6020 | Impairment — Crypto Assets (IAS 38 cost model) | Write-downs when carrying value exceeds recoverable amount |
| 6030 | Custody and Wallet Security Costs | Hardware wallet procurement; custody platform fees; key management |
| 6040 | Crypto Accounting Software | Koinly, CoinTracking, TaxBit subscriptions |
| 6050 | AML / Compliance Costs | KYC tooling; sanctions screening; compliance officer costs |
| 6060 | Legal and Regulatory | VASP/MiCA licence costs; legal counsel on token structure |
| 6070 | G &A — General Operating | Standard office, accounting, bank fees |
Section 2 — IAS 38 Cost Model: Measurement, Impairment, and Disposal
For companies holding crypto as long-term investments with conservative measurement
How the Cost Model Works
Under the IAS 38 cost model, crypto assets are held at their original acquisition cost minus any accumulated impairment losses. Market price movements above the carrying value are ignored — no upward revaluation is permitted under the cost model. Only when the market price falls below the carrying value does an accounting entry arise (impairment). This creates an asymmetric model: losses are recognised, gains are not.
| Market Movement | Cost Model Treatment | Balance Sheet Impact | P &L Impact |
|---|---|---|---|
| Price rises above cost | Ignored — no entry | Carrying value remains at cost (understates current value) | No gain recognised |
| Price falls below cost | Impairment test required | Write down to recoverable amount | Impairment loss charged to P &L |
| Price recovers after impairment | Impairment reversal permitted up to original cost under IAS 36 | Carrying value increased back toward original cost | Impairment reversal credited to P &L |
| Asset sold above cost | Realised gain at disposal | Asset derecognised; proceeds received | Gain credited to P &L |
| Asset sold below cost | Realised loss at disposal | Asset derecognised; proceeds received | Loss charged to P &L |
DR Impairment Loss — Crypto Assets (6020): €8,000.00
CR Crypto Assets — Bitcoin (1100): €8,000.00
DR Crypto Assets — Bitcoin (1100): €4,000.00
CR Impairment Reversal — Crypto (6020 CR): €4,000.00
Section 3 — IAS 38 Revaluation Model: Fair Value, OCI, and Month-End Entries
The preferred model for most Estonian crypto OÜs — reflecting current market value on the balance sheet
How the Revaluation Model Works
Under the revaluation model, crypto assets are remeasured to fair value at each reporting date (at minimum annually; in practice monthly or quarterly for crypto given price volatility). Changes in fair value since last revaluation are recognised in Other Comprehensive Income (OCI) — a section of the equity reserve — rather than in profit or loss. This means unrealised gains do not inflate operating profit, but they are visible on the balance sheet and in the statement of comprehensive income.
| Revaluation Event | Where Recognised | Balance Sheet Effect | P &L Effect |
|---|---|---|---|
| Fair value increase since last revaluation | OCI → Revaluation Reserve (equity) | Asset carrying value rises; equity reserve increases | No P &L impact — gain in OCI |
| Fair value decrease — partially reverses prior OCI gain | OCI → Revaluation Reserve (equity) | Asset carrying value falls; equity reserve decreases | No P &L — reversal of prior OCI gain |
| Fair value decrease — exceeds prior OCI gain | Excess charged to P &L as impairment | Asset carrying value falls below previous OCI baseline | P &L: impairment loss (excess only) |
| Asset disposed above current carrying value | P &L: realised gain on disposal | Asset derecognised; OCI reserve recycled to retained earnings | Gain = proceeds minus current carrying value (revalued) |
| Asset disposed below current carrying value | P &L: realised loss on disposal | Asset derecognised; OCI reserve recycled | Loss = current carrying value minus proceeds |
DR Crypto Assets — Bitcoin (1100): €20,000.00
CR Crypto Revaluation Reserve — OCI (3400): €20,000.00
DR Crypto Revaluation Reserve — OCI (3400): €400.00
CR Crypto Assets — MATIC (1103): €400.00
DR Crypto Revaluation Reserve — OCI (3400): €600.00
CR Crypto Assets — SOL (1103): €600.00
Section 4 — IAS 2 Inventory for Crypto Trading Operations
For exchanges, OTC desks, and companies that buy and sell crypto as their core business
When IAS 2 Applies
| Feature | IAS 38 Revaluation Model | IAS 2 Inventory |
|---|---|---|
| Applicable business model | Treasury, investment, holding | Trading, exchange, OTC, market-making |
| Upward revaluation | Yes — to fair value, gains in OCI | No — lower of cost and NRV only |
| Price increase recognition | OCI equity reserve | Not recognised until sold |
| Price decrease recognition | P &L (if exceeds prior OCI) or OCI reversal | P &L — write-down to NRV |
| Revenue presentation | Gross gain on disposal (P &L) | Trading revenue and cost of sales (gross margin model) |
| Cost method | FIFO, weighted average, or specific ID | FIFO or weighted average (specific ID rarely practical) |
Trading Revenue (BTC + ETH): €111,000
Cost of Crypto Sold (FIFO): −€99,000
Gross Trading Profit: €12,000 (10.8% margin)
Section 5 — Journal Entries for Every Crypto Transaction Type
The complete accounting entry for each event — buy, sell, swap, receive, mine, stake, pay fees
Buying Crypto With EUR
DR Crypto Assets — Bitcoin (1100): €20,000.00
DR Exchange Transaction Fees (5050): €40.00
CR Cash / Exchange EUR Balance: €20,040.00
Selling Crypto for EUR (Revaluation Model — IAS 38)
DR Cash / Exchange EUR Balance: €27,500.00
DR Crypto Revaluation Reserve (3400): €4,000.00
CR Crypto Assets — Bitcoin (1100): €24,000.00
CR Realised Gain — Disposal (4060): €7,500.00
Crypto-to-Crypto Swap (ETH to MATIC)
DR Crypto Assets — MATIC (1103): €2,100.00
CR Crypto Assets — Ethereum (1101): €2,000.00
CR Realised Gain — Disposal (4060): €100.00
Receiving Mining Rewards
DR Crypto Assets — Bitcoin (1100): €100.00
CR Revenue — Mining Rewards (4020): €100.00
Receiving Staking Rewards
DR Crypto Assets — Other Tokens (1103): €40.00
CR Revenue — Staking Rewards (4030): €40.00
Paying Gas Fees in ETH
DR DeFi Protocol Fees and Gas (5040): €6.00
CR Crypto Assets — Ethereum (1101): €6.00
Transferring Between Own Wallets (Non-Taxable)
DR Crypto Assets — Bitcoin — Cold Storage (1100a): €24,000.00
CR Crypto Assets — Bitcoin — Exchange (1100b): €24,000.00
Section 6 — Fair Value Determination for Crypto Assets
How to establish defensible, consistent EUR prices for every transaction and month-end valuation
The Hierarchy: Which Price to Use
| Price Source | IFRS Level | Acceptable For | Best Practice |
|---|---|---|---|
| Major exchange spot price (Binance, Coinbase, Kraken) | Level 1 | BTC, ETH, large-cap tokens with active markets | Specify which exchange in accounting policy; use same exchange consistently |
| CoinGecko average price | Level 1 (averaged) | All listed tokens; transaction-time pricing | CoinGecko API provides historical prices at specific timestamps — ideal for transaction pricing |
| CryptoCompare OHLC data | Level 1 (daily high/low/close) | Month-end valuations; larger token set | Use closing price for month-end; average or specific timestamp for transaction |
| DeFi protocol TVL / NAV | Level 2 | LP tokens, protocol-specific assets | Complex — often requires breakdown of underlying assets |
| Internal model (DCF of expected token cashflows) | Level 3 | Very illiquid or novel tokens with no active market | Requires significant documentation; auditors will challenge subjective assumptions |
Transaction pricing (each acquisition and disposal): CoinGecko API historical price endpoint at UTC timestamp of on-chain confirmation. Currency: EUR.
Month-end revaluation (IAS 38 revaluation model): CoinGecko closing price on last calendar day of month (UTC 23:59).
Policy adopted: [date] | Applies to all crypto assets from adoption date.
Section 7 — Monthly Close Process for Crypto Accounting
Day-by-day — from data download to filed returns and signed-off financial statements
The Crypto Monthly Close — What Makes It Different
| Day | Task | Data Source | Estimated Time | Sign-Off Criterion |
|---|---|---|---|---|
| Day 1 | Export all exchange transaction histories for the month | Binance, Coinbase, Kraken API or CSV export | 1–2 hours | All exchanges downloaded; date ranges confirmed |
| Day 1 | Export on-chain wallet transactions (all addresses) | Etherscan, BTC explorer, Solscan etc. | 1–3 hours (per chain) | All wallets reconciled; no gaps in transaction history |
| Day 2 | Classify transactions (buy/sell/swap/receive/transfer/fee) | Crypto accounting tool + manual review | 2–5 hours | All transactions tagged; DeFi interactions individually reviewed |
| Day 2 | Calculate cost bases (FIFO) for all disposal events | Crypto accounting tool (automated) + manual verification | 1–2 hours | Cost bases reconcile to acquisition history |
| Day 3 | Download month-end prices for all held assets | CoinGecko API | 30 min | Price for each asset at 23:59 UTC last day of month |
| Day 3 | Prepare month-end revaluation schedule | Spreadsheet or accounting system | 1–2 hours | Each asset valued; OCI entries calculated |
| Day 4 | Post all journal entries to accounting system | Crypto tool export + manual entries | 2–3 hours | All entries posted; trial balance balanced |
| Day 4 | Reconcile crypto balances (accounting vs actual wallets) | Actual wallet balances on last day of month | 1–2 hours | Zero variance between accounting ledger and actual holdings |
| Day 5 | Review P &L and balance sheet | Accounting system | 1 hour | No unexplained variances vs prior month |