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.

Chart of Accounts IAS 38 IAS 2 Fair Value Impairment Journal Entries Monthly Close Exchange Integration
IAS 38 Primary Standard
IAS 2 For Traders
FIFO Cost Method
FMV Valuation Basis
OCI Revaluation Gains
5th Monthly Close

5 Key Takeaways From This Page

Your accounting policy must be documented before the first transaction
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.
Revaluation gains go to equity (OCI) — not to your P &L
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.
Impairment testing is mandatory even if you never sell
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.
Every wallet address must be linked to the accounting system
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.
Exchange rates must be captured at transaction time — not month-end
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
Cost Model — Impairment Write-Down (BTC carrying value €30,000, market price €22,000)
DR Impairment Loss — Crypto Assets (6020): €8,000.00
CR Crypto Assets — Bitcoin (1100): €8,000.00
Cost Model — Partial Impairment Reversal (BTC recovers to €26,000)
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
October Month-End Revaluation Entry (net OCI gain €19,000)
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)
IAS 2 — Gross Margin Presentation for a Crypto Trading OÜ
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

Purchase: 0.5 BTC @ €40,000/BTC = €20,000 (via exchange)
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)

Disposal: 0.5 BTC at €55,000/BTC = €27,500 (revalued carrying value was €24,000)
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)

Swap: 1.0 ETH (carrying €2,000, FMV €2,100) for 3,000 MATIC (FMV €2,100)
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

Mining: 0.002 BTC received when price = €50,000/BTC → FMV = €100
DR Crypto Assets — Bitcoin (1100): €100.00
CR Revenue — Mining Rewards (4020): €100.00

Receiving Staking Rewards

Staking: 50 tokens received when price = €0.80/token → FMV = €40
DR Crypto Assets — Other Tokens (1103): €40.00
CR Revenue — Staking Rewards (4030): €40.00

Paying Gas Fees in ETH

Gas Fee: 0.003 ETH gas for a DeFi transaction (ETH price €2,000 → fee = €6.00)
DR DeFi Protocol Fees and Gas (5040): €6.00
CR Crypto Assets — Ethereum (1101): €6.00

Transferring Between Own Wallets (Non-Taxable)

Transfer: 0.5 BTC from Coinbase exchange to own hardware wallet
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
Sample Price Data Policy Statement
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

Frequently Asked Questions

Not necessarily — and this is one of the most important policy decisions to make upfront. IAS 38 allows different classifications for different categories of intangible assets, provided each category is assessed on its own merits. A reasonable approach: BTC and ETH (large-cap, liquid, held as treasury) under IAS 38 with the revaluation model; small DeFi tokens (illiquid, speculative) under IAS 38 with the cost model (due to difficulty establishing a reliable active market price). LP tokens and DeFi protocol positions may require a different treatment again — possibly as financial assets under IFRS 9. Document each classification in your accounting policy with the rationale. The key is that the policy is set at the category level, applied consistently within each category, and documented before the first acquisition in each category.

An airdrop of tokens with clearly non-zero market value is income at the fair market value at the time of receipt. Post: DR Crypto Assets — Token (at €3,000) / CR Revenue — Airdrop Income (€3,000). The €3,000 becomes the cost base for these tokens. If you later sell them for €5,000, the additional gain is €2,000 — recognised in P&L at disposal. If the airdropped tokens have effectively zero market value at receipt (no active market, no exchanges listing them, no price reference), you may record them at zero and only recognise income when they become valuable and are sold. Document the basis for any zero-value recording. EMTA has not published specific guidance on airdrops, but the general principle — income at FMV on receipt — is the defensible approach for tokens with an observable market price.

ETH gas fees are a disposal of ETH — you are spending a small amount of ETH (at its current market price) to pay for network processing. Each gas payment has two accounting effects: (1) the ETH disposed creates a gain or loss against its cost base (usually small, but must be tracked), and (2) the fee itself is an expense. For the fee classification: gas fees on crypto acquisitions (buying tokens) should be capitalised into the cost of the acquired asset — they increase the cost base. Gas fees on business-purpose DeFi transactions (swapping, staking) are operating expenses (Account 5040). Gas fees on transfers between your own wallets are a minor cost with no clear standard treatment — most practitioners expense them. For high-volume DeFi operations, tracking individual gas fees at the transaction level is essential — the cumulative impact on cost bases and expenses is material.

Mining creates two accounting entries on the date the BTC is received: (1) record the BTC at its FMV of €25,000 as an asset, and (2) record €25,000 as mining revenue. Your costs (€8,000 electricity + pool fees) are operating expenses (Accounts 5020 and 5030), recognised in the period incurred. Gross profit from mining = €25,000 revenue minus €8,000 costs = €17,000. The BTC is now on your balance sheet at €25,000 (which becomes its cost base). For Estonian corporate tax purposes, the €17,000 mining profit is retained earnings — no immediate tax. Tax arises when dividends are distributed. If you later sell the BTC at €30,000, the additional gain is €5,000 (€30,000 minus the €25,000 cost base established at mining receipt). This gain also increases retained earnings without immediate tax.

Koinly requires three things to produce accurate records: (1) all wallet addresses — every Ethereum address, Bitcoin address, and wallet on any chain that the OÜ controls, including smart contract positions; (2) exchange API connections — API keys for each exchange with read-only access so Koinly can pull transaction history directly; and (3) manual entries for any transactions not captured by APIs — typically over-the-counter purchases, peer-to-peer transfers, DeFi protocol interactions on chains Koinly doesn’t support fully, and any historical transactions that predate the API connection. Your accountant will then review Koinly’s auto-classified transactions, manually correct any misclassified events (particularly DeFi interactions), export the cost basis data, and use it to prepare the journal entries for your accounting software. Koinly itself does not post to your accounting software — your accountant takes the output and translates it into proper accounting entries.

Need your crypto accounting set up correctly from day one?

Book a free 30-minute consultation. We configure your chart of accounts for digital assets, set up your fair value measurement policy, connect your exchange APIs, and deliver clean monthly financials.

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