Accounting for Crypto and Stablecoins: The HKICPA's 2025 Guidance Framework

• Standards: HKAS 38 — Intangible Assets; HKFRS 9 — Financial Instruments; HKFRS 13 — Fair Value Measurement
• Guidance Issued: 2025 by HKICPA
• Scope: Cryptocurrencies, stablecoins, and digital assets

Hong Kong wants to be a crypto hub. But until recently, the accounting rules for digital assets were a grey area—no dedicated standard, just a patchwork of existing frameworks that didn’t quite fit.

In 2025, the HKICPA issued dedicated guidance clarifying which HKFRS standards apply to cryptocurrencies and stablecoins. There’s still no single new standard for crypto. Instead, the guidance maps different types of digital assets to existing frameworks based on their characteristics and the entity’s business model.

The Classification Framework

Cryptocurrencies not held for sale → Intangible assets (HKAS 38)

Measured at cost less impairment, or using the revaluation model if an active market exists. This is the default treatment for entities holding crypto as long-term investments or treasury reserves. The catch: under the cost model, you can write down but you can’t write up. Impairment is a one-way street until you sell.

Cryptocurrencies held as inventory by commodity broker-traders → Fair value less costs to sell

If you trade crypto in the ordinary course of business as a commodity broker-trader, the inventory measurement exception applies. This gives you fair value accounting with changes flowing through profit or loss.

Stablecoins backed by financial assets → Potentially financial instruments (HKFRS 9)

The classification depends on the nature of the backing and the contractual rights. If the stablecoin gives the holder a contractual right to receive cash or another financial asset, it may meet the definition of a financial instrument.

Investment entities holding crypto at FVTPL → HKFRS 9 with HKFRS 13 disclosures

Fund vehicles holding crypto as part of their investment portfolio measure at fair value through profit or loss, with the standard HKFRS 13 fair value hierarchy disclosures (Level 1, 2, or 3).

The Questions That Matter

The classification decision drives everything—measurement, impairment, and disclosure. Ask yourself:

• What is the entity’s business model for holding the digital asset?
• Does the asset give rise to contractual rights to cash or other financial assets?
• Is there an active market?
• Is the entity a commodity broker-trader?

For entities with material crypto holdings, the guidance provides a clear framework. But the application still requires judgement, particularly for novel token structures that don’t fit neatly into existing categories.

The Regulatory Landscape

Hong Kong launched its comprehensive stablecoin regulatory regime on 1 August 2025. Licensed issuers must maintain a minimum of HK$25 million in paid-up share capital and ensure 100% backing of outstanding stablecoins with high-quality liquid assets. Pre-existing issuers had until 31 January 2026 to receive a provisional license or begin a closing-down period.

The crypto accounting landscape is still evolving globally—the IASB has its own project underway. But for now, the HKICPA guidance gives Hong Kong entities a workable map, and the new licensing regime adds regulatory clarity that should help with classification judgements going forward.

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This article is for informational purposes only and does not constitute professional accounting or legal advice.