Guides / Policy

Write a treasury policy before the first purchase

A short written policy sets the limits, approvals and controls. Use the generator to produce a first draft for your advisers to review.

Last reviewed: 21 October 2026US and UK side by sideEducation only
Education, not advice.

This is general information and education only. It is not financial, investment, tax, accounting, legal or regulatory advice, and it is not a recommendation to buy, sell or hold bitcoin or any other asset. It does not take account of your circumstances or those of your company. You must obtain your own official professional advice to confirm this information is correct before acting on it.

Rules change. This information is correct to our understanding at the last-reviewed date, but it may be incomplete or out of date, and official sources take precedence. Bitcoin is volatile. A company that buys it could lose some or all of the money it puts in.

Using this site does not create an adviser or client relationship. IoT Financial is not authorised or regulated by the Financial Conduct Authority (FCA) and is not registered with the US Securities and Exchange Commission (SEC) as an investment adviser. Read the full disclaimer.

Why write a policy first

A written policy turns a one-off decision into a repeatable process. It records who can approve what, how much the company may hold, where the asset is kept, and when the position is reviewed. It also gives auditors and future directors a clear record of what was agreed and why.

What a policy should cover

SectionWhat it settles
Purpose and authorityWhy the company holds bitcoin at all, and who can change the rules.
Protected reservesThe cash that must always stay in cash. Links to the sizing method.
Allocation limitsPercentage cap, optional hard cap, and what happens when value moves past the cap.
ApprovalsM of N approvers by role, and separation of duties.
CustodyThe model chosen, the key register and recovery testing. The template lists multisig, a regulated custodian and exchange-traded products, and leaves out single-signature wallets, which we do not recommend for a company.
Accounting, records and taxMeasurement basis, record keeping and adviser review.
Review and incidentsReporting cadence, and what to do if a key may be compromised.
CommunicationsWhat the company will and will not say publicly about its holdings.

The generator

Fill in the form to produce a first draft. Everything runs in your browser and nothing is sent to us.

Tool: policy generatorruns in your browser
Optional. Leave blank to use "the Company".
US and UK includes matching clauses for both markets.
Set automatically for US only or UK only. Choose for US and UK.
Excess reserves as defined in the sizing guide.
When fair value exceeds the cap by this much, approvers decide whether to rebalance.
Use roles, not names. The first role is the policy owner.
See the custody guide. A single-signature wallet is not offered: we do not recommend it for a company treasury, because one device or one person becomes a single point of failure.

Illustration only. The calculator, questionnaire and policy generator produce illustrations from your own inputs. They are not recommendations. You must obtain your own official professional advice to confirm this information is correct before acting on it. Disclaimer.

Every download starts and ends with a notice that the draft must be reviewed by your own qualified advisers before adoption. If you remove either notice in the box, it is added back on download. Other edits are kept. If you change a form field afterwards, the draft is regenerated.

US and UK points to check

The generator adds matching clauses for each market you select. These are the points behind them.

USUKUNITED STATES

Accounting

Where ASU 2023-08 applies, holdings are measured at fair value with changes in net income, so the review section should report fair value as well as cost. Shares in a spot bitcoin exchange-traded product are outside ASU 2023-08, so if that is the chosen model the generator adds a clause saying so.

Tax and records

IRS Notice 2014-21 treats virtual currency as property. Keep a record of each acquisition and disposal with its date, units, fair market value in US dollars and basis, which is what the IRS digital assets guidance lists. Do not rely on a Form 1099-DA arriving, as corporations other than S corporations are generally exempt recipients.

Communications

We are not aware of a dedicated US federal regime for cryptoasset promotions like the UK one. General rules on misleading statements still apply, including the SEC antifraud rule where securities are involved (Rule 10b-5) and the FTC Act ban on deceptive practices, and state laws may also apply. Ask your own legal adviser before saying anything public about holdings.

USUKUNITED KINGDOM

Accounting

The measurement basis depends on the framework: FRS 102, FRS 105 (historical cost only) or IFRS, where IAS 38 or IAS 2 may apply. For internal review, the policy can still ask for fair value alongside cost whichever basis the accounts use. HMRC describes crypto ETNs as debt securities, so if that is the chosen model the generator adds a clause saying so.

Tax and records

HMRC expects values to be converted to sterling at the time of each transaction using a consistent method, with the method recorded (CRYPTO40100). Which Corporation Tax rules apply depends on the company's activities and accounting (CRYPTO41000).

Communications

Since 8 October 2023, when qualifying cryptoassets came into the FCA remit, cryptoasset financial promotions to UK consumers have been subject to FCA rules (PS23/6). Before saying anything public about holdings, check whether it could be a financial promotion.

Adopting the policy

  1. Generate a draft here or start from the full template.
  2. Ask your accountant to review sections 7 and 8, and your legal adviser to review the whole document.
  3. Approve it by board resolution or written resolution of the directors, and record the decision in the minutes.
  4. Set the first review date before any purchase is made.

Sources

Primary sources only. Each link was checked on 21 October 2026. Rules change, so confirm the current version with your adviser.

  1. FASBASU 2023-08, Intangibles: Goodwill and Other, Crypto Assets (Subtopic 350-60)
  2. FRCFRS 102: The Financial Reporting Standard applicable in the UK and Republic of Ireland
  3. FRCFRS 105: The Financial Reporting Standard applicable to the Micro-entities Regime
  4. IRSNotice 2014-21: virtual currency is treated as property for federal tax purposes
  5. HMRCCRYPTO41000: Corporation Tax, contents
  6. IRSDigital assets
  7. HMRCCRYPTO40100: Conversion to sterling and accountancy
  8. IRSInstructions for Form 1099-DA (2026): covered securities, basis reporting and exempt recipients
  9. HMRCInformation you need to give to UK cryptoasset service providers
  10. US CFR17 CFR 240.10b-5: employment of manipulative and deceptive devices (SEC antifraud rule)
  11. FCAPS23/6: Financial promotion rules for cryptoassets
  12. US Code15 U.S.C. 45: unfair or deceptive acts or practices (FTC Act, section 5)
  13. FCACryptoassets: our work
  14. SECInvestor Bulletin: exchange-traded products providing exposure to bitcoin and ether (September 2024)
  15. HMRCTax treatment of cryptoasset Exchange Traded Notes

Coming next: a set of working documents for companies that decide to go ahead. See what is coming next.