A scheduled buying policy for a company

Sources checked 10 November 2026. This page is about governance and records for a company that buys bitcoin in instalments on a fixed schedule. It does not say whether scheduled buying will do better or worse than buying at once, or than not buying at all, and it makes no prediction about the price. It is not advice and not a recommendation to buy, sell or hold bitcoin. If anything here conflicts with a linked source, the source wins.

What the policy decides

Our judgement, not a rule: these are the points a scheduled buying section of a treasury policy usually needs to answer. None of them involves a view on price.

The policy generator can add an optional section 13, Scheduled buying, to a draft treasury policy: the standing authority, the amount and interval, limits, pause conditions, withdrawal to the company's multisig and records. Set the scheduled buying field to include it.

Standing authority and directors' duties

A board can delegate routine execution within limits it sets. It cannot delegate away its duties. In the UK, section 172 of the Companies Act 2006 requires a director to act in the way they consider, in good faith, would be most likely to promote the success of the company, and section 174 requires reasonable care, skill and diligence. A written schedule with limits, a funding floor and a review date is one way to show that the board considered the decision once, properly, rather than repeatedly and informally. Delaware and other US states have their own fiduciary duty law; see directors' duties and bitcoin.

Source: legislation.gov.uk: Companies Act 2006, section 172: duty to promote the success of the company, legislation.gov.uk: Companies Act 2006, section 174: duty to exercise reasonable care, skill and diligence.

The minute approving the schedule should name the provider and account, the amount, the interval, the total limit, the funding account, the people who place and check, the withdrawal rule and the review date. A change to any of those is a new decision. See the board paper outline.

Running the schedule

• Recurring buy features. Many providers let an account buy automatically. If the company uses one, the provider's settings should match the minute exactly, and a second person should check them after any change. A manual monthly order, placed and checked by two people, is the alternative.
• Bank evidence. Each purchase should match a bank debit or a pre-funded balance, so the source of funds trail stays clean. See banking and source of funds.
• Withdrawals to multisig. Withdraw in batches to a receiving address checked on the company's signing devices, with a test amount the first time and whenever the address changes. Many small withdrawals create many small coins, which are more expensive to spend later. See fees and UTXOs and sending bitcoin safely.
• Exceptions. If a purchase fails or is skipped, record why. Do not double up the next one unless the policy says so.
• Monthly log. One line per purchase: date and time, amount paid, fee, bitcoin received, provider reference, who placed it and who checked it. Add each withdrawal with its transaction ID.

Choose your country for the tax and records points.

UK: each purchase joins the pool

HMRC's manual says that where tokens are dealt in without identifying the particular tokens, they are pooled under section 104 of the Taxation of Chargeable Gains Act 1992: a single pooled asset for each type of token, whose pooled allowable cost increases with each acquisition. A company buying monthly simply adds each purchase, and its cost, to the bitcoin pool. HMRC also says businesses must keep a record of the amount spent on each type of token, as well as the pooled allowable cost.

Source: HMRC: CRYPTO41350: Corporation Tax on chargeable gains, pooling, with the same day and ten day exceptions for companies.

Two company rules can take a purchase out of the pool. If the company acquires tokens on the same day as it disposes of tokens of the same type, the disposal is matched with that acquisition first. And if the company disposes of tokens within ten days of an acquisition, the disposal is matched with acquisitions in the previous nine days before the pool. A company that buys on a schedule and also sells, for example to rebalance, should check these rules before a sale near a scheduled purchase. These are not the 30-day rule that applies to individuals.

Source: HMRC: CRYPTO41350: Corporation Tax on chargeable gains, pooling, with the same day and ten day exceptions for companies.

HMRC lists the costs it accepts as allowable, including the consideration paid and transaction fees for having a transaction included on the ledger, and sets out which exchange fees qualify. Record the fee for each purchase separately from the amount of bitcoin bought.

Source: HMRC: CRYPTO41300: Corporation Tax, allowable costs, including transaction fees and exchange fees.

Each purchase also affects the accounts at the year end, under FRS 105 or FRS 102. See the year-end checklist and bookkeeping examples.

US: each purchase is a lot

Notice 2014-21 treats virtual currency as property, so each purchase has its own basis and holding period. Treasury Regulation 1.1012-1(j) sets the order in which units are treated as sold. For digital assets not held with a broker, such as in an unhosted wallet like the company's multisig, the company can make a specific identification of the units sold on its books and records no later than the date and time of the sale. Without one, units are treated as sold in order of time from the earliest acquired. Rules for units held with a broker are in the same paragraph. A monthly schedule produces twelve lots a year, so the records system has to keep each one, and must follow units when they move from the provider to the multisig.

Source: IRS: Notice 2014-21: virtual currency is treated as property for federal tax purposes, eCFR: 26 CFR 1.1012-1(j): digital assets, specific identification on the books and records, and the earliest-acquired default.

Revenue Procedure 2024-28 set the transition for allocating basis to wallets and accounts as of 1 January 2025, and providers now report sales on Form 1099-DA. See Form 1099-DA for companies and US basis. Purchases themselves are not taxable events.

Source: IRS: Revenue Procedure 2024-28: allocating unused basis to wallets and accounts as of 1 January 2025 (PDF).

For accounting, ASU 2023-08 measures the holding at fair value each period, so the schedule changes the carrying amount and the disclosures over the year. See US accounting under ASU 2023-08.

Common questions

Is scheduled buying better than buying all at once?

This page does not answer that. It depends on what happens to the price, which nobody knows in advance. The choice here is about governance: a schedule spreads the decision into small, checkable steps; a single purchase is one larger decision with one set of checks. Either needs the same limits and controls.

Can the schedule change if the price moves a lot?

Only if the policy says so in advance, or the board makes a new decision. Rules that pause on the company's own position, such as cash below the floor, are easier to verify than rules based on views about the market.

Should each purchase be withdrawn straight away?

That is a custody and cost trade-off for the policy to settle. Leaving bitcoin with a provider means relying on it for that period; withdrawing every small purchase adds fees and coins to manage. See custody options.

Common mistakes

• A recurring buy set up by one person, with no minute, no limit and no review date.
• The provider's recurring amount changed without a new decision, or not checked after a change.
• No cash floor, so the schedule keeps buying when the business needs the money.
• Recording only the monthly total, not each purchase, its fee and its time, which the UK same day and ten day rules and US lot identification both need.
• Withdrawing every purchase separately and building up many small coins.
• Pausing or doubling the schedule on a feeling about the market, outside the written rules.

Read next

• Treasury policy, with a generator for the written rules.
• Sizing an allocation, the limit the schedule works within.
• Buying bitcoin as a company, providers, checks and the test transaction.
• Selling or rebalancing, the other side of the policy.
• Bookkeeping examples, the UK pool and US lots in journal entries.
• Board paper outline, the paper and the minute.

Sources

Primary sources only. Each link was checked on 10 November 2026. Rules change, so confirm the current version with your adviser.

1. legislation.gov.ukCompanies Act 2006, section 172: duty to promote the success of the company
2. legislation.gov.ukCompanies Act 2006, section 174: duty to exercise reasonable care, skill and diligence
3. HMRCCRYPTO41350: Corporation Tax on chargeable gains, pooling, with the same day and ten day exceptions for companies
4. HMRCCRYPTO41300: Corporation Tax, allowable costs, including transaction fees and exchange fees
5. IRSNotice 2014-21: virtual currency is treated as property for federal tax purposes
6. eCFR26 CFR 1.1012-1(j): digital assets, specific identification on the books and records, and the earliest-acquired default
7. IRSRevenue Procedure 2024-28: allocating unused basis to wallets and accounts as of 1 January 2025 (PDF)