Built 9 November 2026. This tool compares the words in a draft policy with the points on our treasury policy checklist. It is a reading aid, not a legal, accounting or tax review, and it does not say whether a company should hold bitcoin.
How it works
Paste the text of a draft bitcoin treasury policy, choose UK, US or both, and press Check my policy. The tool looks for wording that covers each checklist point, shows the sentence it found, and lists the gaps with a line on what to add. It also flags a few patterns to look at first, such as a single-signature wallet, one person approving alone, or recovery words kept in the cloud.
Your text never leaves your browser. The check runs in JavaScript on this page. The text you paste is not uploaded, stored or recorded anywhere, and the check still works if you go offline after the page has loaded.
Treasury policy, Example Trading Ltd. The company will buy bitcoin because it will rise in value over time. The finance director may approve any purchase up to 50,000 pounds. Bitcoin is held in a single-signature hardware wallet kept by the finance director. The seed phrase is saved in the company cloud drive so it is not lost.
Bitcoin treasury policy Purpose: to hold part of our excess cash reserves in bitcoin under clear limits. We keep 6 months of operating costs in cash at all times. Holdings may not exceed 10% of excess reserves, measured at cost. Every purchase, sale or transfer needs approval by 2 of 3 named approvers: Finance lead, Managing director, Company secretary. Bitcoin is held in a 2 of 3 multisig wallet; the company does not use a single-signature wallet. We report holdings at cost and fair value quarterly to the board.
What it checks
The checks follow the nine headings of the checklist, plus country points. Each point passes when matching wording appears anywhere in the text, so a pass means the topic is mentioned, not that the clause is right for your company.
| Heading | What the tool looks for |
|---|---|
| Purpose and authority | Why the company holds bitcoin; who can change the rules; a policy owner by role. |
| Protected reserves | Cash that must stay in cash, sized in months of costs, including tax, payroll and loan payments. |
| Allocation limits | A percentage cap; an optional money cap; a trigger when value moves past the cap; no borrowing, leverage or lending. |
| Approvals | M of N approvers by role; separation of duties; approvals in writing before execution. |
| Custody | The custody model; a key or account register; recovery tests; no single-signature wallet; optional address allow list. |
| Accounting, records and tax | Measurement basis; a record of each acquisition and disposal; fair value alongside cost; tax reviewed with an adviser. |
| Review, incidents and continuity | Reporting cadence; a review date; what to do on a compromise; what happens when a keyholder leaves. |
| Communications | Who may speak publicly; a legal check before any statement. |
| Adoption | Board resolution and minutes; adviser review; adopted before any purchase. |
Sentences that rule something out are read as such: "the company does not use a single-signature wallet" counts as a pass, not a warning. If your policy uses unusual wording, a real clause can be missed. Read the gaps as questions, not findings.
UK points it checks
- Accounting framework. Whether the policy names the framework the company reports under (FRS 102, FRS 105 or IFRS) and how bitcoin is measured. See UK company bitcoin accounting under FRS 102.
- Corporation Tax. Whether it mentions Corporation Tax, HMRC or chargeable gains. HMRC's manual explains that a company holding exchange tokens as an investment is generally charged Corporation Tax on chargeable gains, and that tokens are pooled.
Source: HMRC: CRYPTO41200: Corporation Tax on chargeable gains, introduction, HMRC: CRYPTO41350: Corporation Tax on chargeable gains, pooling (with the same-day and ten-day exceptions for companies).
- Sterling values. Whether it says how each transaction is valued in sterling. HMRC expects a reasonable, consistently used method.
Source: HMRC: CRYPTO40100: Cryptoassets for businesses, valuation (converting to sterling).
- Public statements. Whether it mentions financial promotion rules or the FCA, so a lawyer is asked before anything is published.
US points it checks
- Accounting basis. Whether the policy names ASU 2023-08 (fair value under ASC 350-60) or another basis agreed with the accountant.
- Basis and lots. Whether it says how cost basis is tracked and which units are treated as sold, wallet by wallet. From 1 January 2025 the regulations use FIFO within each wallet or account unless units are specifically identified in time.
- US dollar values. Whether it names a price source for fair value and transaction records.
- Disclosure. Whether it mentions securities law or disclosure checks before public statements.
What it cannot do
- It cannot tell whether a clause is adequate, lawful or right for your company. Only your advisers can.
- It does not read Word or PDF files. Copy the text into the box, or save the policy as plain text.
- It matches words, so unusual phrasing can be missed and a passing mention can count as covered.
- It checks against our checklist, which is a starting point. Your advisers may add points that matter for your sector or structure.
Read next
- Treasury policy guide, with the checklist this tool uses.
- Treasury policy template, the full draft this tool scores against.
- Board meeting checklist, for the meeting that adopts the policy.
- 2 of 3 multisig simulator, to see why no single key should control company funds.
Sources
Primary sources only. Each link was checked on 9 November 2026. Rules change, so confirm the current version with your adviser.
- HMRCCRYPTO41200: Corporation Tax on chargeable gains, introduction
- HMRCCRYPTO41350: Corporation Tax on chargeable gains, pooling (with the same-day and ten-day exceptions for companies)
- HMRCCRYPTO40100: Cryptoassets for businesses, valuation (converting to sterling)
- eCFR26 CFR 1.1012-1(h) and (j): basis of digital assets and which units are treated as sold (applies from 1 January 2025)
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.