Crypto Treasury Management in 2026: Custody, Accounting, and Compliance

By Chanté Eliaszadeh | Updated June 2026

If you hold digital assets on your company’s balance sheet, three things changed in 2025 and early 2026 that rewrite how you manage a crypto treasury: the accounting rules now mark crypto to fair value, the bank-access climate flipped from hostile to open, and California’s first crypto-custody regime is finally arriving. The FTX collapse still supplies the one durable lesson --- customer and corporate assets must be genuinely segregated and independently custodied --- but almost everything around that lesson has moved. This guide covers where a crypto treasury sits today: custody architecture, the new accounting treatment, banking access after the OCC’s pivot, and the California and federal rules now taking shape.

Key Takeaways

• Crypto is now a fair-value asset on the books. FASB ASU 2023-08, effective for fiscal years beginning after December 15, 2024, requires crypto held on the balance sheet to be measured at fair value through net income.¹
• The custody balance-sheet barrier is gone. The SEC’s SAB 122 rescinded SAB 121 in January 2025, removing the on-balance-sheet liability that had kept banks out of crypto custody.²
• Banking access got easier. The OCC rescinded its supervisory-non-objection requirement in March 2025, reversing the debanking-era posture that treated crypto activity as presumptively risky.³
• California’s DFAL is coming, not here. Registration opened March 9, 2026 and the law takes effect July 1, 2026; the specific custody rules are still in DFPI rulemaking, not yet final.⁴
• Stablecoin treasury holdings now have a federal regime. The GENIUS Act governs payment stablecoins, and it bars a non-financial public company from issuing one absent unanimous federal approval.⁵

How Should a Crypto Company Hold Its Treasury Assets?

The first decision is who holds the keys. After FTX --- where customer assets were commingled with the trading entity and lost --- the governing principle is that treasury assets should be held by a qualified, independently regulated custodian, segregated from operating funds, so that a failure of the operating business cannot reach them. For most companies that means a third-party qualified custodian; for some it means a carefully governed self-custody arrangement with multi-signature or multi-party-computation controls and institutional key management.

The trade-off is real. A regulated custodian gives you insurance, audited controls, and a counterparty a bank or auditor will recognize, at the cost of fees and less direct control. Self-custody gives you control and lower ongoing cost, at the cost of operational risk that sits entirely on your own governance. The larger the treasury, the more the analysis favors a regulated custodian --- or a hybrid, with the working balance in self-custody under tight controls and the bulk with a qualified custodian.

Whatever the architecture, the FTX lesson is the test: if your operating company failed tomorrow, could a creditor reach your treasury assets? If the answer is yes, they are not properly segregated.

Who Are the Qualified Custodians?

The qualified-custodian landscape changed materially at the end of 2025, when the OCC began granting national trust bank charters to digital-asset custodians --- moving several from state trust charters to federal ones. The table below reflects that shift; insurance figures are as reported by the providers and should be confirmed directly before relying on them.³

Confirm a custodian’s current charter and insurance directly --- the regulatory-status column moved fast in 2025-2026, and a provider that was a state trust last year may be a national trust bank now. A technology provider like Fireblocks is not a qualified custodian, even if it secures the keys.

What Changed in Crypto Accounting?

For years, holding crypto on a corporate balance sheet meant accounting for it as an indefinite-lived intangible: written down when prices fell, never written back up when they recovered --- a treatment that understated the asset and discouraged corporate holdings. That is over. FASB ASU 2023-08, effective for fiscal years beginning after December 15, 2024, requires in-scope crypto assets to be measured at fair value, with changes in value flowing through net income each period, plus enhanced disclosure of holdings.¹ For calendar-year companies, that treatment is live as of 2025.

A second, quieter change removed the banking barrier. The SEC’s Staff Accounting Bulletin 121 had required entities that custody crypto for others to record a balance-sheet liability for the safeguarded assets --- a capital hit that effectively kept regulated banks out of crypto custody. SAB 122 rescinded SAB 121 in January 2025, removing that liability and reopening custody as a business banks can actually offer.² The combined effect: crypto on your own books now reflects real value, and the universe of institutions willing to custody it has widened.

If your last accounting policy memo predates 2025, it is out of date. Crypto on the balance sheet is now fair-value-through-net-income, and the custody-liability rule that pushed banks away is gone --- both change how a treasury reports and where it can bank.

Can Crypto Companies Get Banking Access Now?

The banking climate has reversed. The OCC’s 2020 framework (Interpretive Letter 1170) had confirmed national banks could custody crypto, but a 2021 letter layered on a supervisory-non-objection requirement that, in the 2022-2024 debanking climate, functioned as a brake.³ In March 2025 the OCC rescinded that non-objection requirement (Interpretive Letter 1183) and followed with further guidance on crypto activities and third-party arrangements (Interpretive Letter 1184), signaling that crypto custody and related services are permissible banking activities to be supervised like any other --- not presumptively suspect.³

The practical effect for a crypto company’s treasury is that partner-bank relationships are easier to open and keep than they were two years ago, and the “comply with informal guidance or get your account closed” dynamic has eased. It has not vanished --- banks still run their own risk programs --- but the regulatory posture no longer pushes them to exit crypto clients.

If you were debanked or turned away in 2023-2024, the 2025 OCC posture is worth a fresh approach. The supervisory headwind that made banks skittish about crypto custody has been removed.

What Will California’s DFAL Require?

California’s Digital Financial Assets Law is the state’s first comprehensive crypto regime, but it is not yet in force. Enacted as AB 39 in 2023 and then delayed by AB 1934, the law’s licensing registration opened March 9, 2026 and its requirements take effect July 1, 2026.⁴ A treasury operating in or serving California should plan for it, but should not treat its specifics as live obligations today.

Crucially, the detailed custody and security rules are still being written. The DFPI issued proposed regulations and announced modifications in late 2025; until those rules are final, the precise custody thresholds, audit cadence, and breach-notification timelines are not settled law, and anyone stating them as fixed requirements is guessing.⁴ What is reasonably clear is the shape: DFAL will require licensure for covered digital-financial-asset business activity, and it will impose custody and disclosure duties on covered firms. Plan for a licensing analysis well before July 1, 2026; hold the line-item compliance build until the DFPI rules are final.

Treat DFAL as a 2026 planning item, not a current rulebook. The licensing date is real (July 1, 2026); the custody line-items are still in rulemaking, so do not build to figures that are not yet law.

Where Do Stablecoins Fit in a Crypto Treasury?

Many crypto treasuries hold stablecoins for liquidity, and some companies consider issuing one. Both now sit under the GENIUS Act, the federal payment-stablecoin framework enacted July 18, 2025.⁵ For a treasury that merely holds a regulated payment stablecoin, the relevant point is that permitted stablecoins must be fully backed by short, liquid reserves --- which is what makes them a defensible cash-equivalent rather than a credit bet on the issuer. For a company considering issuing its own stablecoin, the Act is a gating constraint: a non-financial public company generally cannot issue a payment stablecoin without unanimous federal approval, so issuance is not an off-the-shelf treasury strategy.⁵ For the full framework, see the GENIUS Act compliance roadmap.

Holding a regulated stablecoin is a liquidity tool; issuing one is a regulated activity a non-financial company generally cannot undertake on its own. Know which side of that line your treasury strategy is on.

What Does Crypto Treasury Management Cost?

The numbers below are planning estimates for a mid-size treasury, not quotes, and they move with provider and scale. Custodian fees typically run as a low annual percentage of assets under custody plus transaction fees; multi-signature or MPC infrastructure for a self-custody build runs from the low tens of thousands into the low hundreds of thousands depending on sophistication; reconciliation and accounting software for crypto runs in the low-to-mid five figures annually; and insurance, audit, and incident-response readiness add to the total. A small treasury can stand up a compliant posture in the low six figures; a large one with full custody, audit, and accounting infrastructure should plan well beyond that.

Budget to your size, and treat custody, accounting, and audit as the three non-optional line items --- the FTX-era lesson is that the cheap version of custody is the expensive one when it fails.

Need Help Structuring Your Crypto Treasury?

Astraea Counsel advises crypto, blockchain, and fintech companies on custody architecture, qualified-custodian selection, the new crypto-accounting treatment, banking access, and California and federal compliance. Explore our Digital Assets & Blockchain legal services.

Related Resources

• GENIUS Act Stablecoin Compliance Roadmap --- The federal payment-stablecoin framework
• Money Transmitter Licensing: State-by-State Strategy --- State licensing for digital-asset businesses
• Qualified Crypto Custodians: Regulatory Requirements --- Selecting and vetting custodians
• Regulatory Compliance Services --- Federal and state compliance guidance
• Contact Us --- Discuss your treasury structure

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Footnotes

1. Financial Accounting Standards Board, Accounting Standards Update 2023-08, Accounting for and Disclosure of Crypto Assets (fair-value measurement; effective for fiscal years beginning after Dec. 15, 2024), available at https://storage.fasb.org/ASU%202023-08.pdf. ↩ ↩²

2. SEC Staff Accounting Bulletin No. 122 (Jan. 23, 2025), rescinding Staff Accounting Bulletin No. 121, available at https://www.sec.gov/rules-regulations/staff-guidance/staff-accounting-bulletins/staff-accounting-bulletin-122. ↩ ↩²

3. OCC Interpretive Letter 1170 (July 2020) (national-bank crypto custody); Interpretive Letter 1183 (Mar. 7, 2025) (rescinding the supervisory-non-objection requirement); Interpretive Letter 1184 (May 2025) (crypto activities and third-party arrangements); see also OCC conditional national trust-bank charter approvals (Dec. 12, 2025). IL 1183: https://www.occ.gov/topics/charters-and-licensing/interpretations-and-decisions/2025/int1183.pdf. PDF ↩ ↩² ↩³ ↩⁴

4. California Digital Financial Assets Law, AB 39 (2023) as amended by AB 1934 (2024); licensing registration opened March 9, 2026, law effective July 1, 2026; implementing custody and security regulations proposed by the DFPI (modified late 2025) and not yet final. AB 39: https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=202320240AB39; AB 1934: https://leginfo.legislature.ca.gov/faces/billTextClient.xhtml?bill_id=202320240AB1934; DFPI DFAL FAQ: https://dfpi.ca.gov/dfal/faq/. ↩ ↩² ↩³

5. Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act), Pub. L. No. 119-27 (2025), approved July 18, 2025; payment-stablecoin reserve and issuance framework, including the restriction on issuance by non-financial public companies absent unanimous Stablecoin Certification Review Committee approval. PDF ↩ ↩² ↩³