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Microlesson · 5-min read

Audit Disclosures for Crypto Currency or Virtual Currency

# Crypto Currency / Virtual Currency - Disclosure Requirements

Where a Company has traded or invested in Crypto Currency or Virtual Currency during the financial year, certain mandatory disclosures must be made in the financial statements. The auditor must verify these disclosures pursuant to Schedule III amendments.

## A. Mandatory Disclosures

Where a Company has traded or invested in Crypto currency or Virtual Currency during the FY, the following shall be disclosed:

1. Profit or Loss on Transactions involving Crypto Currency or Virtual Currency during the year

2. Amount of Currency Held as at the reporting date (closing balance)

3. Deposits or Advances received from any person for the purpose of trading or investing in Crypto Currency / Virtual Currency

## B. Auditor's Verification Approach

### 1. Existence of Transactions

First determine whether the entity has dealt in crypto/virtual currency during the year through:

  • Bank statement scrutiny (transfers to known crypto exchanges)
  • Board minutes (any investment approval)
  • Management representation

### 2. Valuation

  • Verify the basis on which closing balances of crypto currency are valued (cost, fair value)
  • Examine the source of fair value (crypto exchange quotes as on reporting date)

### 3. Profit/Loss Computation

  • Verify transaction-wise computation
  • Reconcile with broker/exchange statements
  • Verify treatment of gains as capital or business income

### 4. Deposits and Advances

  • Examine if entity has received any amounts from third parties for crypto trading
  • Verify nature of relationship (related party implications)
  • Verify if such activity is in line with the company's Memorandum of Association

### 5. Reporting Considerations

  • Verify disclosure compliance with Schedule III (amended)
  • Consider implications of any prohibitions/restrictions by RBI or government circulars
  • Consider tax implications (taxation of Virtual Digital Assets @ 30% under Income Tax Act post-Finance Act 2022)

## C. Risk Considerations

  • High inherent risk due to volatile valuations
  • Pseudonymity makes counterparty verification difficult
  • Regulatory uncertainty creates risk of subsequent events
  • Custody risk (private key safekeeping)

Worked example

### Example 1

Example – Crypto Currency Disclosure:

ABC Pvt Ltd holds the following at year-end (31st March 2026):

  • 5 Bitcoin (BTC) acquired at average cost ₹40,00,000 each = ₹2,00,00,000
  • Fair value at year-end: ₹45,00,000 each = ₹2,25,00,000
  • During the year: Bought 3 BTC at ₹38,00,000 each, Sold 2 BTC at ₹42,00,000 each
  • Received advance of ₹50,00,000 from Mr. X for crypto trading on his behalf

Disclosure required:

ParticularsAmount (₹)
Profit on sale of crypto (2 × (42,00,000 - 38,00,000))8,00,000
Crypto currency held at reporting date (5 BTC)2,00,00,000 (or fair value as per policy)
Advances received for crypto trading50,00,000

The auditor must verify each of these from supporting documents like exchange statements and bank records.

⚠️ Common exam mistakes

  • Failing to identify crypto transactions because they are routed through unusual channels not labeled as 'crypto'
  • Not disclosing the closing balance of crypto held – only disclosing profit/loss
  • Missing disclosure of deposits/advances received for crypto trading (separately required)
  • Not considering whether crypto trading is permitted by the entity's Memorandum of Association
  • Confusing 'amount held' with 'amount invested during the year' – the disclosure is for closing balance
  • Ignoring tax implications under Section 115BBH (30% tax on Virtual Digital Asset transfers)
  • Treating crypto holdings as cash equivalents – inappropriate classification
Bare-Act text Schedule III · Companies Act, 2013 - Schedule III (as amended) · click to expand
Schedule III, Division I/II (as amended by MCA Notification dated 24 March 2021): Where the Company has traded or invested in Crypto currency or Virtual Currency during the financial year, the following shall be disclosed: (a) profit or loss on transactions involving Crypto currency or Virtual Currency; (b) amount of currency held as at the reporting date; (c) deposits or advances from any person for the purpose of trading or investing in Crypto Currency/virtual currency.
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