Getting your bitcoin treasury strategy right is only half the battle. The other half is how, and how often, you communicate it. This playbook distills what investors, auditors, and regulators expect, and it lays out simple, repeatable habits your IR team can implement right away.

1) Anchor on the new accounting baseline (ASU 2023-08)

Under FASB ASU 2023-08, in-scope crypto assets (including bitcoin) are measured at fair value with changes in earnings. The standard also expands disclosures (for example: name, quantity/units, cost basis, fair value, restrictions, and an annual roll-forward of aggregate holdings). Build your template around those items so every update feels complete and comparable.

What to publish each period:

• BTC units held (date-stamped)
• Diluted share count used for your per-share metrics
• Cost basis and period-end fair value
• Changes in the period (purchases, sales, impairments if any, reclasses)
• Any restrictions on use or transfer of the assets (e.g., collateral)

2) Explain custody in plain English, using regulator vocabulary

Investors want to know who holds the keys and how assets are protected. Borrow language from the strictest frameworks so your disclosure answers questions before they’re asked.

• Segregation & no rehypothecation. New York’s DFS guidance for virtual-currency custodians expects segregation of customer assets, clear sub-custody descriptions, and prominent customer disclosures. Even if you’re outside NY, mirroring its “segregation / limited use / sub-custody / disclosure” pattern sets a high bar.

The company’s 6,000 BTC target positions it alongside other corporate Bitcoin pioneers. Click to learn more.

• Banks re-entering custody. In 2025, the U.S. OCC clarified that national banks may provide crypto-asset custody (fiduciary or non-fiduciary) and related services; describe any bank or bank-linked trust you use, and how you oversee them.
• SAB-121 rescission. The SEC rescinded SAB 121 via SAB 122 in January 2025, easing a key accounting obstacle for banks safeguarding crypto, use that context when you explain why you selected a qualified custodian.

One-liner you can adapt:
“We safeguard our bitcoin with a regulated custodian under a segregated-asset model (no rehypothecation). If sub-custodians are used, we disclose them and monitor through SOC reports and service-level reviews.”

3) Publish investor-grade evidence, avoid PoR pitfalls

“Proof-of-reserves” posts aren’t a substitute for audits. The PCAOB has warned that PoR engagements are not audits and provide limited assurance. If you share transparency snapshots, label them accordingly and pair them with auditor-testable artifacts (e.g., wallet mappings, BIP-322 message signing, reconciliations).

Investors are watching closely as Matador Technologies channels $100M into Bitcoin. Click to learn more.

4) Make per-share transparency your north star

Raw “coins held” can mislead when equity is issued. Adopt Bitcoin-per-Share (BPS), BTC divided by diluted shares, as your headline KPI, and keep the denominator consistent across updates. In practice, the market rewards companies that grow BPS while explaining any financing that could dilute it.

Publish with context:

• BPS (with the diluted share count used)
• Acquisition cost vs. spot
• Financing activity (ATM, convertibles, facilities), and how it affects BPS going forward
• Custody summary (from §2)

Learn how Bitcoin enforces “rules, not rulers” in today’s financial system.

5) Establish a predictable disclosure cadence (and stick to it)

Markets value rhythm. Consider a monthly holdings update (press release + IR page) and a fuller quarterly package that ties ASU 2023-08 tables to your KPIs.

• Example cadence: MicroStrategy/Strategy routinely issues time-stamped purchase updates and folds treasury KPIs into earnings materials, investors know when to expect numbers and how to track progress.
  
• Example: Matador Technologies pairs facility news with ongoing holdings updates (e.g., a US$100M convertible-note facility with an initial US$10.5M tranche dedicated to BTC purchases, followed by purchase disclosures), creating a clean “fund → buy → disclose” narrative.

Bitcoin offers Canadians a hedge, an opportunity, and a technology worth understanding. Click to learn more.

6) Map your disclosures to where risk actually lives

A good transparency page (or IR appendix) should answer:

• Where is the bitcoin? Custodian name, regulatory status, and sub-custody summary.
• Who can move it? High-level wallet policy (e.g., multisig/MPC, dual control) without op-sec details.
• What could restrict use? Any liens, collateralization, or regulatory holds.
• How does accounting flow through? A short explainer that fair-value changes run through earnings under ASU 2023-08.

7) Use consistent, investor-friendly language

Replace crypto-native jargon with terms auditors and portfolio managers already use:

• “Segregated assets” instead of “not your keys, not your coins.”
• “Diluted share count” instead of “FDV math.”
• “Fair value through earnings (ASU 2023-08)” instead of “mark-to-market vibes.”

8) A reusable template for your next holdings update

Header: “Bitcoin Treasury Update ,  <Month DD, YYYY>”
Body (3 short paragraphs):

1. Units, cost basis, fair value (date-stamped), BPS with diluted shares.
2. Period activity: purchases/sales, any financing draws/issuance and the expected BPS impact, brief custody statement.
3. Forward look: policy reminders (e.g., target draw cadence, risk controls), and a link to your ASU 2023-08 disclosure tables on the IR site.

9) Bonus for CFOs: align ops with the policy environment

Communications are stronger when they reflect the operating reality:

• If you use a bank custodian or bank-linked trust, include a sentence on oversight consistent with the OCC’s 2025 clarifications.
• If you serve New York customers, echo NYDFS expectations on segregation and sub-custody in your disclosures.
• If you previously referenced SAB 121, update your language to reflect the SAB 122 rescission.

10) Checklist (clip this)

• Publish ASU 2023-08 tables and keep a monthly rhythm for holdings.
• Lead with BPS (diluted) and explain financing impacts clearly.
• Describe custody with regulator-grade terms (segregation, no rehypothecation, sub-custody).
• Avoid calling PoR “an audit;” label it clearly and pair with audit-ready evidence.
• If using bank custody, acknowledge OCC posture; if in NY, mirror NYDFS wording.

Getting your bitcoin treasury strategy right is only half the battle. The other half is how, and how often, you communicate it. This playbook distills what investors, auditors, and regulators expect, and it lays out simple, repeatable habits your IR team can implement right away.

1) Anchor on the new accounting baseline (ASU 2023-08)

Under FASB ASU 2023-08, in-scope crypto assets (including bitcoin) are measured at fair value with changes in earnings. The standard also expands disclosures (for example: name, quantity/units, cost basis, fair value, restrictions, and an annual roll-forward of aggregate holdings). Build your template around those items so every update feels complete and comparable.

What to publish each period:

• BTC units held (date-stamped)
• Diluted share count used for your per-share metrics
• Cost basis and period-end fair value
• Changes in the period (purchases, sales, impairments if any, reclasses)
• Any restrictions on use or transfer of the assets (e.g., collateral)

2) Explain custody in plain English, using regulator vocabulary

Investors want to know who holds the keys and how assets are protected. Borrow language from the strictest frameworks so your disclosure answers questions before they’re asked.

• Segregation & no rehypothecation. New York’s DFS guidance for virtual-currency custodians expects segregation of customer assets, clear sub-custody descriptions, and prominent customer disclosures. Even if you’re outside NY, mirroring its “segregation / limited use / sub-custody / disclosure” pattern sets a high bar.

The company’s 6,000 BTC target positions it alongside other corporate Bitcoin pioneers. Click to learn more.

• Banks re-entering custody. In 2025, the U.S. OCC clarified that national banks may provide crypto-asset custody (fiduciary or non-fiduciary) and related services; describe any bank or bank-linked trust you use, and how you oversee them.
• SAB-121 rescission. The SEC rescinded SAB 121 via SAB 122 in January 2025, easing a key accounting obstacle for banks safeguarding crypto, use that context when you explain why you selected a qualified custodian.

One-liner you can adapt:
“We safeguard our bitcoin with a regulated custodian under a segregated-asset model (no rehypothecation). If sub-custodians are used, we disclose them and monitor through SOC reports and service-level reviews.”

3) Publish investor-grade evidence, avoid PoR pitfalls

“Proof-of-reserves” posts aren’t a substitute for audits. The PCAOB has warned that PoR engagements are not audits and provide limited assurance. If you share transparency snapshots, label them accordingly and pair them with auditor-testable artifacts (e.g., wallet mappings, BIP-322 message signing, reconciliations).

Investors are watching closely as Matador Technologies channels $100M into Bitcoin. Click to learn more.

4) Make per-share transparency your north star

Raw “coins held” can mislead when equity is issued. Adopt Bitcoin-per-Share (BPS), BTC divided by diluted shares, as your headline KPI, and keep the denominator consistent across updates. In practice, the market rewards companies that grow BPS while explaining any financing that could dilute it.

Publish with context:

• BPS (with the diluted share count used)
• Acquisition cost vs. spot
• Financing activity (ATM, convertibles, facilities), and how it affects BPS going forward
• Custody summary (from §2)

Learn how Bitcoin enforces “rules, not rulers” in today’s financial system.

5) Establish a predictable disclosure cadence (and stick to it)

Markets value rhythm. Consider a monthly holdings update (press release + IR page) and a fuller quarterly package that ties ASU 2023-08 tables to your KPIs.

• Example cadence: MicroStrategy/Strategy routinely issues time-stamped purchase updates and folds treasury KPIs into earnings materials, investors know when to expect numbers and how to track progress.
  
• Example: Matador Technologies pairs facility news with ongoing holdings updates (e.g., a US$100M convertible-note facility with an initial US$10.5M tranche dedicated to BTC purchases, followed by purchase disclosures), creating a clean “fund → buy → disclose” narrative.

Bitcoin offers Canadians a hedge, an opportunity, and a technology worth understanding. Click to learn more.

6) Map your disclosures to where risk actually lives

A good transparency page (or IR appendix) should answer:

• Where is the bitcoin? Custodian name, regulatory status, and sub-custody summary.
• Who can move it? High-level wallet policy (e.g., multisig/MPC, dual control) without op-sec details.
• What could restrict use? Any liens, collateralization, or regulatory holds.
• How does accounting flow through? A short explainer that fair-value changes run through earnings under ASU 2023-08.

7) Use consistent, investor-friendly language

Replace crypto-native jargon with terms auditors and portfolio managers already use:

• “Segregated assets” instead of “not your keys, not your coins.”
• “Diluted share count” instead of “FDV math.”
• “Fair value through earnings (ASU 2023-08)” instead of “mark-to-market vibes.”

8) A reusable template for your next holdings update

Header: “Bitcoin Treasury Update ,  <Month DD, YYYY>”
Body (3 short paragraphs):

1. Units, cost basis, fair value (date-stamped), BPS with diluted shares.
2. Period activity: purchases/sales, any financing draws/issuance and the expected BPS impact, brief custody statement.
3. Forward look: policy reminders (e.g., target draw cadence, risk controls), and a link to your ASU 2023-08 disclosure tables on the IR site.

9) Bonus for CFOs: align ops with the policy environment

Communications are stronger when they reflect the operating reality:

• If you use a bank custodian or bank-linked trust, include a sentence on oversight consistent with the OCC’s 2025 clarifications.
• If you serve New York customers, echo NYDFS expectations on segregation and sub-custody in your disclosures.
• If you previously referenced SAB 121, update your language to reflect the SAB 122 rescission.

10) Checklist (clip this)

• Publish ASU 2023-08 tables and keep a monthly rhythm for holdings.
• Lead with BPS (diluted) and explain financing impacts clearly.
• Describe custody with regulator-grade terms (segregation, no rehypothecation, sub-custody).
• Avoid calling PoR “an audit;” label it clearly and pair with audit-ready evidence.
• If using bank custody, acknowledge OCC posture; if in NY, mirror NYDFS wording.