Crypto markets never close. Your financial report still has to pin every holding to one number on one day, and your auditor has to reach that same number without taking your word for it.
This series takes the audit one test at a time. Part 1 covered ownership, Part 2 covered existence and control. This part is value.
The requirement has not changed, only the asset
Regulation 8.02B of the SIS Regulations requires trustees to value all fund assets at market value when preparing the fund's financial statements and accounts each year. It applies to a Bendigo property and a Bitcoin holding in exactly the same way. We covered the other asset classes in an earlier post on reg 8.02B.
What changes with crypto is the evidence. No rates notice, no comparable sale, no registry statement. Just a price that moved while you were reading this sentence.
What the ATO accepts
The ATO is specific about the evidence. Holding statements or investment summaries alone are not sufficient to confirm market value. The auditor must obtain additional objective, supportable evidence. The ATO's own example is the 30 June closing value published on the website of a crypto exchange that provides historical data.
Every word there is doing work. Published. 30 June closing. An exchange that provides historical data, so the price can still be looked up when the audit happens months later.
What does not hold up
The ATO settles the first of these: holding statements alone are not sufficient to confirm market value. The rest is what we see fail in practice.
- A platform's year-end statement standing on its own
- A value taken from an app that does not publish its rates or its methodology
- A price with no date, no time and no source recorded
- A price in another currency converted at an unstated rate on an unstated day
Document three things, not one
The value itself is the least interesting part. What your auditor needs, to arrive at the same number independently, is:
- The source: which exchange or publisher, and the page it came from.
- The date and time: the 30 June closing price, with the time and time zone recorded.
- The conversion: if the published price is not in Australian dollars, the rate used and where it came from.
In practice that is a PDF of the page, saved on the day. Your auditor has to obtain sufficient appropriate evidence, meaning enough of the right kind, to form an opinion on compliance with Reg 8.02B, and to document it in the audit file. Valuing the asset is not the auditor's job. Evidence that existed at 30 June beats evidence reconstructed in March.
Funds that use the same source every year have an easier time of it. Prices differ between platforms, and a source that moves each year to whichever exchange gives the friendliest number is what we see undermine a valuation.
The hard cases
Mainstream assets are the easy part. In our own audit files, these are the ones that generate qualifications:
Thinly traded tokens. Where no reputable exchange publishes a reliable price, the auditor cannot solve that problem for the fund. What counts is a record of what was tried and what could not be obtained.
Staked or locked assets. The coins are committed to a protocol or tied up for a term, so the holding is real but not freely transferable at 30 June. The lock-up bears on liquidity as well as value.
Non-fungible tokens. A unique asset has no published closing price to point to. These are the ones where specific advice, well before year end, saves the most trouble.
Delisted or collapsed platforms. Where the platform has failed, the recoverable value is a genuine question, not a formality. Last year's figure rolled forward is not evidence of this year's value.
That last habit deserves a warning of its own. ATO data analysis identified over 16,500 SMSFs reporting assets at the same value for three consecutive years, many of them property, and it wrote to those funds and their auditors. Its own evaluation calls the campaign partially effective: around 63 per cent of funds changed property valuations, and 45 per cent changed unlisted trust investments. (More in our earlier post on the ATO's stale-value campaign.)
An unchanged value is not of itself a contravention. But in an asset class this volatile, it invites the question, and the answer has to be objective, supportable evidence.
What happens if the value cannot be supported
Where the auditor cannot verify that the fund's crypto is reported at market value, and the amount is material, the auditor qualifies both parts of the audit report. Part A covers the financial statements; Part B covers compliance with the super rules. Where the ATO's reporting tests are met, the auditor also lodges an Auditor Contravention Report with the ATO for a Reg 8.02B breach.
If a member is near the $3 million mark
Most funds can skip this. Division 296 tax applies from 1 July 2026, and it turns on a member's total super balance across every fund they belong to, not on the size of this one. The large super balance threshold is $3 million for the 2026-27 income year, and for that first year the balance is tested at year end. A member's balance is built from reported asset values, so a crypto valuation at 30 June can feed a tax calculation as well as an audit file.
Done on the day, with the source and the timestamp kept, valuation is rarely the part that holds up the audit.
Value settled, the last question is whether the investment was allowed at all. Part 4 takes the super laws.
SMSF Audit Group are independent, ASIC-registered SMSF auditors. To find out what valuation evidence your fund needs before 30 June, get in touch.