DeFi for businesses: understanding transactions and preparing the accounting
Published 19/09/2023 · Updated 08/09/2026 · Houssen Issouf Aly, French chartered accountant
Crypto-assets · Companies · Directors
Practical guidance for companies and directors. Revised on 7 September 2026.
Describe the actual transaction
“Using DeFi” does not identify a contract or an accounting entry. Distinguish swaps, lending, borrowing, liquidity provision, rewards and movements between networks. Each step may change the business’s assets, rights or obligations.
The ACPR’s April 2023 discussion paper distinguishes infrastructure, application and access risks, including concentration and technical dependencies. It is a dated analysis with regulatory proposals, not itself a set of new binding rules for 2026.
Keep an operation record
Identify the asset owner, network, addresses, interface, protocol and version where available. Explain what is sent, received, committed or owed. Keep transaction references, dates and supporting records.
- Swap: quantities exchanged, fees and valuation evidence.
- Lending or borrowing: rights, repayment, collateral and liquidation conditions.
- Liquidity: contributed assets, position representation, withdrawals and income.
- Rewards: origin, entitlement conditions and availability.
- Cross-network movement: departure, arrival, timing and fees.
A transaction reference supports investigation but does not alone establish economic ownership, purpose or tax treatment. A screenshot without history may not reconstruct the position.
Separate technical review from management approval
Explain who authorises the operation, what is exposed and how it will be monitored. Obtain competent review of contracts, permissions, dependencies and exit conditions. Read a technical audit with its date, scope and limitations; its existence cannot prove absence of risk.
Do not use historical returns as certain cash-flow assumptions. Rewards and asset values can change. Compare claimed availability with actual withdrawal conditions and company payment needs.
Assign monitoring, review triggers and incident responsibilities. These processes organise decisions; they do not guarantee capital or recovery.
Reconcile positions at closing
Start with opening quantities, add inflows and subtract outflows by asset and network. Connect movements to evidence and explain closing balances. Distinguish wallet balances from protocol positions without double counting exposure.
Accounting classification depends on actual rights and obligations and the framework applicable to the entity and financial year. A received token’s name cannot determine the account automatically. Document judgements, prices and missing data.
Fictional example: a wallet sends 100 units and receives a token representing a position. Treating the original units as simply missing, or adding both representations without analysis, may distort the records. Explain the mechanism and rights before proposing entries.
Practical questions
Does software execution determine the law?
It does not alone settle applicable law, ownership or remedies. Those questions need separate analysis.
Does accounting require private keys?
No transfer authority is required for suitable evidence, exports and read-only access.
Where should we begin?
Bring a complete transaction and position inventory. Read the wallet guide, ANC guide and software guide. Our accounting engagement can define the file and controls.