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Company crypto treasury: questions before getting started

Practical guidance for companies and directors. Revised on 7 September 2026.

Original article: 2025-12-16 · HODL Consulting

Company crypto treasury: questions before getting started

Separate the business project from personal assets

Investing through a company starts with a documented management decision. The bank balance alone does not measure available cash: some funds may already be needed for salaries, suppliers, taxes or committed investment.

Identify the funds and their owner

Specify the purchasing entity, source of funds and objective. An operating company, a holding company and its director personally are separate holders. A shareholder current account also represents a relationship between the shareholder and company; it should not be confused with equity or money invested personally.

Review the corporate purpose, decision-making powers, financing commitments and activity-specific rules. Regulated professions and particular structures require their own assessment. A platform accepting a corporate account application does not validate the company’s investment decision.

Example: available today may be needed tomorrow

Suppose an SME has €150,000 in its bank account. It expects €60,000 of near-term expenses, €30,000 of equipment spending and a €40,000 operating reserve. That leaves €20,000 before unforeseen events. This is not an allocation recommendation; it illustrates why a cash forecast should precede the decision.

Define the time horizon, exit conditions and ability to withstand a loss or prolonged unavailability. Holding company projects and medical practices require additional questions about structure and funding.

Prepare a documented decision

A written policy connects transactions to the original decision and identifies who acts when circumstances change. It can remain simple, provided it is usable.

  • Scope: permitted transactions, proposed assets, providers and custody arrangements.
  • Responsibilities: people authorised to initiate and approve transactions, limits and access reviews.
  • Liquidity: euro-denominated needs to preserve, withdrawal times and an unavailability scenario.
  • Monitoring: reconciliation frequency, escalation of discrepancies and information provided to management.
  • Continuity: procedures for staff departure, lost access or incidents, without exposing secrets in accounting files.

Provider checks should identify the legal entity and relevant services, not just the brand. Also examine export quality, access to historical records, fees and contractual terms. Our platform verification guide explains this process.

Holding, lending and staking are different activities

An income-producing arrangement may introduce a counterparty, lock-up, restitution right or protocol-specific risk. Document what the contract actually permits, the assets transferred and income received. A displayed yield describes neither fund availability nor the net result after fees and changes in value.

Connect transactions to the accounts

Open accounts in the correct entity’s name and identify business wallets. For each transaction, retain the date, asset, quantity, countervalue, fees, supporting record and source. Reconcile internal transfers so they are not mistaken for new purchases or revenue.

Classify before recording

Accounting treatment depends on the asset’s rights, its use and the entity’s framework. It is not a free choice between inventory, fixed assets and cash. ANC Regulation 2026-01 was endorsed by the order of 12 August 2026, published in the French Official Journal on 3 September. Article 9 provides for financial years beginning on or after 1 January 2027, with early application permitted for the financial year in progress at publication.

Preparation means inventorying positions, documenting methods and identifying first-application effects. Our ANC 2026 guide helps organise this review. Source: endorsement order and regulations.

Company taxation and the director’s position

The private capital-gains flat tax and form 2086 are not the standard regime for a company treasury subject to French corporate income tax. Company transactions and a subsequent distribution to the director require separate assessments. Disposals, exchanges and protocol income need classification; the absence of conversion to euros does not establish tax neutrality.

Frequently asked questions

Is a holding company necessary? Not automatically. Compare objectives, costs, constraints and relationships with existing companies before creating another entity.

Can the director’s personal crypto account be used? Organise accounts and supporting records that clearly identify the company as owner. If transactions have already been mixed, reconstruct the situation before continuing.

What documents should we prepare? Statutes, recent accounts, a cash forecast, source of funds, account and wallet lists, available history and the proposed transactions.

Company tax and the director’s tax

The private capital-gains flat tax and form 2086 are not the standard regime for a corporate-income-tax company’s treasury. Distributions to a director require a separate assessment from company transactions. Bring the statutes, recent accounts, source of funds and transaction flow chart to your initial meeting.