## The Recording of Fungible Crypto Assets in Macroeconomic Statistics (approved final version)

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### Background and typology of fungible crypto assets
- IMF and OECD engagement:
  - IMF and OECD began exploring statistical measurement of crypto assets in 2018; IMF paper in 2019 and OECD proposals in 2020 informed classification efforts.
- Definition and primary focus:
  - Crypto assets: digital representations of value relying on cryptography and decentralized peer-to-peer architecture based on distributed ledger technology (DLT).
  - Fungible crypto assets: divisible and not unique — GN focuses on fungible crypto assets.
- Broad typology (three categories and subcategories):
  - Crypto assets designed to act as a general medium of exchange:
    - With a corresponding liability:
      - Issued by a monetary authority (e.g., CBDCs that qualify as crypto assets).
      - Not issued by a monetary authority (e.g., stablecoins with a claim on the issuer).
    - Without a corresponding liability (CAWLM) (e.g., Bitcoin and stablecoins without a claim on the issuer such as Terra).
  - Crypto assets that act as a medium of exchange within a platform or network (payment tokens):
    - With a corresponding liability.
    - Without a corresponding liability (CAWLP).
  - Security tokens (always have a counterpart liability):
    - Debt security crypto assets (e.g., Bond-i).
    - Equity crypto assets (such as Meridio).
    - Derivative crypto assets.

### General consensus on classification of fungible crypto assets
- Asset boundary:
  - All fungible crypto assets meet the asset boundary: holders have ownership rights, they act as a store of value, can be exchanged for goods and services, and provide economic benefits and risks to the holder.
- Consensus classification for crypto assets with corresponding liability:
  - Debt security crypto assets → recorded as debt securities.
  - Equity crypto assets → recorded as equity.
  - Derivative crypto assets → recorded as financial derivatives.
  - Payment tokens with a corresponding liability → negotiable instruments/evidence of debt; may warrant a separate subcategory.
  - Crypto assets designed as a general medium of exchange with corresponding liability:
    - Issued by a monetary authority → classified as currency.
    - Issued by a non-monetary authority → recorded under a new, distinct financial asset category.
- Algorithmic stablecoins without a corresponding liability are identified as a type of CAWLM.

### Issue 2a — Are CAWLM financial or nonfinancial assets? Two main statistical approaches
- Definitions and precedent:
  - Financial assets generally require a corresponding claim on another institutional unit (2008 SNA paragraph 11.8; MFSMCG paragraphs 4.5–4.6).
  - The only financial asset in the 2008 SNA explicitly without a corresponding liability is monetary gold.
- CAWLM characteristics:
  - Hybrid features: designed as a medium of exchange but lack a corresponding liability.
  - Often used as store-of-value with high volatility rather than broadly as money.
- Approach 1 — Treat CAWLM as a new type of nonfinancial asset (arguments):
  - Consistency with the counterpart liability criterion: absent direct counterpart liability, CAWLM would not fit financial asset definition.
  - Precedent caution: extending monetary gold exception risks inconsistency and could prompt other commodities to be treated as financial assets.
  - Practical considerations: treating CAWLM as financial without strong justification could create inconsistencies between recorded financial assets and recorded liabilities worldwide.
  - Market role: current primary role appears to be store-of-value with high volatility; therefore a strong justification for an exception similar to monetary gold does not presently exist.
- Approach 2 — Treat CAWLM as financial assets (rationale and concerns discussed elsewhere in GN).

### Criteria for CAWLM to qualify as money (Annex III framing and Table 1 example)
- CAWLM may qualify as money and be treated as financial assets if they meet monetary criteria (MFSMCG paragraph 6.11) and the GN’s listed conditions:
  - be issued or authorized by the government,
  - be a generally accepted means of payment,
  - be a reliable or stable store of value (in the short-term),
  - be a unit of account,
  - be a widely used medium of exchange.
- Example assessment for Bitcoin (criteria responses preserved exactly):
  - Authorized by the government — TRUE — Bitcoin could be legal tender by law.
  - Accepted as means of payment — TRUE — A government can require by law the acceptance of Bitcoin by merchants as a means of payment, including the possibility of paying taxes with Bitcoin.
  - Reliable store of value — FALSE — Bitcoin is very volatile to be considered a reliable or stable store of value.
  - Unit of account — FALSE — Bitcoin is not used to price goods or services offered in any country yet.
  - Widely used as a medium of exchange — FALSE — Due to its limited supply, expected appreciation, and high volatility, Bitcoin is mostly held as a long-term store of value investment rather than a medium of exchange (acquisition of goods and services in exchange for Bitcoin).
  - Conclusion — FALSE — Bitcoin is not money for macroeconomic statistics.
- Conditional future change:
  - If a CAWLM satisfies the criteria and meets the definition of broad money, consideration should be given to treating CAWLM as financial assets by making an exception to the counterpart liability criterion.
  - If CAWLM is money in a particular country, holdings by residents in that country should be included in money aggregates.

### Treatment as valuables vs. financial assets and hybrid-assets discussion
- Valuables route:
  - CAWLM do not meet current valuables definition; GN suggests either adjusting valuables definition or creating a new subclass “digital valuables” under nonfinancial assets reflecting price volatility, intangibility, and limited availability.
- Exception route:
  - Alternative approach: create an additional exception to counterpart liability and treat CAWLM as financial assets (analogous to monetary gold exception). Monetary gold exception rationale: role as reserve asset historically in balance of payments financing and confidence.
- Hybrid-assets option (considered and rejected by BOPCOM and AEG in March 2022):
  - Proposal: new asset class “hybrid assets” reflecting both financial and nonfinancial features.
  - Rejection reasons and implications documented; hybrid approach kept for information but not adopted.

### Issue 2b — Accounting for creation/production activities of CAWLM (mineable vs non-mineable)
- Creation mechanisms:
  - Mineable CAWLM (proof-of-work): enter circulation via miners solving cryptographic puzzles; mining requires software, IP for algorithms, specialized computing equipment, considerable energy, and time.
  - Non-mineable CAWLM: enter circulation via explicit sales or payments to validators (proof-of-stake, proof-of-authority); designer chooses issuance mechanism.
- Validation/creation as production:
  - Miners/validators use intermediate goods and services, labor, and capital — a production activity.
  - Key difference: proof-of-work requires significantly more intermediate inputs and energy than proof-of-stake.
- Example miner technical specification preserved:
  - Bitmain AntMiner S9: hash rate of 14 TH/s and capacity to mine 0.03600399 Bitcoin per month.
- Two alternatives for recording production activities:
  - Approach 1 — Regard CAWLM as produced assets:
    - Rationale: new CAWLM arise from miners’ work or designers’ issuance; miners receive new CAWLM; outputs include explicit validation fees (consumed services) and newly mined CAWLM (capital formation).
    - Advantages: straightforward and easily implementable.
    - Challenges if not regarded as produced: assumptions on initial ownership/allocation of new coins and potential negative value added for mining entities.
  - Approach 2 — Regard CAWLM as non-produced assets:
    - Alternatives: new CAWLM brought into circulation by miners but not as result of production, or initial ownership attributed to designers/holders.
    - Practical difficulties: identifying initial owners, attributing consumption of validation services, bilateral asymmetry risks.

### Options considered for CAWLM classification (Issues 2a and 2b)
- Option I — Produced Nonfinancial Assets:
  - CAWLM are nonfinancial assets produced by miners (mineable) or creators/issuers (non-mineable); expenditure counterpart is capital formation by producers.
  - Pros: consistent with counterpart liability criterion (except monetary gold), consistent with current international accounting standards and some regulators, adds to capital formation.
  - Requires updating categories of produced nonfinancial assets (e.g., valuables).
- Option II — Non-Produced Nonfinancial Assets:
  - CAWLM are nonfinancial assets “released” via other changes in the volume of assets and distributed to new owners in exchange for validation services.
  - Pros: consistent with counterpart liability criterion; consistent with view miners do not produce coins but receive them for validation services; ensures consistent recording across validation types and modes of circulation.
  - Adds to production and consumption/trade in services; may require expanding categories of non-produced nonfinancial assets; practical implementation may require assumptions on counterpart of implicit validation fee.
- Option III — Financial Assets:
  - CAWLM treated as financial assets “released” via other changes in the volume of assets and distributed to new owners in exchange for validation services.
  - Pros/Cons: inconsistent with counterpart liability criterion (would require adding an exception, risking other commodities being regarded as financial assets); holdings may increase a country’s net financial position without a counterparty, creating inconsistencies globally.
  - Adds to production and consumption/trade in services; implementation may require assumptions on counterpart of implicit validation fee and risks bilateral asymmetries.

### Consultation outcomes and editorial/committee decisions
- GFS community consultation (total responses: 11):
  - Forty five percent (five respondents) preferred classifying CAWLM as nonfinancial assets.
  - 27 percent (three respondents) preferred classifying CAWLM as financial assets.
  - 18 percent (2 respondents) did not express any preference.
  - One respondent preferred a hybrid option (not presented in GN/GFS questions).
  - Of those preferring nonfinancial assets: three supported produced nonfinancial treatment; two supported non-produced nonfinancial treatment.
  - One respondent preferring financial assets also expressed some preference for hybrid treatment.
- Broader global consultation (January 28—February 25, 2022): 42 respondents representing 35 economies.
  - User consultation showed most respondents supported treating CAWLM as nonfinancial assets (within nonproduced assets).
- Committee and AEG decisions (March 2023):
  - To treat non-liability crypto assets (CAWLM and CAWLP) as non-produced non-financial assets—within a separate category—in the 2025 SNA and BPM7.
  - Additional recommendations:
    - Monitor developments and review recommendations if significant market/regulatory/accounting changes arise.
    - Retain the issue in SNA and BPM research agendas.
    - Develop communication and guidance on identification, borderline cases, and recording of flows/stocks.
    - Develop practical guidance on data sharing to facilitate compilation of crypto assets flows/stocks.

### Data collection, data sharing, and implementation guidance (Annexes V–VI)
- Core data collection recommendations:
  - Collect information on ownership, creation, and use of crypto assets in domestic economy and cross-border transactions.
  - Testing countries should collect data on CAWLM ownership and transactions from households, corporations, government, and non-profit entities.
  - Drafting team recommends countries share collected crypto assets data via international organizations to help resolve asymmetries and fill missing information.
- Core data items to collect (paragraph 72 items preserved):
  - Stock of crypto assets owned by resident institutional sectors and changes in these stocks (financial transactions, revaluations, other changes), including cross-border flows and positions, ideally broken down by counterpart country.
  - Data on creation of crypto assets: transaction fees broken down into explicit fees and block rewards paid to/received by miners and validators; other forms of bringing new coins into circulation; input costs (e.g., labor, machinery, electricity).
  - Data on use of crypto assets: use in purchasing goods and services by sector and use as an alternative investment.
- Target entities and specific data items (paragraph 74 summary):
  - Tax authorities: ownership at beginning/end of period; gains/losses from holding and selling crypto assets.
  - Retailers accepting crypto payments: use and receipt of crypto assets (domestic vs non-resident).
  - Mining enterprise/validation provider: holding gains/losses, input costs (electricity, equipment, employment, labor costs), receipt of transaction fees (explicit fees, block reward), sale of crypto assets.
  - Crypto asset designer: value of coins held, release of new coins during period, input costs.
  - Crypto asset exchange/trading platform/wallet: use, creation, revaluation, purchase/sale data, stocks held by residents/non-residents.
- Suggested simplified data collection exercise for Monetary and Financial Statistics and BOP/IIP:
  - Target resident wallet providers and resident currency exchanges for positions and transactions data.
  - For nonresident providers used by residents, collect estimates via surveys of resident holders if direct data are not available.
  - Collect aggregated holdings by institutional sector and aggregated cross-border transactions by type and counterpart.
  - Track whether CAWLM is used as a means of payment only or as a medium of exchange (positions held vs immediate conversion).
- Example Bitcoin-mining questionnaire fields (paragraph 42 preserved units and items):
  - Number of Bitcoins mined during the period — Units.
  - Value of Bitcoins mined (at price of the day of the transaction) — USD.
  - Explicit Fee received for validating the transactions (in Bitcoins) — Value — Units — USD.
  - Input costs related to mining/validation services — USD (electricity, maintenance, labor, other).
  - Use of Bitcoins — sold to resident exchanges, sold to nonresident exchanges, transferred to head office, payments for goods and services, other (number, value, units, USD).

### Numerical examples and accounting implications (selected exact figures preserved)
- Example 1: Cross-border purchase of goods:
  - Country B purchases units of CAWLM from Country C for US$100.
  - Country B imports goods of US$80 from Country A and pays with CAWLM.
  - Recording impacts:
    - Goods exporter (Country A): Current account balance under different treatments: Valuable: 0; Permits: +80; Financial Asset: +80; Hybrid Asset (Model 1): +80.
    - Goods importer (Country B): Current account balance: Valuable: -100; Permits: -80; Financial Asset: -80; Hybrid Asset: -80.
    - CAWLM seller (Country C): Current account balance: Valuable: +100; Permits: 0; Financial Asset: 0; Hybrid Asset: 0.
- Example 2: Use of CAWLM as alternative investment:
  - Country B purchases units of CAWLM from Country A for US$100.
  - Country B holds CAWLM; value increases to US$120.
  - Recording impacts:
    - CAWLM seller (Country A): Current account balance under different treatments: Valuable: +100; Permits: 0; Financial Asset: 0; Hybrid Asset (Model 1): 0.
    - CAWLM holder (Country B): Change in net worth across all treatments: +20; Change in stock of nonfinancial assets under Valuable or Permits: +120; Change in stock of financial assets when CAWLM are financial assets: +20.
- Example 3.A (Mineable coin miner example exact figures):
  - Country B final consumer pays a transaction fee of US$10 in existing CAWLM.
  - Country A miner receives US$90 in new CAWLM as Block reward.
  - Miner incurs US$80 electricity cost.
  - Across recording options, Miner: Net Value Added = +20; Net Saving = +20; Net lending/borrowing varies by treatment (e.g., -80 under Valuable Permits and Financial Asset; +20 under Hybrid Asset Model 1).
- Example 3.B (Non-mineable coin/proof-of-stake example exact figures):
  - Country B final consumer pays a transaction fee of US$10 in existing CAWLM.
  - Country A entity receives US$15 in new CAWLM as Block reward.
  - Entity incurs US$5 electricity cost.
  - Entity: Output of validation services = 25; Net Value Added = 20; Net Saving = 20; Net lending/borrowing varies (e.g., -5 under Valuable Permits and Financial Asset; +20 under Hybrid Asset Model 1).
- GN conclusion on accounting impacts:
  - Different recording options do not change net value added; they change composition/type of output and accounting treatment of flows and stocks.
  - Recording CAWLM as financial assets vs nonfinancial or hybrid assets affects revaluations’ impact on the IIP, net lending/borrowing, and distribution of stocks across asset categories.
  - Overall net worth remains the same across recording options (subject to GN assumptions).

### Measurement challenges, data exchange, and next steps
- Key measurement challenges (paragraph 62 exact concerns summarized):
  - Pseudo-anonymity of transactions despite ledger recording.
  - Difficulty assigning geography/residency when digital address owners are unknown.
  - Difficulty valuing positions and separating flows from valuation changes due to high price variance.
  - Lack of comprehensive data on economic use domestically and internationally.
- Data-sharing and international coordination:
  - GN recommends exploring data sharing from crypto exchanges and service providers across countries to improve data quality and consistency.
  - Paragraph 70/71 scenarios on CBDC data sharing:
    - Scenario 1: Five countries issue CBDC by end of 2021 and report holders’ data to a central IMF-based unit; compilers elsewhere use the central database to identify CBDC holdings by residents.
    - Scenario 2: No central database; bilateral arrangements needed; small, low-income countries face burdens contacting CBDC issuers; complications amplified when issuers do not collect/share data.
- Recommended next steps:
  - Monitor market, regulatory, and accounting developments and review recommendations if warranted.
  - Retain issue in SNA and BPM research agendas.
  - Countries should begin collecting data necessary to measure transactions and stocks and compile related statistics.
  - A testing phase with volunteer countries/entities is recommended to assess practical challenges and aggregate impacts (preferred volunteers include countries with significant mining activity, many exchanges/wallet providers, intensive users of crypto assets, and large enterprises accepting crypto payments).

*International Monetary Fund Guidance Note, "The Recording of Fungible Crypto Assets in Macroeconomic Statistics" (approved final version).*

### SECTION I: THE ISSUE

### SECTION I: THE ISSUE

### BACKGROUND
- The IMF and the OECD started to explore the statistical measurement of crypto assets in 2018, with discussions at the IMF’s Committee on Balance of Payments Statistics, the OECD Working Party on Financial Statistics (WPFS), and the Advisory Expert Group (AEG) on National Accounts.
- An IMF paper was published in 2019 in consultation with the AEG; the OECD published updated proposals in 2020 to address new types of crypto assets.
- Crypto assets are digital representations of value that rely on cryptography and decentralized peer-to-peer architecture based on distributed ledger technology (DLT).
- Crypto assets are divided into fungible (divisible and not unique) and non-fungible (unique and non-divisible); this guidance note focuses on fungible crypto assets.
- Remaining classification discussion centers on:
  - Crypto assets designed to act as a general medium of exchange without a corresponding liability (CAWLM).
  - Crypto assets designed to act as a medium of exchange within a platform only, without a corresponding liability (CAWLP).
- The guidance note (GN) presents current consensus on most fungible crypto assets and discusses three recording options (with pros and cons) for CAWLM and CAWLP, using CAWLM as the primary focus because CAWLP follows the same reasoning.
- Macro-statistical classification should primarily follow macroeconomic statistics principles but also consider arguments from monetary authorities, financial regulators, and international financial institutions (including BIS and IMF); Annex I summarizes IMF user perspectives based on a recent consultation.

### ISSUES FOR DISCUSSION
- Issue 1: Typology of fungible crypto assets — importance of developing a sufficiently granular classification, building on IMF (2019) and OECD (2020) proposals.
- Issue 2: Classification of fungible crypto assets — whether certain crypto assets are financial or nonfinancial, and how to account for their creation.

### TYPology OF FUNGIBLE CRYPTO ASSETS
- Current broad grouping into three categories:
  - Crypto assets designed to act as a general medium of exchange:
    - with a corresponding liability:
      - issued by a monetary authority (e.g., central bank digital currencies (CBDCs) that qualify as crypto assets)
      - not issued by a monetary authority (e.g., stablecoins with a claim on the issuer)
    - without a corresponding liability (CAWLM) (e.g., Bitcoin and stablecoins without a claim on the issuer such as Terra)
  - Crypto assets that act as a medium of exchange within a platform or network (payment tokens):
    - with a corresponding liability
    - without a corresponding liability (CAWLP)
  - Security tokens (which always have a counterpart liability):
    - Debt security crypto assets (e.g., Bond-i)
    - Equity crypto assets (such as Meridio)
    - Derivative crypto assets (derivative contracts that rely on cryptography and can be exchanged peer-to-peer)

- Hybrid tokens are not given a separate category; hybrid assets should be classified into one of the other categories according to their main characteristics.

### CLASSIFICATION OF FUNGIBLE CRYPTO ASSETS — GENERAL CONSENSUS
- All fungible crypto assets meet the asset boundary because holders have ownership rights, they act as a store of value, can be exchanged for goods and services, and provide economic benefits and risks to the holder.
- Consensus on assets with a corresponding liability:
  - Debt security crypto assets → recorded as debt securities.
  - Equity crypto assets → recorded as equity.
  - Derivative crypto assets → recorded as financial derivatives.
  - Payment tokens with a corresponding liability → negotiable instruments serving as evidence of debt; may warrant a separate subcategory given differences from traditional debt securities.
  - Crypto assets with corresponding liability designed as a general medium of exchange:
    - Issued by a monetary authority → classified as currency.
    - Issued by a non-monetary authority → recorded under a new, distinct financial asset category separate from traditional currency and deposits.
- Algorithmic stablecoins without a corresponding liability aim to maintain a stable value via supply-adjustment protocols and are a type of CAWLM.

### ISSUE 2a: ARE CAWLM FINANCIAL OR NONFINANCIAL ASSETS?
- Definitions and precedents:
  - Financial assets generally require a corresponding claim on another institutional unit (2008 SNA paragraph 11.8; MFSMCG paragraphs 4.5–4.6).
  - The only financial asset in the 2008 SNA explicitly without a corresponding liability is monetary gold.
  - Nonfinancial assets derive value from use in production activities, except valuables (produced goods of considerable value held as stores of value; 2008 SNA paragraphs 10.13 and 9.57).
- CAWLM characteristics:
  - Exhibit hybrid features: designed to act as a medium of exchange (financial-like) but lack a corresponding liability (nonfinancial-like).
  - Appear as an immature and evolving asset class with features of both financial and nonfinancial assets.
- Two primary statistical approaches are possible for CAWLM.

Approach 1: Treatment of CAWLM as a New Type of Nonfinancial Asset
- Arguments for nonfinancial classification:
  - Consistency with the counterpart liability criterion: absent a direct counterpart liability, CAWLM would not fit the definition of financial assets.
  - Precedent caution: Monetary gold is a long-standing, historically justified exception; extending a similar exception to CAWLM risks inconsistency and could prompt other commodities (e.g., silver, nonmonetary gold) to be treated as financial assets.
  - Practical consideration: Treating CAWLM as financial without strong justification could create inconsistencies between recorded financial assets and recorded liabilities worldwide.
  - Current primary role in markets appears to be store-of-value with high volatility rather than functioning broadly as money; therefore strong justification for another exception (akin to monetary gold) does not presently exist.
- Historical context cited:
  - Monetary gold’s exception is rooted in its role in international payments and reserves at the IMF’s founding era (decisions and practices dating from 1944 and the first Balance of Payments Manual, published in 1948).
  - Monetary gold’s liquidity, return, and safety characteristics underpinned its treatment as a financial asset without a counterpart liability.

*Source: IMF guidance note SECTION I: THE ISSUE (focusing on the recording of fungible crypto assets in macroeconomic statistics).*

### Annex III for information purpose.

### f18-the-recording-of-fungible-crypto-assets-in-macroeconomic-statisticsapproved-final-version - Annex III for information purpose.

### Overview and key framing
- National net worth at the consolidated level is equal to the sum of nonfinancial assets, monetary gold, and the net claim on non-residents; financial assets do not add to the wealth of a nation unless CAWLM are considered an exception.
- If CAWLM were treated as an exception, net worth would become equal to the sum of nonfinancial assets, monetary gold, net claims on non-residents, and CAWLM.
- The demand for CAWLM as a new investment asset is currently relatively high compared with their use to purchase goods and services; some retailers accept CAWLM but actual uptake seems limited.
- Some financial policy makers and financial sector experts view the future of digital money as favoring stablecoins with counterpart liability (private digital money) and CBDCs (public digital money).

### Assessment of CAWLM relative to money concepts
- Argument: CAWLM could be treated as a type of valuable (a new subclass “digital valuables” under nonfinancial assets) unless evidence shows they act as a general medium of exchange.
- Distinctive feature of CAWLM analogous to precious metals/stones: limited number of units that can be mined (they are exhaustible after a certain period).
- From a monetary statistics perspective, instruments meeting the definition of broad money share low volatility; CAWLM lack low volatility, often by design (e.g., fixed supply such as Bitcoin).

### Criteria for CAWLM to qualify as money (and hence as financial asset)
- When a CAWLM has a stable value and is a widely accepted medium of exchange, it may meet the definition of broad money in the MFSMCG (paragraph 6.11) and be considered a financial asset.
- For CAWCLM to qualify as money and be accepted as a financial asset, it should meet these criteria:
  - be issued or authorized by the government,
  - be a generally accepted means of payment,
  - be a reliable or stable store of value (in the short-term),
  - be a unit of account,
  - be a widely used medium of exchange.
- Table 1 example assessment for Bitcoin (criteria response and explanation preserved exactly):
  - Authorized by the government — TRUE — Bitcoin could be legal tender by law.
  - Accepted as means of payment — TRUE — A government can require by law the acceptance of Bitcoin by merchants as a means of payment, including the possibility of paying taxes with Bitcoin.
  - Reliable store of value — FALSE — Bitcoin is very volatile to be considered a reliable or stable store of value.
  - Unit of account — FALSE — Bitcoin is not used to price goods or services offered in any country yet.
  - Widely used as a medium of exchange — FALSE — Due to its limited supply, expected appreciation, and high volatility, Bitcoin is mostly held as a long-term store of value investment rather than a medium of exchange (acquisition of goods and services in exchange for Bitcoin).
  - Conclusion — FALSE — Bitcoin is not money for macroeconomic statistics.

### Current recommended classification and conditional future change
- As CAWLM do not have counterpart liability and currently presumably act mostly as a means of payment (and not as a medium of exchange), it is sensible to classify them as nonfinancial assets at this point in time.
- If in future any CAWLM satisfies the criteria in Table 1 and meets the definition of broad money, consideration should be given to treating CAWLM as financial assets by making an exception to the counterpart liability criterion.
- Note: If a CAWLM meets the criteria for money in a particular country, holdings by residents in that country should be included in money aggregates to ensure accurate money supply estimates.

### Treatment as valuables vs. financial assets
- CAWLM do not meet the current definition of valuables; either the valuables definition needs adjustment or a new subclass of digital valuables should be created under nonfinancial assets reflecting price volatility, intangibility, and limited availability.
- Alternative approach: create an additional exception to the counterpart liability criterion and treat CAWLM as financial assets (analogous to the monetary gold exception).
  - Monetary gold exception rationale: role as reserve asset for balance of payments financing, exchange market intervention, maintaining confidence, and as basis for foreign borrowing (BPM6, paragraph 6.64).
  - PSDS Guide rationale: monetary gold bullion is treated as financial asset because it “provide[s] economic benefits by serving as a store of value and can be used as a means of payment to settle financial claims and finance other types of transactions” (PSDS, paragraph 3.12).
- Fiat currency may be viewed as a different kind of exception to counterpart liability because its claim is often conventional; unlike CAWLM, fiat is issued by monetary authorities and endorsed by governments.
- Public trust in CAWLM derives from technology and miner/validator networks and degree of integration with the financial system, differing from trust in fiat currency rooted in economic fundamentals.

### Implications of classification choices
- CAWLM derive value from expectations of acting as a medium of exchange or alternative to traditional financial instruments; they do not derive intrinsic value from production uses as do most nonfinancial assets, nor from artistic/sentimental reasons as valuables.
- If recorded as produced nonfinancial assets and then used as medium of exchange, not treating CAWLM as financial assets would produce barter recording implications for current account balances and net lending/net borrowing, though current impact is expected to be relatively small.
- Recommendation if CAWLM are recorded as financial assets:
  - Record CAWLM in a separate asset class to distinguish them from other financial assets, given the absence of formal backing and distinct characteristics compared with fiat currencies and traditional financial asset types.
  - Broaden financial asset coverage and create a new subclass reflecting CAWLM properties.

### Issue 2b — Accounting for creation/production activities of CAWLM
- Most mineable CAWLM enter circulation via miners solving cryptographic puzzles (proof-of-work) and validating transactions; mining requires software, intellectual property for algorithms, specialized computing equipment, considerable energy (for run and cooling), and time.
- Non-mineable CAWLM enter circulation via explicit sales (e.g., how Ether was launched) and/or as payment to validators using proof-of-stake or proof-of-authority; designer chooses the issuance mechanism.
- The validation/creation process is a production activity because miners/validators use intermediate goods and services, labor, and capital.
- Key difference: mineable CAWLM (proof-of-work) require significantly more intermediate inputs and energy than validation processes for non-mineable CAWLM (proof-of-stake), which may not require specialized computing equipment and generally require less energy.

### Two alternatives for recording production activities
- Approach 1 — Regard CAWLM as produced assets:
  - Rationale: New CAWLM come into existence from miners’ work or from designers/issuers; miners who solve the puzzle receive CAWLM; designers of non-mineable coins are responsible for creation when issued via explicit sale.
  - For mineable CAWLM, miners using highly efficient machines (e.g., Bitmain AntMiner S9) have higher chances of producing new CAWLM.
  - Bitmain AntMiner S9 technical specification example preserved: hash rate of 14 TH/s and capacity to mine 0.03600399 Bitcoin per month.
  - Output of miners considered to consist of two components: an explicit validation fee (treated as consuming services) and newly mined CAWLM (which would constitute capital formation in the national accounts).
  - Advantages: straightforward and easily implementable.
  - Challenges of not regarding as produced: would require assumptions on initial ownership/allocation of new coins and could produce negative value added for mining entities if coins are treated as not produced.
- Approach 2 — Regard CAWLM as non-produced assets:
  - Alternatives if not produced: (i) new CAWLM considered brought into circulation by miners but not seen as result of production, or (ii) initial ownership attributed to designers or holders of existing coins.
  - Practical difficulties: identifying initial owners, attributing consumption of validation services, and risk of bilateral asymmetries if not implemented consistently across countries.

*Annex III of "The Recording of Fungible Crypto-Assets in Macroeconomic Statistics" (approved final version), IMF.*

### 31. It can also be argued that CAWLM should be regarded as non-produced assets, taking the

### f18-the-recording-of-fungible-crypto-assets-in-macroeconomic-statisticsapproved-final-version - 31. It can also be argued that CAWLM should be regarded as non-produced assets, taking the

### Treatment of mining and validating activities
- Miners and validators are engaged in productive activities but that does not automatically imply they produce the crypto assets themselves.
- Miners and validators provide validation services, remunerated by:
  - an explicit fee, and
  - a new coin acting as an implicit fee.
- Viewing mining/validation as production of validation services ensures consistency between:
  - validators who receive only an explicit fee, and
  - validators who are rewarded by both an explicit fee and a new coin.
- Proof-of-work, proof-of-authority, and proof-of-stake are different validation protocols with different remuneration mechanisms.
- Many mineable CAWLM come into circulation at a pace determined by the developer; miners can claim a larger share of the predetermined new coins but cannot increase the total release rate set by the protocol.
- If total coins are predetermined, miners will eventually receive only transaction fees once all coins are mined.
- Treating mining as validation services supports regarding miners as being remunerated in fees and new coins rather than as producers of the coins.

### Accounting for “off production” creation and circulation of CAWLM
- Main challenge: accounting for off-production creation and the mechanism by which CAWLM are brought into circulation, especially when coins are exchanged for production activities (proof-of-work, proof-of-stake, etc.).
- Key assessment question: who benefits from the activities in relation to the release of new coins?
- Possible approaches:
  - Regard the designer as receiving new coins when coins are brought into circulation via explicit sales.
  - This reasoning is less convincing when coins are released as remuneration for validation (proof-of-work, proof-of-stake, proof-of-authority).
- When CAWLM are brought into circulation in exchange for production activities:
  - Owners of existing CAWLM coins can be regarded as consuming the products provided (the crypto asset community in Annex IV).
  - Multiple institutional units across a wide range of countries may be the beneficiaries.
  - The financial payment associated with this consumption corresponds to the dilution in value of existing coins, recorded as a financial transaction between producers and the community.
  - Dilution effect may not be visible in stocks if accounts are denominated in CAWLM; this appears as an “exchange rate” effect recorded as revaluations in accounts denominated in CAWLM.

### Data and implementation considerations
- Implementation requires detailed information on:
  - transactions of CAWLM by counterparty,
  - stocks,
  - activities of miners (explicit fees and block rewards through new coins).
- At present, it is unclear whether sufficient information will be available to compile macroeconomic aggregates for CAWLM.

### Typology and classification outcomes
- Broad agreement to distinguish types of fungible crypto assets as described in paragraph 6.
- Agreement that all fungible crypto assets meet the asset boundary per paragraph 8.
- Consensus that fungible crypto assets with a corresponding liability should be recorded as financial assets, with specific classifications:
  - Crypto assets designed to act as a general medium of exchange with a corresponding liability:
    - issued by a monetary authority — classified as currency under “currency and deposits” (AF.2).
    - not issued by a monetary authority — classified under a separate new asset class.
  - Crypto assets that act only as a medium of exchange within a platform or network (payment tokens) with a corresponding liability — classified under a separate subcategory under “debt securities” (AF.3).
  - Security crypto assets (always have a counterpart liability):
    - Debt security crypto assets (and utility tokens) — classified under “debt securities” with a separate subcategory for utility tokens (AF.3).
    - Equity crypto assets — classified under “equity and investment fund shares and units” (AF.5).
    - Derivative crypto assets — classified under “derivatives and employee stock options” (AF.7).
- Payment tokens without a corresponding liability (CAWLP) recommended to be classified in line with CAWLM, in a separate (sub)class.

### Options considered for CAWLM classification (Issues 2a and 2b)
- Three options considered, covering whether CAWLM are produced nonfinancial, non-produced nonfinancial, or financial:
  - Option I — Produced Nonfinancial Assets:
    - CAWLM are nonfinancial assets produced by miners (mineable) or creators/issuers (non-mineable); expenditure counterpart is capital formation by producers.
    - Pros: consistent with counterpart liability criterion for financial assets except monetary gold; consistent with current international accounting standards and some regulators; adds to capital formation.
    - Requires updating categories of produced nonfinancial assets (e.g., valuables).
  - Option II — Non-Produced Nonfinancial Assets:
    - CAWLM are nonfinancial assets “released” via other changes in the volume of assets and distributed to new owners in exchange for validation services.
    - Pros: consistent with counterpart liability criterion; consistent with view miners do not produce coins but receive them for validation services; ensures consistent recording across validation types and modes of circulation.
    - Adds to production and consumption/trade in services; may require expanding categories of non-produced nonfinancial assets.
    - Practical implementation may require assumptions on counterpart of implicit validation fee, posing challenges and affecting bilateral asymmetries.
  - Option III — Financial Assets:
    - CAWLM are financial assets “released” via other changes in the volume of assets and distributed to new owners in exchange for validation services.
    - Pros/Cons: inconsistent with counterpart liability criterion (would require an update adding an exception, risking other commodities being regarded as financial assets); holdings may increase a country’s net financial position without a counterparty, creating inconsistencies in global financial asset-liability totals.
    - Adds to production and consumption/trade in services; practical implementation may require assumptions on counterpart of implicit validation fee, posing challenges and bilateral asymmetry risks.

### Consultation with the GFS community and responses
- Consultation outcomes within the GFS community:
  - Total responses: 11 responses.
  - Forty five percent (five respondents) preferred classifying CAWLM as nonfinancial assets.
  - 27 percent (three respondents) preferred classifying CAWLM as financial assets.
  - 18 percent (2 respondents) did not express any preference.
  - One respondent preferred a hybrid option (not presented in GN/GFS questions).
- Of those preferring CAWLM as nonfinancial assets:
  - Three respondents supported produced nonfinancial assets treatment.
  - Two respondents supported non-produced nonfinancial assets treatment.
- One respondent preferring financial asset classification also expressed some preference for hybrid treatment.
- Most respondents did not provide GFS-specific arguments.
- One respondent raised concern about potential impact on government net lending/net borrowing if CAWLM classified as nonfinancial assets and highlighted issues of government seizures of crypto assets and recording in government accounts.
- A broader global consultation took place during January 28—February 25, 2022, collecting input from 42 respondents representing 35 economies; results presented at the joint meeting of the Committee and the AEG in March 2022.

### Next steps and recommendations
- Arguments and recommendations are based on the drafting team’s understanding at the time of writing; the crypto asset landscape is rapidly changing and guidance may become out of date.
- Statistical experts and compilers should monitor developments that may necessitate changing recommendations.
- The drafting team recommends countries begin collecting data necessary to measure transactions and stocks of these assets and to compile related statistics.
- Preferred set of volunteer countries/entities for testing should preferably include:
  - (a) countries with significant mining activity related to Bitcoins and other crypto assets (e.g., Georgia, Iran, Kazakhstan, Malaysia, Malta, Canada, and the US);
  - (b) countries with many crypto exchanges/wallet providers (e.g., US, UK, and Singapore);
  - (c) countries that are intensive users of crypto assets (e.g., Nigeria, Philippines, El Salvador, Argentina, South Africa, Thailand, Turkey, and Vietnam);
  - (d) large enterprises that accept bitcoin or other crypto assets as payment.
- A testing phase is recommended to provide information on practical challenges and on how macroeconomic aggregates are affected under each recording option.

*International Monetary Fund Guidance Note*

### 50. The three approaches discussed in the GN require about the same information to compile

### The Recording of Fungible Crypto Assets in Macroeconomic Statistics

### Data collection and international data sharing
- The three approaches discussed in the GN require about the same information to compile accurate and detailed statistics.
- Testing countries should collect data on CAWLM ownership and transactions from:
  - households,
  - corporations,
  - government, and
  - non-profit entities.
- Annex VI contains recommendations on the data items required, the entities to target in data collection efforts, and a sample questionnaire for CAWLM mining entities.
- The drafting team recommends that countries share crypto assets’ data they collect through international organizations to:
  - help resolve asymmetries expected from the decentralized nature of the CAWLM economy, and
  - fill in missing information.

*Outcomes of the March/October 2022 and March 2023 joint Committee and AEG meetings*
- March 2022:
  - Agreement that all fungible crypto assets meet the asset boundary.
  - Fungible crypto assets with a corresponding liability should be recorded as financial assets.
  - Agreement on the typology of fungible crypto assets (see paragraphs 38–40).
  - No consensus was reached on the treatment of crypto assets without a corresponding liability designed to act as a medium of exchange.
- October 2022:
  - Agreement that a user consultation process should be undertaken.
  - SNA and BPM editors were to prepare an Issue Note, considering outcomes of the user consultation, to be presented to AEG and BOPCOM for endorsement.
- Following October 2022:
  - SNA and BPM editors, in consultation with the drafting team, prepared a survey questionnaire and conducted a global consultation of the user community.
  - The Issue Note considered outcomes of the user community consultation.
  - The user consultation showed that most respondents supported treating CAWLM as nonfinancial assets (within nonproduced assets).
- March 2023:
  - Based on SNA/BPM editorial recommendations in the Issue Note, the Committee and the AEG agreed:
    - To treat non-liability crypto assets (CAWLM and CAWLP) as non-produced non-financial assets—within a separate category—in the 2025 SNA and BPM7.
- Additional recommendations by AEG and Committee:
  - (i) National accounts and balance of payments communities should monitor developments relating to non-liability crypto assets and review the recommendation if significant market, regulatory, and/or accounting changes arise that may justify revision either before or after the release of the manuals in 2025.
  - (ii) Retain the issue of treatment of non-liability crypto assets in the SNA and BPM research agendas.
  - (iii) Develop communication on the recommended treatment and guidance on identification of non-liability crypto assets, treatment of borderline cases, and recording of flows/stocks related to non-liability crypto assets in national accounts and external sector statistics to users and producers.
  - (iv) Develop practical guidance on data sharing to facilitate compilation of crypto assets flows/stocks in national accounts and external sector statistics, leveraging recommendations in the Guide to Sharing Economic Data in Official Statistics.

### IMF internal user perspectives (Annex I)
- An internal IMF consultation in December 2020 yielded the following main takeaways:
  - Strong preference to maintain, for now, the current statistical treatment of CAWLM and digital tokens without counterpart liabilities as nonfinancial assets.
  - Importance of continuing to monitor developments, including market trends, CAWLM adoption and usage, and use of CAWLM as a means of international payment.
  - If CAWLM were classified as financial assets, concerns would arise regarding conflicts with central banks, regulators, and International Financial Reporting Standards (IFRS); legitimacy for speculative investments; and financial integrity and consumer protection issues.
  - CAWLM are not anticipated, for now, to become a significant medium of exchange, given growth of stablecoins and the possibility of central bank digital currencies (CBDCs).
  - The possibility of creating a separate statistical category for “hybrid assets” (assets with both financial and nonfinancial features) could be explored.
  - Legal and user considerations for classifying financial assets include the nature of legal relationships between holders and providers and private law implications.
  - It is important to assess whether CAWLM would achieve significant market depth (capitalization) and liquidity (ease of convertibility) to pose systemic financial stability risks.

### The hybrid-assets option (Annex III) — alternative model considered and rejected
- Proposal:
  - Create a new asset class—hybrid assets—reflecting CAWLM’s features of both financial (designed to act as a medium of exchange) and nonfinancial (no corresponding liability) assets.
  - This option was discussed by the drafting team but rejected by BOPCOM and AEG at their joint meeting in March 2022; it is included for information.
- Under the hybrid-assets approach:
  - Acquisition of goods and services with existing CAWLM would be treated as acquisitions against financial assets (not barter).
  - Net acquisitions of existing CAWLM against other assets would not be seen as contributing to capital formation.
  - CAWLM produced by mining would be treated as resulting from a production activity contributing to capital formation, similar to produced nonfinancial assets.
- Key conceptual and accounting issues:
  - Transactions in CAWLM would be treated differently depending on whether they correspond to creation of new assets or exchange of existing assets; distinguishing newly created versus existing CAWLM could be challenging in practice.
  - Introducing a new account between the capital account and the financial account is one possibility to reflect transactions in existing CAWLM (but not creation of new CAWLM).
  - Two alternative models for treatment of the balancing item were presented:
    - Model 1: Net lending/net borrowing (B9) retained as the balancing item of the capital account.
      - Result: Net lending/net borrowing reflects current and capital accounts; newly introduced account covers transactions in existing hybrid assets and financial assets.
    - Model 2: Net lending/net borrowing (B9) retained as the balancing item of the financial account.
      - Result: Definitions and placements of B9 and related balancing items change; net lending/net borrowing from financial account differs from net lending/net borrowing from current and capital accounts plus hybrid account.
  - Implications:
    - Reconciling the demand to avoid classifying CAWLM as financial assets while avoiding statistical artifacts from treating payments with CAWLM as barter transactions.
    - International trade effects on the current account would be the same whether payments are made with financial assets or CAWLM.
    - Capital formation would be unaffected by payments with CAWLM as it is by payments with financial assets.

### Numerical examples and accounting implications (Annex IV) — exact figures preserved
- Example 1: Cross-border purchase of goods
  - Scenario:
    - Country B purchases units of CAWLM from Country C for US$100.
    - Country B imports goods of US$80 from Country A and pays with CAWLM.
  - Main differences in recording for Goods Exporter (Country A):
    - Current account balance under different treatments: Valuable: 0; Permits: +80; Financial Asset: +80; Hybrid Asset (Model 1): +80.
    - Net lending/borrowing: Valuable: 0; Permits: 0; Financial Asset: +80; Hybrid Asset: +80.
    - Change in net international investment position: Valuable: - - ; Permits: +80; Financial Asset: +80; Hybrid Asset: - .
  - Main differences in recording for Goods Importer (Country B):
    - Current account balance: Valuable: -100; Permits: -80; Financial Asset: -80; Hybrid Asset: -80.
    - Net lending/borrowing: Valuable: -100; Permits: -100; Financial Asset: -80; Hybrid Asset: -80.
    - Change in stock of financial assets when CAWLM are financial assets: -100 then -80 (reflecting retention of US$20 worth of CAWLM after purchase of goods).
  - Main differences in recording for CAWLM Seller (Country C):
    - Current account balance: Valuable: +100; Permits: 0; Financial Asset: 0; Hybrid Asset: 0.
    - Net lending/borrowing: Valuable: +100; Permits: +100; Financial Asset: 0; Hybrid Asset: 0.
    - Change in stock of financial assets when CAWLM are financial assets: +100.
  - Notes:
    - In these examples, CAWLM is considered as an external asset for all economies when classified as a financial asset.
- Conclusion from Example 1:
  - In national accounts, main differences between treatment options emerge in net lending/borrowing and the stock of assets.
  - When CAWLM are treated as nonfinancial assets, net lending/borrowing (calculated as net saving minus gross domestic investment and capital-account transactions) is the same across nonfinancial options because acquisitions less disposals of valuables and permits are recorded in the capital account.
  - When CAWLM are financial or hybrid assets, net lending/borrowing reflects only the part of the transaction involving the current and capital accounts.
  - International Investment Position (IIP) effects:
    - If CAWLM classified as a financial asset, net effect on the IIP is zero when purchased with or sold for currency (or another crypto asset).
    - If classified otherwise, net effect on the IIP is negative when purchased with currency and positive if sold for currency; exchange for another crypto asset does not affect the IIP.
  - Recording as nonfinancial asset may lead to barter-treatment implications: purchases may show up as barter trade; recording as valuable does not affect current account balance; recording as non-produced nonfinancial asset (permits) does not affect net lending/borrowing.
- Example 2: Use of CAWLM as an alternative investment vehicle
  - Scenario:
    - Country B purchases units of CAWLM from Country A for US$100.
    - Country B holds CAWLM; value increases to US$120.
  - Main differences in recording for CAWLM Seller (Country A):
    - Current account balance under different treatments: Valuable: +100; Permits: 0; Financial Asset: 0; Hybrid Asset (Model 1): 0.
    - Net lending/borrowing: Valuable: +100; Permits: +100; Financial Asset: 0; Hybrid Asset: 0.
  - Main differences in recording for CAWLM Holder (Country B):
    - Change in net worth across all treatments: +20.
    - Change in stock of nonfinancial assets under Valuable or Permits: +120.
    - Change in stock of financial assets when CAWLM are financial assets: +20 (reflecting the valuation gain).
    - Current account balance under different treatments: Valuable: -100; Permits: 0; Financial Asset: 0; Hybrid Asset: 0.

### Conclusion (document-level)
- The GN highlights that data collection and international data sharing are essential for compiling accurate and detailed statistics on fungible crypto assets.
- After user consultation and editorial analysis, the Committee and AEG agreed to record non-liability crypto assets (CAWLM and CAWLP) as non-produced non-financial assets—within a separate category—in the 2025 SNA and BPM7, while recommending ongoing monitoring, research agenda inclusion, communication of guidance, and development of practical data-sharing guidance.
- The hybrid-assets approach was explored as an intermediate solution but rejected by BOPCOM and AEG; it remains documented for informational purposes and illustrates alternate accounting models and implications for net lending/net borrowing, asset stocks, current account balances, and the IIP.

*Approved Guidance Note, "The Recording of Fungible Crypto Assets in Macroeconomic Statistics".*

### Conclusion:

### f18-the-recording-of-fungible-crypto-assets-in-macroeconomic-statisticsapproved-final-version - Conclusion

### Main conclusions on recording options and economic impacts
- Different recording options (valuable permits, financial asset, hybrid asset/Model 1) do not change net value added; they change the composition/type of output and the accounting treatment of related flows and stocks.
- Recording CAWLM as a financial asset versus as a nonfinancial or hybrid asset affects:
  - How revaluations of CAWLM affect the International Investment Position (IIP); IIP is affected only when CAWLM are classified as financial assets.
  - Net lending/borrowing, because of differences between changes in net worth attributable to saving and capital transfers and net acquisitions of nonfinancial assets.
  - Stocks across asset categories (nonfinancial assets, financial assets, hybrid assets), while overall net worth remains the same across recording options.
- When CAWLM are recorded as produced or non-produced nonfinancial assets versus as valuable (barter-like) transactions:
  - Recording as a valuable: payment in CAWLM for validation services is fully recorded as barter trade and does not affect the current account.
  - Recording as a non-produced nonfinancial asset: validation service appears in the current account; the payment is recorded in the capital account.
  - Recording as a hybrid asset: current account reflects provision of validation services; capital account reflects production of new coins.
- For international accounts, inclusion of crypto assets in the IIP (analogous to monetary gold) when treated as financial assets leads to different outcomes for net lending/borrowing and changes in the IIP; whether this is the preferred approach remains to be discussed.

### Example summaries (selected numeric details preserved)
- Example 3.A (Mineable Coin; miner in Country A):
  - Country B final consumer pays a transaction fee of US$10 in existing CAWLM.
  - Country A miner receives US$90 in new CAWLM as Block reward.
  - Miner incurs US$80 electricity cost.
  - Across recording options, Net Value Added and Net Saving for miner are +20 and +20 respectively; Net lending/borrowing varies by treatment (e.g., -80 under Valuable Permits and Financial Asset; +20 under Hybrid Asset Model 1).
  - For transactor in Country B: Consumption of validation services = +10; Net Saving = -10; Current account balance varies (e.g., 0 under Valuable Permits; -10 under other treatments).
  - For owners of existing CAWLM: Consumption of validation services and corresponding accounting differ by recording (e.g., +90 consumption under Financial Asset or Hybrid Asset leads to Net Saving = -90 and Current account balance = -90).
- Example 3.B (Non-Mineable Coin; proof-of-stake validation):
  - Country B final consumer pays a transaction fee of US$10 in existing CAWLM.
  - Country A entity receives US$15 in new CAWLM as Block reward.
  - Entity incurs US$5 electricity cost.
  - Miner/entity: Output of validation services = 25; Net Value Added = 20; Net Saving = 20; Net lending/borrowing varies (e.g., -5 under Valuable Permits and Financial Asset; +20 under Hybrid Asset Model 1).
  - Transactor in Country B: Consumption of validation services = 10; Net Saving = -10; Current account balance varies by treatment (0 or -10).
  - Owners/issuer: Output of CAWLM = +15 (in Valuable or Hybrid Asset cases); Net Saving and Current account impacts differ accordingly.
- Across both mineable and non-mineable examples:
  - Overall net worth is the same in all recording options (subject to assumptions noted in the GN).
  - Differences arise in which institutional unit is recorded as producer of new coins (miner vs issuer) depending on whether CAWLM are treated as produced assets.

### Measurement challenges (Annex V; numbered observations)
- Practical feasibility hinges on obtaining reliable information on emergence, ownership, and use of crypto assets (paragraph 61).
- Key concerns (paragraph 62):
  - Pseudo-anonymity of transactions despite ledger recording.
  - Difficulty assigning geography/residency when digital address owners are unknown.
  - Difficulty valuing positions and separating flows from valuation changes due to high price variance.
  - Current lack of comprehensive data on economic use of crypto assets domestically and internationally.
- Required data to implement classification recommendations (paragraph 63):
  - Mining activities: location, inputs used, block rewards, residency of transactors validated.
  - Stocks of crypto assets by resident institutional sectors and their changes (financial transactions, revaluations, other changes).
  - Flows of crypto assets between countries and institutional sectors.
  - Use of crypto assets as medium of exchange: purchases of goods and services by entities, broken down into domestic and abroad acceptance.
- Data-sharing recommendation (paragraph 64): explore sharing data from crypto asset exchanges and crypto asset service providers across countries to improve data quality and cross-country consistency.
- Systemic concerns (paragraphs 65–69):
  - Timely data collection is critical where crypto assets act as a general medium of exchange for measuring money, liquidity aggregates, and international capital flows.
  - Foreign-issued CBDCs and stablecoins, issued by nonresident intermediaries, may be difficult for national compilers to observe.
  - CBDCs and crypto assets could seriously undermine measurement of money, liquidity aggregates, and international capital flows if data are unavailable to compilers.
  - Rapid currency substitution via foreign CBDCs or crypto assets poses a major challenge to monetary statistics, especially for countries with weak fiat currencies.

### Data exchange and coordination (paragraphs 70–71 and scenarios)
- Paragraph 70: Data exchange among central banks issuing CBDCs can be facilitated by an international organization with global reach, such as the IMF, via a central database for CBDC holdings by nonresidents.
- Paragraph 71: Absence of such collaboration would hurt monetary aggregate compilation; bilateral arrangements would burden smaller countries.
- Two illustrative scenarios (paragraph 71):
  - Scenario 1: Five countries issue CBDC by end of 2021; they report holder’s data to a central IMF-based unit; compilers elsewhere use the central database to identify CBDC holdings by their residents for monetary aggregates.
  - Scenario 2: No central database; bilateral arrangements are needed; small, low-income countries face burdens in contacting CBDC issuers; complications amplified by crypto assets issued in jurisdictions that do not collect/share relevant data.

### High-level data collection guidance (Annex VI; paragraph 72 onward)
- Recommendation: Countries begin collecting information on ownership, creation, and use of crypto assets in domestic economy and cross-border transactions.
- Core data items to collect (paragraph 72 bullets preserved):
  - Stock of crypto assets owned by resident institutional sectors and changes in these stocks (financial transactions, revaluations, other changes), including cross-border flows and positions, ideally broken down by counterpart country.
  - Data on creation of crypto assets: transaction fees broken down into explicit fees and block rewards paid to/received by miners and validators; other forms of bringing new coins into circulation; and input costs (e.g., labor, machinery, electricity).
  - Data on use of crypto assets: use in purchasing goods and services by sector and use as an alternative investment.
- Possible data sources (paragraph 73):
  - Development of a dataset collecting crypto asset ownership and transaction information from households, corporations, government, and non-profit entities.
  - Potential collection via tax authorities (owner identification), regulatory bodies, crypto asset exchanges, wallets, and trading platforms subject to anti-money laundering “know your customer” requirements—subject to feasibility if entities are not resident.
  - Surveys targeting main players in domestic crypto markets and entities involved in crypto activities; international exchange of data may help when main players are located abroad.

*Source: IMF Guidance Note (approved final version) — "The Recording of Fungible Crypto Assets in Macroeconomic Statistics".*

### 74. The following is a list of specific data items about which members should collect information. The

### The Recording of Fungible Crypto Assets in Macroeconomic Statistics

### Specific data items to collect (paragraph 74)
- Target entities and associated data items:
  - Tax authorities
    - Ownership of crypto assets by businesses and individuals at beginning and end of recording period
    - Gains/losses from holding and selling crypto assets
  - Retailers that accept payments in crypto assets
    - Use of crypto assets to purchase of goods and services (domestic versus non-resident)
    - Receipt of crypto assets in sale of goods and services (domestic versus non-resident)
  - Mining enterprise or validation provider
    - Holding gains/losses on crypto assets
    - Input costs in relation to validation services and/or mining
      - Electricity
      - Equipment
      - Employment
      - Labor costs (or hours spent)
    - Receipt of transaction fees in crypto assets
      - Explicit fees (existing coins)
      - Block reward (new coins) in the case of CAWLM
      - Sale of crypto assets (in exchange for fiat currency or other assets)
  - Crypto asset designer
    - Value of coins held at beginning and end of recording period
    - Release of new coins during the recording period (mineable or non-mineable) by counterpart country
    - Input costs in relation to design and/or management of crypto asset
      - Electricity
      - Equipment
      - Employment
      - Labour costs (or hours spent)
  - Crypto asset exchange/trading platform/wallet
    - Information on use of crypto assets
    - Information on creation of new crypto assets
    - Information on revaluation of crypto assets
    - Purchase/sale of crypto assets (in exchange for fiat currency or other assets)
    - Stocks of crypto assets held by residents/non-residents and possibly sector at the beginning/end of a period

- Notable policy development mentioned:
  - A proposal was recently passed by the U.S. Senate to (i) collect more data on crypto assets, primarily from crypto asset exchanges, and (ii) raise tax revenues from the crypto industry. The proposal targets exchanges because they have data on who owns crypto assets and how much, and records of who sold what crypto to whom and for how much. (paragraph 67)

### Specific recommendations for Monetary and Financial Statistics (MFS) and Balance of Payments/IIP compilers (paragraph 75 and following)
- Rationale
  - Digital currencies and new means of payment using DLT networks (such as Bitcoin’s blockchain) challenge measurement of monetary and liquidity aggregates and cross-border financial transactions and positions.
  - In countries with weak currencies or unbanked populations, digital money or new means of payment can have a significant impact on monetary (currency substitution) and external sector (new cross-border payment channels) statistics.
- Recommended simplified data collection exercise characteristics:
  - Targeted Fintech Companies:
    - Resident wallet providers (for positions data: amount of crypto assets held by different institutional sectors)
    - Resident currency exchanges (for transactions data, especially cross-border transactions)
  - Nonresident Fintech Companies:
    - Nonresident wallet providers and currency exchanges used by residents, with estimates on the share of the domestic market
    - If direct data from nonresident providers are difficult to collect, conduct surveys among resident holders of crypto assets to estimate importance of these providers in the domestic economy
  - Data Collection (Positions):
    - Aggregated data on resident institutional units' holdings of crypto assets by type and broad sector classification (money issuers—CB and ODC—central government, and money holding sectors)
    - For nonresident customers, aggregated data by broad sector and country of residency
  - Data Collection (Transactions):
    - Aggregated data on resident institutional units' cross-border transactions in crypto assets by type and by sector and country of residency of counterparty
    - Cover purchase/sale of crypto assets by type (including CAWLM), purchase/sale of goods and services, remittances, and direct investment (e.g., real estate) using CAWLM
  - CAWLM Data Tracking:
    - Aggregated data on customer transactions and holdings of CAWLM, aiming to measure whether CAWLM is used as a means of payment only (buyers and sellers, or remittance senders and recipients immediately convert the CAWLM) or as a medium of exchange (buyers and sellers, or remittance senders and recipients maintain positions in CAWLM, bearing appreciation/depreciation risk)

### Example survey questionnaire: Bitcoin mining company (paragraph 42)
- Item list and units as example fields for collection:
  1. Number of Bitcoins mined during the period — Units
  2. Value of Bitcoins mined (at price of the day of the transaction) — USD
  3. Explicit Fee received for validating the transactions (in Bitcoins)
     - Value — Units — USD
  4. Input costs related to mining/validation services — USD
     - a) Electricity — USD
     - b) Maintenance of equipment — USD
     - c) Labor costs — USD
     - d) Other input costs — USD
  5. Use of Bitcoins
     - a) sold to resident exchanges — Number (could be a fraction), Value, Units, USD
     - b) sold to nonresident exchanges — Number, Value, Units, USD
     - c) transferred to head office/others — Number, Value, Units, USD
     - d) payments for purchase of goods and services — Number, Value, Units, USD
     - e) Other uses

### Supplementary information and referenced works (Annex VII)
- Bibliographic entries cited in the annex include works by ALVAREZ, FERNANDO; DAVID ARGENTE; DIANA VAN PATTEN (2022), BANK FOR INTERNATIONAL SETTLEMENTS (2019), EUROPEAN COMMISSION/INTERNATIONAL MONETARY FUND/ORGANISATION FOR ECONOMIC CO‑OPERATION AND DEVELOPMENT/UNITED NATIONS/WORLD BANK (2009), INTERNATIONAL MONETARY FUND (2011; 2016; 2019), OECD (2020; 2019), and ZWIJNENBURG, JORRIT et al. (2018; 2020). Specific titles and web references are listed in the annex. (paragraphs 43–44)

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_Source: https://www.imf.org/-/media/files/data/statistics/bpm6/approved-guidance-notes/f18-the-recording-of-fungible-crypto-assets-in-macroeconomic-statisticsapproved-final-version.pdf_