A Trustee’s guide to crypto in SMSFs: Be safe, be compliant

Article

Published: November 27, 2025 |

The inclusion of crypto assets in Self-Managed Superannuation Funds (SMSFs) is a topic that continues to gain traction across trustee discussions, adviser briefings, and audit reviews. As the regulatory environment evolves and investor interest in crypto assets grows, trustees should approach this asset class with care. A measured approach, grounded in regulatory responsibilities is essential.

According to the Australian Taxation Office (ATO), SMSFs held approximately $3.02 billion in digital assets as at June 2025. While this represents a slight four per cent year-on-year decline, it is a significant increase from 2019, when holdings totalled just $119 million. Notably, SMSFs with balances under $200,000 allocate close to seven per cent of their portfolios to crypto and digital assets, compared to an average allocation of around two per cent across all SMSFs. This suggests a demographic shift, with younger trustees or newer funds showing a stronger appetite for emerging asset classes. These trends highlight the importance of tailored advice, especially as crypto assets become more accessible through regulated platforms and trustee interest continues to grow.

The ATO's compliance expectations

The ATO’s latest guidance outlines key compliance expectations for SMSFs investing in crypto assets.

Ownership: The crypto wallet must be registered in the name of the SMSF, not the individual trustee. Personal and SMSF crypto holdings must be kept strictly separate to avoid breaches of the Superannuation Industry (Supervision) Act 1993
Record-keeping: Trustees must maintain detailed records of all crypto transactions, including purchases, sales, and transfers
Valuation: Crypto assets must be reported at market value in financial statements. Auditors require objective, supportable evidence such as 30 June closing prices from reputable exchanges
Security: Passwords and private keys must be securely stored. Trustees should remain vigilant against impersonation scams and cyber threats.

Auditor focus areas

In addition, the ATO requires SMSF auditors to focus on certain areas of compliance including:

Fund documentation: Verify that crypto investments are permitted under the fund’s trust deed, align with the fund’s investment strategy and retirement objectives
Ownership and valuation: Ensuring assets are held in the fund’s name and reported at market value
Evidence and reporting: Confirming investments are supported by verifiable documentation such as exchange data or Type 2 custodian reports. Auditors are increasingly rejecting screenshots or informal records.

Trustees should consider using platforms that provide audit-ready reporting or engage third-party attestation services to support compliance.

Understanding the ATO’s expectations

The following section explores each of these points in more detail.

Investment strategy

Trustees must ensure their fund’s investment strategy explicitly allows for digital assets. This includes clearly stating the purpose of the investment, such as diversification or growth, while also considering risk tolerance, liquidity needs, and retirement goals. Trustees are expected to document the rationale behind asset selection and how these investments will be monitored over time.

Custody: Platform vs self-custody

Custody is also a critical consideration. Trustees must also choose between platform custody and self-custody. Platform custody offers convenience, integrated reporting tools, and increasing alignment with Australian Financial Services (AFS) licensee obligations. These platforms are evolving to resemble traditional investment platforms, with improved governance and transparency. In contrast, self-custody provides direct control but introduces risks around private key management, loss, or theft. Each option carries distinct audit and compliance implications, requiring trustees to carefully assess their choices and implement appropriate controls to manage risks effectively.

Tax implications

Digital assets are subject to capital gains tax (CGT). It is important that assets are held in the SMSF’s name, related-party transactions are avoided, and clear records are maintained for CGT events. Trustees also need to be aware of Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) obligations and avoid using unregulated exchanges. Given the volatility of crypto assets, trustees are encouraged to assess whether the fund can meet its short- and medium-term obligations, such as pension payments. It is also important to consider how crypto assets fit within the fund’s overall asset allocation, and the potential impact of market downturns on retirement outcomes.

Succession planning and continuity

Crypto assets introduce a unique challenge: knowledge centralisation. In many SMSFs, one trustee may be solely responsible for managing the crypto asset wallet, passwords, and transaction records. This creates significant risk if that trustee becomes incapacitated or passes away. Trustees are expected to ensure that wallet access credentials are securely stored and accessible only to authorised parties. It is also considered good practice to document procedures for accessing and managing crypto assets, and to incorporate crypto assets into the fund’s succession and estate planning strategy. In some cases, appointing a professional custodian or adviser may help support continuity. Without proper planning, the loss of access to digital assets could result in permanent loss of value to the fund and its members.

A strategic approach to crypto assets

Crypto assets offer exciting opportunities for SMSFs but must be approached with caution. The key question is not whether SMSFs can invest in crypto, but if it is appropriate to do so. If the answer is yes, the next step is to determine how to proceed safely, meeting regulatory obligations and aligning with the fund’s long-term objectives.

Trustees are responsible for making decisions that are well-documented, supported by professional advice, and underpinned by strong governance and risk management practices. As platforms mature and regulatory clarity improves, crypto assets may increasingly resemble traditional investments, but the fundamentals of trustee responsibility remain unchanged.

How BDO Can Help

Managing digital assets within an SMSF requires careful planning and a clear understanding of compliance obligations. BDO's superannuation team can help you review your investment strategy, meet regulatory requirements, and stay audit-ready.

If you have questions about SMSF crypto investments or would like to discuss how we can support your fund’s compliance and governance needs, contact your local BDO adviser.

The information contained in this publication is purely factual in nature and does not take into account your personal objectives, financial situation or needs. It is provided as an information service only and does not constitute financial product or other professional advice and should not be relied upon as such. Before making any investment or financial decisions you should consider your particular objectives, and financial circumstance or needs. Where information relates to a particular financial product you should obtain and consider the relevant Product Disclosure Statement and obtain advice from a financial adviser before making any decision. If you do require financial advice, please contact the relevant BDO member firms in Australia who will be able to assist you in their capacity as an Australian Financial Services licensee. Each BDO member firm in Australia, their partners and/or directors, employees and agents do not give any warranty as to the accuracy, reliability or completeness of information contained in this publication nor do they accept or assume any liability or duty of care for any loss arising from any action taken or not taken by anyone in reliance on the information in this publication or for any decision based on it, except in so far as any liability under statute cannot be excluded.

BDO refers to one or more members of a national association of separate entities who are allmembers of BDO International Ltd, a UK company limited by guarantee. Each BDO member firm in Australia is a separate legal entity and has no liability for another entity’s acts and omissions. Liability limited by a scheme approved under Professional Standards Legislation.

BDO is the brand name for the BDO network and for each of the BDO member firms.