Bitcoin Treasury Policy: What a Private Company Should Put in Writing

A bitcoin treasury policy is a written, board-approved document that sets out why a company holds bitcoin, how much it can hold, who can buy, sell, move, or borrow against it, how it is custodied, and how it is reported. For a private company or family office, the policy is what turns a bitcoin position from one founder’s conviction into a governed treasury asset that auditors, lenders, investors, and successors can understand.

Most companies that hold bitcoin bought it first and wrote the rules later, if at all. That works until something changes: the price drops 30% in a week, a key person leaves, a lender asks how the asset is controlled, or the auditor asks who approved the last transfer. Year-end is a natural time to fix that gap, because boards are already reviewing budgets, audits are being scheduled, and 2027 plans are being set.

This guide covers the ten sections a bitcoin treasury policy should include, sample language you can adapt, and the borrowing rules worth setting before you ever need liquidity.

Key Takeaways

• A bitcoin treasury policy should answer five questions in writing: why the company holds bitcoin, how much it can hold, who can act, where it is held, and how it is reported.
• Allocation limits work best as a percentage of total treasury or excess cash, with a hard cap and a defined process for exceeding it.
• No single person should be able to move company bitcoin alone. Dual approval and multi-party custody are the baseline.
• If the company may ever borrow against its bitcoin, set the maximum loan-to-value (LTV), approved uses of proceeds, and a margin call playbook in advance.
• Review the policy at least once a year and after any major market, regulatory, or personnel change.

Why a Written Bitcoin Treasury Policy Matters

Cash, bonds, and money market funds come with decades of established treasury practice. Bitcoin does not. It trades around the clock, it can move globally in minutes, a lost key can mean a lost asset, and its price can swing far more in a month than most treasury assets move in a year. Those traits are exactly why written rules matter.

A clear policy does several jobs at once:

• Protects the company from key-person risk. If the person who set up the wallet is unavailable, the business still knows how to access and manage the asset.
• Prevents emotional decisions. Predefined rules for rebalancing and drawdowns keep the company from panic selling or overbuying.
• Supports the audit. Under FASB’s ASU 2023-08, many companies now measure bitcoin at fair value each reporting period, and auditors will ask how holdings are controlled and valued. See our guide to bitcoin fair value accounting.
• Makes the company easier to lend to. Lenders and counterparties want to see that an entity has authority, controls, and a repayment plan before they extend credit.
• Gives the board a framework. Directors can approve the strategy once and monitor it against agreed limits rather than debating every transaction.

The 10 Sections Every Bitcoin Treasury Policy Should Include

1. Purpose and objective. State why the company holds bitcoin. Common reasons include a long-term reserve asset, a hedge against currency debasement, or operational needs such as paying vendors or receiving customer payments. The objective drives every other limit in the policy.
2. Allocation limits. Define the maximum position, usually as a percentage of total treasury assets or of cash above a defined operating reserve. Set a floor for operating cash that bitcoin purchases can never dip into, such as six to twelve months of expenses.
3. Approval authority. Name who can approve purchases, sales, transfers, and borrowing, and at what dollar thresholds. Larger transactions should require a second approver or board sign-off.
4. Custody and key management. Specify where bitcoin is held, whether with a qualified custodian, in a company-controlled multi-signature setup, or a combination. Document key holders, backup locations, and what happens when a key holder leaves.
5. Counterparty due diligence. List what the company checks before using an exchange, custodian, or lender: licensing, how client assets are held, whether collateral is rehypothecated, insurance, and financial reporting. Our post on whether bitcoin-backed loans are safe covers the questions to ask a lender.
6. Borrowing and leverage rules. State whether the company may borrow against bitcoin, the maximum starting LTV, approved uses of proceeds, and who approves a loan. More on this below.
7. Liquidity and rebalancing. Explain when the company buys, sells, or rebalances. Some companies use dollar-cost averaging for purchases and set bands that trigger a review when bitcoin grows beyond its target share of treasury.
8. Accounting, tax, and reporting. Assign responsibility for valuation, cost basis records, tax reporting, and the monthly or quarterly report to leadership and the board.
9. Risk monitoring and escalation. Define price levels or drawdown percentages that require a review, who gets notified, and how quickly decisions must be made. Include security incidents and counterparty events.
10. Policy review and amendment. Set an annual review date and list events that trigger an earlier review, such as a regulatory change, a new custodian, or a change in leadership.

Sample Bitcoin Treasury Policy Language

The examples below are starting points, not legal language. Your attorney, CPA, and board should tailor them to your entity, jurisdiction, and risk tolerance.

Borrowing Against Bitcoin: Rules to Set Before You Need Liquidity

One of the main advantages of holding bitcoin as a treasury asset is that it can support liquidity without a sale. A crypto-backed business loan can fund working capital, inventory, payroll timing gaps, or an acquisition while the company keeps its bitcoin position. Selling instead can create a taxable gain and permanently reduce the reserve.

Borrowing also adds risk, which is why the rules belong in the policy before a loan is needed. A strong borrowing section covers:

• Maximum starting LTV. Lower LTVs leave more room for price drops. Many conservative policies cap starting LTV well below the maximum a lender offers. Use the loan calculator to see how much collateral a given loan requires.
• Approved uses of proceeds. For example, working capital and capital expenditures, but not speculative trading or buying more bitcoin with borrowed funds.
• Margin call playbook. Decide in advance whether the company will add collateral, pay down principal, or use a protection feature if LTV rises, and who is authorized to act on a weekend. Read What Is a Margin Call on a Crypto-Backed Loan? for how thresholds work.
• Downside protection. Note whether the company will use features such as Stabilization or SALT Shield®. Compare them in SALT Shield® vs. Stabilization.
• Maximum term and repayment plan. Tie loan maturity to a known source of repayment, such as forecast cash flow, rather than an expected bitcoin price.
• Reserve for additional collateral. Keep a defined amount of unpledged bitcoin or cash available to cure a margin call.

For a deeper look at sizing and managing crypto-backed credit, see our bitcoin treasury management guide for private companies and family offices.

Common Bitcoin Treasury Policy Mistakes

• One person controls the keys. This is the most common and most dangerous gap, both for security and for continuity.
• Limits set in bitcoin instead of percentages. A cap of 10 BTC means something very different at different prices. Percentage limits adjust automatically.
• No operating cash floor. Bitcoin should never be the reason the company cannot make payroll.
• Borrowing rules written after the loan. If the policy is silent on leverage, the first margin call becomes a governance debate under time pressure.
• No exit or rebalancing rules. A policy that only covers buying leaves the company without a plan when the position grows far beyond its target.
• Set it and forget it. Regulation, accounting rules, and the company itself change. An annual review keeps the policy useful.

How to Put a Bitcoin Treasury Policy in Place

1. Inventory what you hold today. Document every wallet, account, custodian, and key holder, along with cost basis records.
2. Agree on the objective. Leadership should settle why the company holds bitcoin before setting limits.
3. Draft the ten sections. Use the framework above, starting with allocation, approval authority, and custody.
4. Review with advisors. Have your attorney, CPA, and auditor review the draft for legal, tax, and reporting requirements in your jurisdiction.
5. Approve at the board level. A formal resolution gives the policy authority and creates a record for auditors and lenders.
6. Implement controls. Move custody, approvals, and reporting into line with the policy, then confirm it works with a test transaction.
7. Schedule the first review. Put the annual review on the board calendar before the meeting ends.

Frequently Asked Questions

What is a bitcoin treasury policy?

A bitcoin treasury policy is a written document, usually approved by a company’s board, that defines why the company holds bitcoin, how much it can hold, who can approve transactions, how the asset is custodied, whether it can be borrowed against, and how holdings are reported.

Does a private company need a board-approved bitcoin policy?

There is no general rule requiring one, but a board-approved policy is considered good governance. It documents authority, supports the annual audit, and gives lenders, investors, and successors confidence that the asset is controlled.

How much bitcoin should a company hold in its treasury?

There is no universal number. Companies typically set a percentage of total treasury or of excess cash above an operating reserve, based on their cash needs, risk tolerance, and time horizon. The policy should state the limit and the process for changing it.

Who should have access to company bitcoin?

Access should be split so that no single person can move company bitcoin alone. Common approaches include a qualified custodian with dual approval or a multi-signature setup with keys held by different officers and a documented backup plan.

Can a company borrow against its bitcoin?

Yes. Many lenders offer loans to business entities secured by bitcoin, typically after entity verification. The treasury policy should set the maximum LTV, approved uses of proceeds, approval authority, and the response plan if collateral value falls.

How often should a bitcoin treasury policy be reviewed?

At least once a year, and sooner after a major event such as a large price move, a new custodian or lender, a change in accounting or tax rules, or a change in the people named in the policy.

Is there a bitcoin treasury policy template?

The ten sections and sample language in this guide can serve as a starting framework. Because legal, tax, and reporting requirements vary by entity and jurisdiction, have your attorney and CPA tailor any template before the board adopts it.

Give Your Bitcoin Treasury the Structure It Deserves

A written policy is what separates a bitcoin position from a bitcoin treasury strategy. It protects the company from key-person risk, keeps decisions disciplined in volatile markets, and makes it easier to access liquidity when the business needs it. If your policy allows borrowing, SALT offers crypto-backed business loans that let companies access dollars or stablecoins without selling their bitcoin.

EXPLORE BUSINESS LOANS

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Disclosures

This article is provided for informational and educational purposes only and does not constitute legal, tax, accounting, investment, or financial advice. Sample policy language is illustrative and should not be adopted without review by qualified legal, tax, and accounting professionals. Requirements vary by entity type and jurisdiction.

Loans are originated by SALT Lending LLC (NMLS ID 1711910). SALT does not offer loans to all prospective borrowers, and additional screening may apply. Loan terms, rates, and availability vary by jurisdiction, loan amount, and collateral type, and business loan availability may differ from personal loan availability. SALT loans are subject to jurisdictional limitations and other restrictions. See where SALT currently lends at saltlending.com/map-list.

Borrowing against digital assets involves risk, including the risk that a decline in collateral value may require additional collateral or result in liquidation. Digital currency is not legal tender, is not backed by any government, and SALT accounts are not protected by FDIC or SIPC. Digital assets are highly speculative and you should be prepared for the possibility of losing your entire collateral.

California loans are made or arranged pursuant to a California Financing Law license. Idaho residents: Regulated Lender License No. RRL-11258. Michigan residents: Regulatory Loan License No. RL-0025865. For complete terms, see saltlending.com/terms-of-use.