Crypto advisory for companies: when it makes sense

Crypto advisory for companies makes sense once a business already touches digital assets in its operations, taking payment from customers or paying suppliers abroad, or once it has decided to keep part of its cash in bitcoin or stablecoins and needs a custody, accounting and tax policy before the amounts grow. The Brazilian framework has tightened: since February 2, 2026, the virtual asset service providers a company relies on need authorization from the Central Bank of Brazil under Resolution BCB 519 of November 10, 2025. Vault Capital, a securities consultancy authorized by the CVM under CVM Resolution 19/2021, works with companies at exactly this point: it recommends and monitors, and the company decides and keeps custody.

In short

• Four topics the company needs to settle before the first real goes into crypto: regulation, accounting, tax and custody.
• Fees are a monthly advisory fee on assets under advisory, set by contract; Vault never holds client assets.

Treasury use cases, side by side

Crypto assets carry high risk, including significant volatility and the possibility of losing the capital invested. Nothing here is a recommendation: each row becomes a decision only after a diagnosis of the company.

When a company needs advice

Three signals. The first is volume: once what flows through or sits in crypto matters to the cash position, the partner who "knows bitcoin" becomes a governance risk. The second is the accountant or auditor asking for a written policy, because the balance sheet has to explain what that asset is. The third is the departure of a partner or employee who was the only person with access to the keys. Advisory prevents the third case; it cannot fix it afterwards.

The post is a crypto advisor worth it? shows who advisory makes sense for in the case of individuals; the logic for companies is identical.

What a CVM consultancy does and does not do for a company

It does: diagnose current exposure, build an allocation plan across crypto and fixed income that fits the company's policy and is formalized in a contract, and provide continuous monitoring through the app with direct access to the advisor, including on custody and key succession.

It does not: hold keys, receive company funds, distribute exchange products or guarantee returns. Vault works under the principle of advisory, never custody: assets stay in exchanges and wallets in the company's own name. The page crypto advisory: how it works describes the three steps of the process.

Governance and custody policy

The most common single point of failure in companies is one person holding the seed. The policy has to answer who approves transactions, how many signatures are required (2 of 3 multisig is the most common arrangement for treasuries), where backups live, who has exchange access and what happens when any of those people leave. Per-transaction and daily limits, an operating wallet separate from the reserve and a quarterly review complete the design. None of this needs sophisticated technology; it needs a document signed by the partners.

Accounting and tax

For accounting, the reference is the IFRS Interpretations Committee agenda decision of June 2019 on holdings of cryptocurrencies: IAS 2 (inventories) applies when the asset is held for sale in the ordinary course of business, and IAS 38 (intangible assets) applies otherwise. Brazil's equivalents are CPC 16 and CPC 04. An intangible sits at cost and is tested for impairment, with no upward revaluation, which is why a bitcoin treasury shows below market value on the balance sheet during rallies. The CVM's Guidance Opinion 40 of October 11, 2022 sets out when a crypto asset is a security, which matters for tokens beyond bitcoin and stablecoins.

For tax, the monthly R$ 35,000 exemption belongs to individuals and does not apply to companies. Under lucro real, the gain on sale enters taxable profit, subject to 15% IRPJ plus a 10% surcharge on the portion above R$ 20,000 per month (Law 9,249/1995, art. 3) and to CSLL; under lucro presumido, the capital gain is added to the base. Normative Instruction RFB 2,291/2025, of November 14, 2025, created the DeCripto crypto asset return, which replaced IN 1,888/2019 from July 1, 2026 and reaches companies that transact outside domestic exchanges above the monthly threshold. Rules checked in September 2026; confirm your case with an accountant before booking anything.

How to start

Gather a statement of everything the company holds or receives in crypto and the treasury's goals. Vault's diagnostic conversation is free and ends with a straight answer on whether advisory makes sense. If the company proceeds, Vault is paid through an advisory fee on the client's assets, charged monthly, on the terms set in the contract; professional investors may opt for a hybrid model combining an advisory fee and a performance fee. The exact figure depends on the assets under advisory and is presented in the proposal. Vault's regulatory documents are on the compliance page.

Frequently asked questions

Can a Brazilian company hold bitcoin on its balance sheet?

Yes. Under the 2019 IFRS Interpretations Committee decision, followed by the CPC in Brazil, the asset is booked as an intangible, or as inventory when traded in the ordinary course of business. The decision must be documented in a board resolution and a treasury policy.

How is a company taxed on crypto gains in Brazil?

There is no R$ 35,000 exemption for legal entities. The gain enters taxable profit: 15% IRPJ plus a 10% surcharge above R$ 20,000 per month and CSLL under lucro real, or added to the base under lucro presumido. The DeCripto return may be required above the monthly threshold.

How much does crypto advisory for companies cost?

Vault is paid through an advisory fee on the client's assets, charged monthly, on the terms set in the contract. The exact figure is presented in the proposal after the initial diagnosis, which is free.

Let's talk

If your company already receives, pays or holds crypto and has no written policy for it, Vault's diagnostic conversation is free and carries no commitment. It ends with a straight answer: advisory makes sense for your case or it does not.