SMSF Bitcoin Audit Guide

Collaborative security in this context refers to a 2-of-3 multisignature (multisig) arrangement: multiple keys are held by different parties, and a configured threshold of signatures (e.g. two of three) is required to move funds. In plain terms:

• Multiple keys exist; no single key can move the Bitcoin alone.
• Trustees (or their delegates) retain control; they are signers and direct the use of the vault.
• No single party—including The Bitcoin Adviser or the software platform—can unilaterally move funds.
• There are no pooled assets; the vault is attributed to the SMSF (or the client).
• There is no unilateral third-party authority over the assets.

In this arrangement, coordination platforms are not Bitcoin custodians for your fund in the pooled-custody sense. The platform that coordinates multisig (e.g. Unchained, Theya) supplies software and coordination. It does not hold Bitcoin in a custodial capacity for the SMSF; assets remain on the Bitcoin network and are controlled by the key holders according to the multisig policy. Wording here describes this model, not every possible service structure elsewhere.

Scope and limitations. This guide focuses on Australian SMSFs. Lost keys, inheritance of SMSF Bitcoin, and tax implications of multisig transfers are complex; trustees should seek specific professional advice. If you are outside Australia, consult your local regulations.

Bitcoin held in an SMSF under this model is on-chain: it exists as entries on the Bitcoin network, controlled by the keys that form the multisig vault. The trustees (or their authorised signers) control those keys and are responsible for access and decisions. Trustees remain responsible for the fund's investment strategy, record-keeping, and compliance. This is consistent with self-custody principles and with the Australian Taxation Office's expectations that SMSF trustees understand and control fund assets. For current guidance, see the ATO's pages on self-managed super funds and, where applicable, crypto assets.

The auditor is ordinarily trying to substantiate existence at the reporting date, attribution to the SMSF, supportable valuation, and separation from personal assets. The structure below follows the same logic as the core evidence set above.

Existence / balance

• On-chain balance at the relevant reporting date.
• Transaction history and relevant TXIDs.
• Reconciliation of the reported balance to the fund's records.

Attribution to the SMSF

• SMSF source of funds.
• Acquisition records linked to the relevant wallet or vault.
• Consistent identification of the holding in the fund's records.
• Clear separation from personal assets.

Valuation

• Reporting-date BTC quantity.
• Documented valuation approach.
• Objective and supportable market data.
• Retained evidence of price source and date.

A trustee or director attestation can support attribution of a wallet or vault to the SMSF, but it is not ordinarily relied on in isolation. It carries weight only where it lines up with the objective record: SMSF source of funds, traceable transactions, separation from personal assets, wallet attribution documentation, and a reconciled year-end balance.

Put simply: trustee attestation supports the evidence trail; it does not replace it.

For reporting and audit purposes, the fund should use a documented valuation approach based on objective and supportable market data at the relevant reporting date. The method used should be retained with the fund's records and applied consistently unless a deliberate policy change is made and documented.

If open, close, spot, or exchange-specific methodology is used, it should be applied consistently. The formulas below are tools to implement a chosen policy, not a substitute for one.

Spreadsheet tools to support your valuation policy

Our reports show balances and movements in Bitcoin. For audit purposes, accountants often need market value and fiat amounts for each transaction. You can look up the Bitcoin price for any date and in your chosen currency using built-in spreadsheet functions in Google Sheets or Excel.

Google Sheets — Current price in AUD: =GOOGLEFINANCE("CURRENCY:BTCAUD"). For the closing price on the date in cell A2:

=INDEX(GOOGLEFINANCE("CURRENCY:BTCAUD","close",A2,A2,"DAILY"),2,2)

You can use "open", "high", or "low" instead of "close". For other currencies, replace BTCAUD with BTCUSD, BTCEUR, BTCCAD, etc. Data may be delayed by up to 20 minutes.

Excel (Microsoft 365) — For a single date in cell A2, returning date and close price in AUD:

=STOCKHISTORY("BTCAUD", A2, A2, 0, 1, 0, 1)

Ticker ("BTCAUD", "BTCUSD", "BTCEUR", etc.), then property codes: 0 = Date, 1 = Close, 2 = Open, 3 = High, 4 = Low, 5 = Volume. Requires Microsoft 365; data is end-of-day.

Valuation basis (open, close, high, or low) is a matter of professional judgment and documented fund policy. The formulas above help you apply your chosen basis consistently; they do not substitute for that policy.

We help trustees and accountants assemble a coherent, proportionate, audit-ready documentation set: the same items auditors expect in this custody model, without asking for private keys or weakening wallet security. The aim is less audit friction and clearer records, within our non-custodial role.

We provide the following to support trustees, accountants, and auditors:

• Statement of Holdings: snapshot of vault balances and attribution at a point in time.
• Full transaction history: transaction IDs and details for movements into and out of the vault.
• Vault balances: on-chain balance information for the vault addresses.
• Service agreement: the client’s agreement with The Bitcoin Adviser (our Terms of Service and any engagement terms).
• Invoices: for fees paid for advisory and co-signing services.

Verification does not require disclosure of private keys, seed phrases, or any action that would weaken the security of the SMSF's Bitcoin. The relevant evidence can be supported through the documentation above and, where appropriate, view-only or export-based records that do not expose signing authority.

Optional read-only tool for trustees (TBA Vault Watcher)

Trustees can use TBA Vault Watcher on iPhone to view vault balances and transaction history from watch-only configuration: no private keys, no signing, and data stays on the device. It can help cross-check fund records, TXIDs, and the documentation above (including a Statement of Holdings) against the public blockchain. That supports the same reconciliation idea as the core evidence set; it is not a formal attestation or a substitute for the documented evidence pack.

Audit evidence should not require disclosure of private key material, seed phrases, or any other action that weakens the security of the SMSF's Bitcoin. In this self-custody model, the objective is to substantiate the holding and valuation without creating unnecessary security or privacy risks.

The following are not provided to anyone, including auditors or accountants:

• Private keys
• Seed phrases or other key material
• Custody attestations (we do not act as a pooled custodian of fund Bitcoin)
• Third-party reserve statements or Proof-of-Reserves reports (not applicable in the same way as for a pooled custodian)
• Requests that would unnecessarily expand exposure of wallet security information beyond what is reasonably required

Audit requirements can be satisfied using the documentation set out in the “What we provide” section above.