Reporting and Audit Imperatives for Institutional and Accounting Teams

Crypto ETFs are heading into 2026 with a crowded pipeline and growing institutional attention.  If you support ETF issuers, audit teams, treasury organizations, or institutional infrastructure, the operational takeaway is simple:

Audit evidence has to be more repeatable, more complete, and easier to reperform.

Below is a practical playbook for what matters most in 2026 and how to prepare.

What is changing in 2026

1) More products means more audit surface area

As more crypto ETF products and structures come to market, the reporting footprint expands: more valuation scenarios, more custody models, more complex flows (and more opportunities for gaps). 

2) Custody expectations are becoming more explicit

In late 2025, the SEC’s Division of Trading and Markets issued a staff statement on how Rule 15c3-3 applies to broker dealers custodying crypto asset securities, including a framework where “physical possession” can be demonstrated in specified circumstances.  Commissioner Peirce’s response highlights both the significance and the policy tension, which is another signal that custody and control evidence will stay in focus. 

3) Accounting classification topics are moving up the stack

FASB has already added a project to clarify whether certain digital assets may be classified as cash equivalents. That conversation matters for treasury reporting, presentation, and controls, particularly where stablecoins play a meaningful role in operations. 

The audit imperatives: what teams will be asked to prove

Custody, control, and transfer capability

For ETF issuers and institutional holders, the hardest questions tend to be basic, and auditors still need hard evidence:

  • Who can initiate transfers?
  • How is authorization enforced?
  • How is key access logged and reviewed?
  • What happens during forks, airdrops, outages, or chain disruption?

The SEC staff statement describes expectations that map cleanly to audit evidence needs, including key protection controls and disruption planning. 

Valuation and pricing lineage

Crypto is 24/7. Audits still require a consistent policy and the ability to reproduce results later.

Audit ready valuation support should clearly document:

  • the pricing source(s)
  • timestamp conventions and cut off policy
  • exception handling (outliers, stale markets, venue issues)
  • historical retention (so the same valuation can be reproduced)

Completeness and reconciliation

The most painful audit cycles happen when teams cannot close the loop across:

  • custodian statements
  • administrator records
  • on chain activity (where applicable)
  • the general ledger

In 2026, the expectation will be less “send us raw exports,” and more “show us the tie out and the evidence chain.”

Staking, rewards, forks, and airdrops

As products consider yield and staking adjacent exposure, you need deterministic, replayable reporting that answers:

  • what is income vs return of capital (if applicable)
  • what is fee vs reward vs rebate
  • what is the time window and the source of truth
  • what did you do with forks and airdrops

The SEC custody statement explicitly calls out the need to plan for forks and airdrops in the safekeeping framework, which is a strong proxy for auditor concerns more broadly. 

What this means by segment

ETF issuers

  • Treat the close package like an “audit binder” you can reproduce: custody narrative, valuation policy, pricing lineage, and reconciliations.
  • If staking or yield is in scope, expect deeper evidence requirements around classification and cut off.

Accounting firms

  • Standardize crypto ETF procedures and workpapers so teams are consistent across engagements.
  • Require client deliverables that are reperformable: not just balances, but lineage, exceptions, and tie outs.

Treasury companies

  • Tighten internal controls and documentation for custody and valuation now, before you need it under time pressure.
  • If stablecoins are material, track the FASB cash equivalents project and plan for potential presentation and controls implications. 

Institutional validators

  • ETF growth increases institutional scrutiny on staking outputs, reward attribution, and fee reporting.
  • Expect stronger downstream demands for evidence quality and reproducibility from partners and clients. 

2026 readiness checklist

If you want a fast gut check, start here:

  1. Custody and access controls
    Separation of duties, key management, authorization workflows, and audit logs.
  2. Disruption playbook
    Forks, airdrops, chain issues, incident response, and continuity planning. 
  3. Valuation policy
    Pricing source selection, timestamp conventions, outlier handling, and historical retention.
  4. Closed loop reconciliation
    Source records to on chain evidence (when relevant) to custodian and administrator to GL.
  5. Deterministic outputs
    Can someone else rerun the process and land on the same results?

How NODE40 helps

NODE40 is built for defensible reporting in messy on chain realities. For ETF and institutional workflows, the most valuable outcome is not another dashboard. It is an evidence pack:

  • Reperformable valuation support (source, time, exceptions, history)
  • Custody and control artifacts aligned to what audit teams test
  • Deterministic categorization for staking rewards, fees, and complex flows
  • Reconciliations that close the loop across systems

If you are heading into a 2026 close cycle and want to reduce audit churn, the fastest win is to standardize your evidence pack and make it repeatable.