9.1 Introduction

On January 23, 2025, the SEC published SAB 122 to rescind the previous guidance in SAB 121. SAB 121 required an entity to recognize a liability and corresponding asset for its obligation to safeguard crypto assets. The rescission of SAB 121 will have a significant impact on the financial statements of entities that were previously within the scope of SAB 121. Full retrospective application of SAB 122 is required for annual periods beginning after December 15, 2024, but entities are permitted to early adopt SAB 122 in any interim or annual financial statement period included in filings with the SEC on or after January 30, 2025.1 While there is a short period before entities are required to formally adopt SAB 122, we have observed that most entities have early adopted SAB 122. While expected to be rare, there may be instances in which an entity is still applying SAB 121. See Appendix C for additional considerations related to SAB 121.