Question
An SMSF holds Bitcoin, gold, unlisted shares and investment property. How should these assets be valued at 30 June 2027? Are certified valuers required? Can a real estate agent provide the property valuation, or can the directors of the corporate trustee do it themselves?
Answer
The standard is market value, supported by objective evidence. There is no general requirement to engage a certified valuer for the annual accounts. The trustees—or directors of the corporate trustee—can determine the values themselves, provided their methods and supporting evidence are reasonable and defensible.[1][3]
A real estate agent’s appraisal can also support a property valuation. What matters is the evidence behind the figure, not simply the signature on the letter.
What does the law require?
Regulation 8.02B requires fund assets to be valued at market value when preparing the accounts and statements required by section 35B of the SIS Act.[1]
Section 10 defines market value by reference to the amount a willing buyer could reasonably be expected to pay a willing seller, assuming an arm’s-length transaction, proper marketing, and knowledgeable and prudent parties.[2]
Historical cost, book value or a nominal amount is not sufficient merely because it appears in last year’s accounts. It can only be retained where evidence supports it as the current market value.
The ATO expects a valuation to consider relevant factors, use a rational process, rest on objective and supportable data, and be capable of explanation to another person.[3]
Can the directors do the valuation?
Yes—but a directors’ resolution is not a substitute for evidence.
The directors should retain the sources, calculations and assumptions supporting each figure. An unsupported statement that “we consider the property worth $1 million” does not become reliable merely because every director signs it.
The ATO recommends considering a qualified independent valuer where an asset represents a significant proportion of the fund or is difficult or complex to value.[3]
There are also specific exceptions to the general flexibility. For example, a related-party disposal covered by the collectables and personal-use asset rules requires a valuation by a qualified independent valuer.[3] That is different from an ordinary annual valuation of investment bullion or property.
Bitcoin
Use a reputable exchange’s historical closing price for 30 June, applied to the fund’s actual Bitcoin holding.[4]
Retain:
- The quantity held and records establishing the fund’s ownership.
- The exchange and quoted price used.
- The valuation time and time zone, because Bitcoin trades continuously.
- The Australian-dollar conversion, if necessary.
Ownership and valuation are separate audit questions. An exchange price supports the value; it does not establish that the fund owns the coins. A wallet address alone does not identify its legal owner.
Gold
For investment bullion, establish the quantity, weight and purity, then apply reliable market-price evidence at the valuation date.
Keep the dealer quotation or published price, any currency conversion, and custodian or storage records. Explain whether the quotation is a dealer’s buying or selling price and why it reasonably represents the holding’s market value.
Do not automatically apply a bullion spot price to jewellery, collectible coins or other items whose value depends on more than their metal content. Those assets may need specialist evidence and consideration of the separate collectables rules.
Unlisted shares
The method must suit the company and the rights attached to the shares. Relevant approaches can include:
- Recent arm’s-length transactions in comparable shares.
- Net assets adjusted to current market values, particularly for investment or property-holding companies.
- Earnings or discounted cash-flow methods for operating businesses, supported by defensible assumptions.
Check the underlying assets and liabilities, share classes, control rights and any justified minority or marketability adjustments. Last year’s company accounts or the original subscription price may not establish today’s value.[3]
The employee-share-scheme start-up valuation concessions are not a general valuation shortcut for an SMSF’s unlisted investments.
Investment property
A real estate agent’s appraisal can be acceptable evidence, particularly where it identifies relevant comparable sales and explains the property’s characteristics and the resulting valuation.[3]
A bare price range or unsupported opinion is much weaker. Obtain evidence supporting the particular figure adopted in the accounts.
Review the property’s value every year. There is no blanket requirement for a fresh independent report annually—or automatically every three years. However, an earlier report needs current supporting evidence, and significant market movements or property changes may make a new valuation necessary.[3]
The required figure is market value, not market value less hypothetical selling costs.
The practical approach
Prepare an annual valuation file containing the evidence for each asset, the method, calculations, assumptions and reasons for the adopted figure. A trustee minute recording those decisions is good governance, but does not replace the underlying evidence.
Discuss the evidence with the auditor early, especially for material property and unlisted shareholdings. The cheapest valuation is not necessarily the one that survives the audit.
This article addresses annual accounts under the law and ATO guidance checked on 8 November 2026. Recheck before 30 June 2027. Other events, such as pension commencement or an asset transfer, may require a valuation at a different date. General information only.
Prepared with assistance from Tax Guru AI; edited for publication.
Footnotes
- Superannuation Industry (Supervision) Regulations 1994, regulation 8.02B, annual accounts market-value requirement.
- Superannuation Industry (Supervision) Act 1993, section 10, definition of market value.
- ATO — Guide to valuing SMSF assets, valuation evidence, valuers, real property, unlisted investments and collectables.
- ATO — Auditing SMSFs with crypto assets, ownership evidence and year-end exchange pricing.