When choosing a Bitcoin-backed loan provider in Australia, not all platforms offer the same level of security, transparency, and protection for your digital assets. This detailed comparison examines two prominent Australian Bitcoin lending platforms—Vield and Block Earner, across critical criteria that matter most to borrowers seeking to leverage their Bitcoin holdings.
While both platforms enable Australians to borrow AUD against cryptocurrency collateral, significant differences exist in their approach to custody, transparency, regulatory compliance, asset protection, and crucially, tax treatment. This analysis provides an evidence-based assessment to help you make an informed decision about where to entrust your Bitcoin assets.
Vield vs. Block Earner
Vield positions itself as Australia's most secure and transparent Bitcoin-backed loan provider, emphasizing institutional-grade custody, comprehensive insurance, a strict no-rehypothecation policy, and the only ATO-confirmed CGT-neutral loan structure in Australia. While Vield's rates are higher than some competitors, the platform delivers superior asset protection, tax certainty, and transparency that justify the premium.
Block Earner offers competitive rates and a broader product suite including crypto exchange services, DeFi access, and various yield products. However, the platform has faced regulatory scrutiny, operates with less transparency regarding custody arrangements, and has no ATO confirmation on CGT treatment for loan collateral.
Quick Comparison Table
Comparison Criteria
We've evaluated both platforms across nine critical dimensions:
1. Capital Gains Tax (CGT) Treatment
Vield: Australia's Only ATO-Confirmed CGT-Neutral Bitcoin Loan
In October 2025, Vield achieved a groundbreaking milestone: securing a Private Binding Ruling from the Australian Taxation Office (Authorisation Number 1052452380351) confirming that depositing Bitcoin as loan collateral through Vield's platform does not trigger a Capital Gains Tax event. This is the first and only such ruling obtained by any crypto lending platform in Australia.
Why This Matters:
For Bitcoin holders with substantial unrealised gains, this ruling eliminates what could be a six-figure tax liability. Consider a typical scenario:
- A Bitcoin holder purchased 2 BTC for $20,000 in 2020
- Those 2 BTC are now worth $200,000 (representing $180,000 in unrealised capital gains)
- They want to borrow $100,000 AUD using their Bitcoin as collateral
- Without CGT protection, depositing that Bitcoin could trigger a $90,000 CGT liability (50% of gains taxed at 50% marginal rate)
- With Vield's ATO-confirmed structure, no CGT event occurs – you borrow the $100,000 without any tax consequences
The Legal Foundation: Section 106-60
Vield's CGT protection operates through Section 106-60 of the Income Tax Assessment Act 1997, which disregards asset transfers made purely for security purposes. The ATO confirmed that Vield's structure satisfies this provision because:
- Segregated custody: Your Bitcoin is held in a wallet uniquely associated with you, not pooled with other customers' assets
- No rehypothecation: Vield has no rights to use, transfer, or redeploy your collateral during the loan term
- Clear security documentation: The loan agreement expressly states that the transfer is for security purposes only
- Perfected security interest: A PPSA charge can be registered over the Bitcoin, though it would be impractical
This is also the first time the ATO has ruled on Section 106-60 in over a decade, making it a landmark decision for the crypto lending industry.
Block Earner: No ATO Confirmation on CGT Treatment
Block Earner has no ATO guidance confirming the CGT treatment of loan collateral deposits. This means that borrowers using Block Earner's platform operate without any certainty about whether depositing their Bitcoin triggers a taxable CGT event.
The Risk for Block Earner Users:
Under ordinary CGT principles, transferring Bitcoin to a custodian's wallet (where you no longer control the private keys) looks like a change of ownership – which would constitute a disposal under CGT Event A1. For borrowers with substantial unrealised gains, this interpretation would mean:
- Immediate crystallisation of all accumulated capital gains
- Tax liability potentially running into tens or hundreds of thousands of dollars
- Making the loan economically unviable for long-term Bitcoin holders
- Potential ATO audit risk if CGT is not declared and paid
While Block Earner's structure may theoretically qualify for Section 106-60 protection, without ATO confirmation, borrowers cannot be certain. The platform's historical rehypothecation practices (lending customer crypto to third parties during the Earner product period) may also complicate any Section 106-60 analysis.
The Vield Advantage: Tax Certainty Worth More Than Rate Savings
For a borrower with $180,000 in unrealised Bitcoin gains, the potential CGT liability ($90,000) would dwarf any interest rate savings from choosing a cheaper platform. Even if Block Earner's rates were 5% lower than Vield's 13% APR, you would need to borrow for 11 years before the interest savings equaled the upfront CGT cost.
Vield is the only platform where borrowers can proceed with complete tax certainty, backed by formal ATO confirmation. This protection alone can save borrowers more money than a decade of interest rate differences.
Note on DeFi Lending and CGT:
The ATO has indicated that decentralized finance (DeFi) lending arrangements may also trigger CGT events. Block Earner's "Access" product provides one-click connection to DeFi protocols like Aave and Compound. Users of these DeFi features should be aware that the ATO has not provided clear guidance on the CGT treatment of DeFi deposits, creating additional tax uncertainty beyond the uncertainty already present with centralized crypto-backed loans. Vield's focus on traditional, regulated loan structures with confirmed CGT treatment avoids this additional layer of complexity.
2. Asset Custody & Security Architecture
Vield: Institutional-Grade Protection
Vield utilizes Zodia Custody, an FCA-registered institutional custodian backed by major financial institutions including Standard Chartered Bank, Northern Trust, SBI Holdings, and National Australia Bank. This partnership delivers:
- Multi-signature wallet technology with distributed governance frameworks
- Cold storage solutions using FIPS 140-2 Level 3 hardware-enforced security
- Air-gapped systems that provide 24/7 real-time access while maintaining maximum security
- Individual wallet segregation where each client receives a unique blockchain address with complete visibility
- No commingling of funds ensuring your assets remain separate from other customers
Every loan is transparently recorded on the blockchain, allowing borrowers to verify their collateral's location and security status at any time.
Block Earner: Limited Custody Transparency
Block Earner's custody arrangements are less transparent. While the platform has partnered with Fireblocks for security infrastructure:
- Custody details are not prominently disclosed on their platform
- No publicly available information about wallet segregation practices
- Limited transparency regarding whether client assets are commingled
- Historical use of customer assets for lending to third parties (during the Earner product period)
The platform's website states assets are "secured with Fireblocks" but provides minimal detail about the specific custody architecture or client asset segregation.
3. Insurance Coverage
Vield: USD $55-200 Million Per Incident
Vield provides comprehensive insurance through Zodia Custody covering:
- Up to USD $55-200 million per incident depending on incident type (theft, hacking, cyber incidents, etc.)
- Institutional-grade coverage that protects client assets against various security threats
This level of protection is typically reserved for institutional investors and represents a significant commitment to asset safety.
Block Earner: Coverage Details Unclear
Block Earner does not prominently disclose insurance coverage details on their current website. While historical sources mentioned custody insurance arrangements:
- No current insurance information available on the platform's website
- Previous references to insurance (from 2023) may be outdated
- Unclear which products or customers benefit from any insurance coverage
- No detailed information about coverage terms, exclusions, or claim processes
The lack of clear, accessible insurance information creates uncertainty for borrowers about whether their specific collateral is actually insured.
4. Rehypothecation Policy
Vield: Absolute Non-Rehypothecation Guarantee
Vield explicitly commits to never rehypothecating client assets:
- Assets remain untouched throughout the entire loan term
- No lending, staking, or reuse of your collateral under any circumstances
- Stored in cold storage with multi-layer protection via Zodia Custody
- Clear contractual commitment outlined in terms and conditions
- Essential for CGT protection – the no-rehypothecation policy is a key requirement for the ATO ruling
This policy ensures your Bitcoin remains exactly where you deposited it, eliminating counterparty risk from third-party lending activities.
Block Earner: Historical Rehypothecation Practices
Block Earner's history with asset use raises important questions:
- During the "Earner" product period (2022), Block Earner lent customer crypto to third parties at higher interest rates to generate profit
- The Full Federal Court decision confirmed that "Block Earner would loan cryptocurrency borrowed from investors, together with its own cryptocurrency, to third parties"
- While the Earner product has been discontinued, current rehypothecation policies for loan collateral are not clearly stated
- No prominent disclosure about whether current loan collateral remains segregated and unused
- Historical rehypothecation may complicate any Section 106-60 CGT analysis
This historical practice, combined with limited current disclosure, creates uncertainty about how your collateral is handled and whether CGT protection could apply.
Key Differentiators: Why Vield Stands Out
Tax Certainty: The Ultimate Differentiator
Vield is the only Bitcoin lending platform in Australia with ATO confirmation that deposits don't trigger CGT. For borrowers with substantial unrealised gains, this single advantage can save more money than decades of interest rate differences. The CGT protection, backed by a formal Private Binding Ruling, eliminates six-figure tax risks that other platforms cannot address.
The Security Premium
Vield's partnership with Zodia Custody—backed by Standard Chartered, Northern Trust, SBI Holdings, and NAB—provides access to institutional-grade infrastructure typically reserved for banks and hedge funds. This isn't marketing language; it's a fundamental architectural difference in how your assets are protected.
Transparency You Can Verify
Unlike platforms where you must trust the provider's assurances, Vield enables independent verification. You can personally examine the blockchain to confirm your collateral's location, see it hasn't moved, and verify the loan structure. This transparency eliminates the need for blind trust.
No Hidden Asset Use
Vield's absolute non-rehypothecation policy means your Bitcoin or Ethereum sits untouched in cold storage. It's not being lent out, staked, used for liquidity, or exposed to any third-party risks. This policy is both a security measure and a requirement for CGT protection. Block Earner's historical practice of lending customer crypto to third parties demonstrates a fundamentally different philosophy about asset use.
The Safer Choice for Australian Bitcoin Borrowers
Both Vield and Block Earner serve the Australian Bitcoin-backed loan market, but they do so with fundamentally different approaches to security, transparency, tax treatment, and customer asset protection.
Block Earner offers competitive rates and a broad suite of crypto services, making it attractive for borrowers focused primarily on cost minimization. However, the platform's limited custody transparency, unclear insurance coverage, historical asset rehypothecation practices, ongoing regulatory litigation, and complete absence of CGT certainty create meaningful risks that borrowers should carefully consider.
Vield provides institutional-grade security and tax certainty at a premium price point. The higher cost reflects genuine, verifiable differences in custody infrastructure, insurance coverage, transparency mechanisms, regulatory certainty, and ATO-confirmed CGT protection. For borrowers with substantial unrealised Bitcoin gains, the CGT protection alone can save more than a decade of interest payments. When combined with superior security and transparency, Vield's premium represents essential value rather than unnecessary expense.
The Australian Bitcoin lending market offers choices that reflect different priorities. Vield's position is clear: when you're entrusting potentially life-changing amounts of Bitcoin to a third party, security, transparency, and tax certainty aren't luxuries—they're requirements.
Vield acknowledges it isn't the cheapest option. However, for borrowers who understand that the lowest interest rate means little if your collateral isn't properly protected or if you face a massive unexpected tax bill, Vield delivers the transparency, security, and peace of mind that justify the premium.
Ready to Experience Institutional-Grade Bitcoin Lending with Tax Certainty?
Discover how Vield's commitment to security, transparency, and customer asset protection—backed by ATO-confirmed CGT protection—creates a fundamentally safer and more tax-efficient borrowing experience. Get started with:
- ATO-confirmed CGT-neutral structure – the only platform in Australia with tax certainty
- 24/7 blockchain verification of your collateral
- $55-200M USD institutional insurance coverage(varies by incident type)
- Absolute non-rehypothecation guarantee
- Full Australian regulatory licensing
- Same-day AUD disbursement
This comparison is based on publicly available information as of January 2026. Tax treatment information is based on ATO Private Binding Ruling 1052452380351 obtained for Vield's specific loan structure. Readers should conduct their own research and seek independent tax and legal advice before making borrowing decisions. Cryptocurrency investments and Bitcoin-backed loans involve significant risks. Consider your financial circumstances and risk tolerance carefully.
.png)
