Nasdaq Files to List and Trade Shares of the 21Shares Spot Dogecoin (DOGE) ETF

Nasdaq has filed a 19b-4 application with the U.S. Securities and Exchange Commission (SEC) to list and trade shares of the 21Shares spot Dogecoin (DOGE) exchange-traded fund (ETF).

The filing, which was submitted on April 29, 2025, is part of a broader initiative by several asset managers to introduce crypto ETFs to retail investors.

Earlier this month, 21Shares submitted an S-1 to register a spot-based Dogecoin ETF with the SEC. The ETF, which would be structured as a commodity-based trust, is designed to track the performance of Dogecoin.

Nasdaq's filing, which is made Section 19(b)(1) of the 1934 Securities Exchange Act, discloses that 21Shares's Dogecoin ETF will be listed and traded on the exchange under its Rule 5711(d), which covers commodity-based trust shares.

The Dogecoin ETF will be organized as a Maryland statutory trust, with 21Shares serving as the sponsor, manager, and third-party administrator. A trust company based in Maryland will act as the trustee, while Coinbase Custody will hold the ETF's Dogecoin on behalf of the trust.

The investment objective of the 21Shares spot Dogecoin ETF is to provide investment results that correspond to the price return of Dogecoin.

It is a passive investment vehicle, which means it will not engage in speculative trading of DOGE or attempt to generate additional returns. Instead, the ETF aims to simply mirror the performance of Dogecoin through the CF DOGE-Dollar US Settlement Price Index.

Unlike some other types of ETFs that use derivatives, leverage, or buy assets at lower prices to sell at higher ones, this ETF is designed to track Dogecoin's price without any attempt to generate additional returns or capitalize on price changes.

This approach ensures that the 21Shares Dogecoin ETF remains straightforward, with no active management or speculative trading strategies. The goal is for the ETF to provide a reliable and transparent way for investors to gain exposure to Dogecoin's performance in the broader market.

Along with 21Shares, Bitwise and Grayscale are also applying for approval of their own spot-based Dogecoin ETFs. These ETFs are designed to make it easier for traditional investors to access cryptocurrency markets, without the need for directly purchasing and managing digital assets.

NYSE Arca has already submitted exchange applications for Bitwise's Dogecoin ETF and Grayscale's converted Dogecoin Trust. The SEC has acknowledged these filings, and the final deadline for approval of these applications is October 11 and November 12, 2025, respectively.

If approved, Nasdaq would add the 21Shares Dogecoin ETF to its diverse range of products and services. The exchange is a leading platform for listing equities, ETFs, and other securities.

Earlier this year, Gemini announced the listing of two new institutional-grade Bitcoin futures ETFs on Nasdaq. These ETFs, issued by Gemini and managed by Factorial, are designed to provide investors with a liquid and transparent way to invest in Bitcoin futures contracts.

The SEC is expected to acknowledge Nasdaq's application for the 21Shares Dogecoin ETF within two weeks, which would officially begin a 240-day review period. During this time, the SEC will decide whether to approve or disapprove the application.

The filing from Nasdaq also mentions that the SEC has made it clear that cryptocurrency coins like Dogecoin are not classified as securities. This is a key point for potential investors, as it highlights the regulatory landscape for cryptocurrencies in the U.S.

In contrast to many other cryptocurrencies that have faced scrutiny by the SEC regarding their classification as securities, which has complicated the approval process for ETFs based on those assets, the SEC has stated that cryptocurrency coins are not to be classified as securities.

This clarification from the SEC helps solidify Dogecoin's place in the financial ecosystem, as it is now officially recognized as a commodity rather than a security. Ultimately, the decision on whether to approve or disapprove the 21Shares Dogecoin ETF will rest with the SEC.

Nasdaq's application to list the 21Shares Dogecoin ETF is part of a broader trend of increasing interest in cryptocurrencies among traditional financial institutions.

As the industry continues to grow and evolve, we can expect to see more asset managers file applications for crypto ETFs, and existing asset managers expand their offerings in this rapidly developing asset class.