Unveiling the Path to Standardized Spot Crypto ETFs in the US Market
In the ever-evolving world of cryptocurrency, the drive to standardize how US exchanges list spot crypto ETFs is reaching a critical juncture. Quiet yet strategic modifications in rule filings are laying the groundwork to expand beyond Bitcoin and Ethereum, potentially paving the way for single-asset products like XRP and Dogecoin.
The Imminent Arrival of Spot XRP and Dogecoin ETFs
The shift in momentum isn’t due to a flashy announcement from the Commission but rather the synchronized efforts of three major national exchanges: Cboe BZX, NYSE Arca, and Nasdaq. These exchanges are aligning nearly uniform generic listing standards (GLS) for Commodity-Based Trust Shares. The proposed standards would allow qualifying commodity ETPs, including those holding “digital asset commodities,” to list without the need for bespoke 19b-4 approvals each time. In return, the products must meet specific criteria, and the exchanges are required to uphold strict surveillance measures. NYSE Arca’s Rule 8.201-E (Generic), Nasdaq’s amendments to Rule 5711(d), and Cboe’s revamped Rule 14.11(e)(4) collectively aim to streamline the approval process for spot crypto ETFs while safeguarding market integrity.
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Key Amendments in Commodity Definition
One significant technical amendment in these filings involves redefining the term “commodity.” Greg Xethalis, General Counsel at Multicoin Capital, highlighted these subtle yet impactful changes. The exchanges have amended their Commodity-Based Trust Shares ETP Generic Listing Standards to exclude certain instruments like interest-rate indexes or currencies from being inadvertently categorized under the Commodity Exchange Act’s “excluded commodity” provision. Nasdaq’s filing further elucidates this, explicitly carving out these exclusions and referencing the CEA §1a(19) definition for clarity.
The Futures-Market Seasoning Test
An integral aspect of the proposal is the futures-market seasoning test, which many view as a crucial step for new spot products. Cboe’s proposal stipulates that the underlying asset must be associated with a futures contract available for trading on a Designated Contract Market for a minimum of six months. Additionally, a surveillance-sharing agreement with the DCM is required. The “made available to trade” wording anchors the six-month timeline to the contract’s listing date, aligning with the SEC’s approach since the 2024 approvals for spot-BTC and spot-ETH.
ETF Applications in the Pipeline
The XRP and Dogecoin applications have already entered the 19b-4 pipeline. If standardized listing rules are approved by late September or early October, they would coincide perfectly with the final statutory deadlines for these applications.
The XRP Timeline
For XRP, several spot filings are in motion. The CoinShares XRP ETF on Nasdaq was published in the Federal Register on February 25, 2025, with proceedings initiated on May 29 and extended on August 21. According to Exchange Act timing, the 240-day deadline from publication lands on October 23, 2025. On NYSE Arca, the Grayscale XRP Trust reached the Register on February 20, 2025, with the 180th day falling on August 19, and the 240-day date on October 18, 2025. Meanwhile, Cboe BZX’s Canary XRP Trust entered the queue with a publication date of February 25, 2025, also pointing to October 23, 2025, as the outside date. These filings exemplify the 19b-4 listing process, although S-1 registrations must still become effective before shares are traded.
The Dogecoin Timeline
For Dogecoin, several spot proposals provide comparable milestones. The Bitwise Dogecoin ETF on NYSE Arca was issued on March 17, 2025, setting a 240-day outside date of November 12, 2025. On Nasdaq, the 21Shares Dogecoin ETF notice was published on May 19, 2025, implying an outside date of January 14, 2026. Grayscale’s Dogecoin Trust filed an S-1 on August 15, 2025, disclosing that NYSE Arca submitted its companion 19b-4 on January 31, 2025, indicating that issuers have been preparing thoroughly for approval.
The overarching implication is that if the SEC approves the generic listing standards as anticipated, the calendar aligns neatly with XRP’s October 18–23 deadlines, and Dogecoin’s November 12 follow-up, creating the “floodgates” scenario described by industry insiders.
Conclusion
As of this writing, XRP is trading at $2.81, poised for potential market shifts. The synchronization of exchange efforts and the SEC’s anticipated approval could mark a significant turning point, heralding a new era for the cryptocurrency ETF landscape.
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