Nasdaq has officially 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 was submitted on April 29, 2025, under Section 19(b)(1) of the 1934 Securities Exchange Act. If approved, this move would mark a critical milestone for Dogecoin in the financial market, bringing the cryptocurrency closer to mainstream adoption.
Nasdaq’s Filing and Key Details
The filing from Nasdaq comes just three weeks after 21Shares submitted an S-1 application to introduce a spot-based Dogecoin ETF. This ETF would be structured as a commodity-based trust, designed to track the performance of Dogecoin. The filing outlines Nasdaq’s intention to list and trade 21Shares’ Dogecoin ETF under its Rule 5711(d), which deals with commodity-based trust shares.
In terms of structure, the Dogecoin ETF will be organized as a Maryland statutory trust, with 21Shares acting as the sponsor and manager. A trust company based in Maryland will serve as the trustee, while Coinbase Custody will hold the ETF’s Dogecoin on behalf of the trust. A third-party administrator will be appointed by 21Shares to oversee the operational aspects of the ETF.
Investment Objective of the 21Shares Dogecoin ETF
The 21Shares spot Dogecoin ETF is characterized as a passive investment vehicle, which means it will not engage in speculative trading of DOGE. 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 attempting to generate additional returns.
This approach ensures that the 21Shares Dogecoin ETF remains straightforward, without any active management or speculative trading strategies. The goal is for the ETF to provide a secure and transparent way for investors to gain exposure to Dogecoin’s performance in the broader market.
Growing Interest in Dogecoin ETFs
The filing by Nasdaq highlights the increasing interest in Dogecoin ETFs. Along with 21Shares, other major asset managers, such as Bitwise and Grayscale, are also seeking SEC approval for 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.
Already, NYSE Arca has 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 set for October 11 and November 12, 2025, respectively.
The SEC is expected to acknowledge Nasdaq’s application 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.
Regulatory Landscape for Dogecoin
One key point in the filing is that the SEC has made it clear that cryptocurrency coins like Dogecoin are not classified as securities. This provides clarity for potential investors, as it means that there is no regulatory uncertainty that could hinder the introduction of spot ETFs tied to Dogecoin. In contrast, many other cryptocurrencies have faced scrutiny by the SEC regarding their classification as securities, complicating the approval process for ETFs based on those assets.
This clarification helps solidify Dogecoin’s place in the financial ecosystem, as it is now officially recognized as a commodity rather than a security. This decision makes the approval process for the 21Shares Dogecoin ETF potentially smoother and faster.
Conclusion
Nasdaq’s application to list the 21Shares Dogecoin ETF marks an important step for the cryptocurrency industry, as it continues to gain acceptance in traditional financial markets. If approved, this ETF would provide investors with a new and more convenient way to gain exposure to Dogecoin. With several other asset managers following suit, the approval of Dogecoin ETFs could pave the way for greater mainstream acceptance of cryptocurrency investment vehicles.
