The U.S. Securities and Exchange Commission (SEC) recently approved generic listing standards for commodity-based exchange-traded products (ETPs)—explicitly including crypto asset commodities—so that qualifying ETFs can list without a bespoke § 19(b) order for each product.¹ In practical terms, exchanges that adopt these standards may list a crypto ETP that meets the criteria through Rule 19b-4(e) without separate Commission approval, compressing time-to-market for products that fit pre-approved guardrails.² Paired with the SEC’s authorization of in-kind creation/redemption mechanics for certain crypto ETPs, the process is beginning to look less like bespoke exception-making and more like the standardized pipelines used for other commodity and equity ETPs.³

What Is an ETF?

An exchange-traded fund (ETF) is a pooled vehicle that holds a basket of assets (e.g., stocks, bonds, commodities) and issues shares that trade intraday on exchanges. Liquidity and price discipline come from authorized participants (APs) who create and redeem shares—often in-kind, delivering the underlying assets—which helps keep the ETF’s market price close to net asset value (NAV). ETFs differ from some exchange-traded products (ETPs) that are not registered investment companies (e.g., many commodity or crypto ETPs), but the core creation/redemption plumbing—and the role of APs—is analogous.⁴⁵⁶

From the Old Regime to the New

Until now, most crypto ETPs navigated a dual hurdle: (1) an exchange’s § 19(b) rule-change filing for listing, and (2) the issuer’s registration and staff review. Many applications were delayed or denied amid concerns about manipulation, custody, surveillance-sharing, and price discovery. In January 2024, however, the SEC allowed the listing and trading of multiple spot Bitcoin ETPs, a watershed that set the stage for later process refinements.⁷ The Commission subsequently approved spot Ether ETPs in May 2024.⁸ The move to generic listing standards continues that arc by allowing exchanges to list qualifying commodity-based trust shares—including crypto—under a pre-approved rule set, while leaving atypical or complex products to the traditional, bespoke route.¹²

In-Kind Creations & Redemptions: A Key Operational Shift

Historically, early crypto ETPs were often limited to cash-only creations/redemptions, which added friction and cost. In July 2025, the SEC permitted in-kind creations/redemptions for certain bitcoin- and ether-based products—aligning crypto ETP operations with established commodity ETP practice and improving arbitrage mechanics.³ Law-firm analyses explain why this matters for costs, tax efficiency, and institutional participation.⁹¹⁰

Wall Street’s Long Pursuit of Crypto Access

This pivot lands after more than a decade of persistent institutional demand for regulated crypto exposure. The SEC approved futures-based bitcoin ETFs in 2021, providing a first regulated pathway—albeit via derivatives rather than spot holdings.¹¹ The Commission’s 2017 disapproval of the Winklevoss Bitcoin Trust proposal is emblematic of the earlier era’s surveillance and manipulation concerns that repeatedly stalled spot products.¹² With surveillance-sharing, futures-market correlations, and improved custody practices, the Commission ultimately permitted direct exposure in 2024, and exchanges are now moving toward generic standards for listings that meet clearly enumerated criteria.¹²⁷⁸

How the New Framework Works

Under Rule 19b-4(e), a “new derivative securities product” that fits an exchange’s Commission-approved generic standards can list without a separate § 19(b) approval.² The September 2025 approvals adopted generic standards for commodity-based trust shares across multiple exchanges; in related actions, the Commission also approved ancillary market-structure components (e.g., index options) that help integrate crypto exposure into existing trading ecosystems.¹ Commissioner Hester Peirce supported the modernization as consistent with the 2019 ETF Rule’s emphasis on standardized conditions; Commissioner Caroline Crenshaw cautioned that faster listings increase the importance of robust surveillance and clear disclosures as product types diversify.¹³¹⁴⁶

Immediate Implications—and Early Use

Shortly after adoption, exchanges and issuers began positioning products to route through the generic pathway when eligible. For example, the Commission approved NYSE Arca’s proposal to list Grayscale Digital Large Cap Fund (GDLC)—a multi-crypto product—after setting aside a delegated staff action, illustrating how a rules-based framework can be paired with targeted reviews for non-standard features.¹⁵ Financial press coverage underscores expectations of shorter timelines for qualifying products and a broader slate of filings.¹⁶¹⁷

Risks, Constraints & Open Questions

• Eligibility limits: Not all tokens have sufficiently deep regulated futures markets or pricing inputs to qualify under generic standards.
• Exchange burden: Listing venues shoulder ongoing surveillance, compliance, and disclosure responsibilities under their rulebooks.
• Fallbacks remain: Leveraged, actively managed, complex baskets, or products outside the standards still require bespoke § 19(b) review.
• Operational readiness: Custody models, index governance, fork/staking policies, tax treatment, and AP networks remain make-or-break details.
• Ongoing oversight: Even after listing, crypto ETPs face examination, enforcement, and evolving staff guidance.

Looking Ahead

Crypto ETFs are shifting from niche instruments to standardized building blocks—especially for institutions that prefer exchange-traded wrappers with familiar plumbing. The generic-standards + in-kind combination lowers friction and invites more experimentation—under watchful eyes. Over the coming quarters, expect more filings, more index methodologies, and continuing debates over which digital assets clear the bar.