18.03.2025
Ezequiel Gomes
Contributor
18.03.2025

Nasdaq requests SEC approval to list 21Shares Polkadot Trust shares

Nasdaq requests SEC approval to list 21Shares Polkadot Trust shares Nasdaq requests SEC approval to list Polkadot Trust shares

​Nasdaq has submitted a rule change application to the U.S. Securities and Exchange Commission (SEC) seeking approval to list and trade shares of the 21Shares Polkadot Trust. 

If approved, the trust will allow investors to gain exposure to Polkadot (DOT) without directly purchasing or managing the cryptocurrency, according to the Cryptopolitan.

The application, filed under Section 19(b)(1) of the Securities Exchange Act of 1934, classifies the trust’s shares as commodity-based securities under Nasdaq Rule 5711(d). The trust aims to track the price of DOT without engaging in active management or speculation.

Structure and mechanics of the trust

According to the filing, 21Shares US LLC will serve as the trust’s sponsor, while CSC Delaware Trust Company will act as trustee. Coinbase Custody Trust Company will securely store all DOT holdings. The trust will determine its net asset value (NAV) daily, using the CME CF Polkadot-Dollar Reference Rate.

Unlike some crypto investment vehicles, the 21Shares Polkadot Trust will not engage in staking, lending, or yield-generating activities. The trust will also decline airdropped or forked tokens.

Shares will be created and redeemed in blocks of 10,000, known as Baskets, through Authorized Participants—financial institutions approved to interact with the trust. Instead of handling DOT directly, they will conduct all transactions in cash, with a separate DOT Counterparty managing crypto purchases and sales on behalf of the trust.

Nasdaq emphasized in its filing that the trust does not qualify as an investment company under the Investment Company Act of 1940 and will not be subject to Commodity Futures Trading Commission (CFTC) regulations. The SEC’s decision will determine whether the trust can move forward with its listing.

Meanwhile, Nasdaq has recently taken a significant step toward expanding digital asset offerings by filing to list the Canary HBAR ETF, designed to provide investors exposure to Hedera’s native token, HBAR.

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