Spot crypto ETFs: what changed from 2024 to now, and why finance teams care
From the first spot bitcoin approvals to generic listing standards, in-kind creations and staking: what the products are, and how their numbers are built.
If your company, fund or DAO holds spot crypto exchange-traded products, or is weighing them against holding coins directly, the rules around these products have moved a long way in under three years. The practical questions for a finance team are what you actually own, how the product is valued, and where its numbers differ from your own.
January 2024: bitcoin, narrowly
On 10 January 2024 the SEC approved the listing and trading of several spot bitcoin exchange-traded products [1]. The then-chair's statement stressed how narrow the decision was: it covered products holding one non-security commodity, bitcoin, and the agency said it was not approving or endorsing bitcoin itself or the custody and trading platforms involved [1]. The statement also noted that the approval followed a court ruling that the agency had not adequately explained earlier denials [1].
May 2024: ether follows
On 23 May 2024 the SEC granted accelerated approval to rule changes from NYSE Arca, Nasdaq and Cboe BZX allowing ether-based exchange-traded products to list (Release No. 34-100224) [2]. The trusts would hold spot ether, and the order noted that the proposals did not contemplate staking it [2]. At launch, both the bitcoin and ether products created and redeemed shares for cash only [3].
July 2025: in-kind creations and redemptions
On 29 July 2025 the SEC approved orders permitting authorized participants to create and redeem shares of crypto ETPs in kind, meaning by delivering or receiving the underlying coins rather than cash [3]. The agency described this as a departure from the cash-only model of the earlier spot bitcoin and ether approvals and as bringing them in line with other commodity-based ETPs [3]. The same set of actions approved a product holding both spot bitcoin and spot ether, options on certain bitcoin ETPs, and higher option position limits [3].
September 2025: generic listing standards
On 17 September 2025 the SEC approved generic listing standards proposed by three exchanges for commodity-based trust shares, including those that hold digital assets [4]. An exchange can now list a product that meets the standard without first filing a separate rule change under Section 19(b) of the Exchange Act [4]. The same day the SEC approved the Grayscale Digital Large Cap Fund, which holds several assets based on the CoinDesk 5 Index [4].
According to a law-firm summary of the approved standards, the underlying asset must meet at least one of three tests: it trades on a market that belongs to the Intermarket Surveillance Group; it has underlain a futures contract on a designated contract market for at least six months; or an ETF with at least 40% exposure to it is already listed [5]. Leveraged and inverse products cannot use the generic route, and each product still needs an effective registration statement [5].
October 2025: staking inside an ETP
The 2024 ether proposals did not include staking [2]. That changed for at least one large issuer: the Grayscale Ethereum Trust, since renamed the Grayscale Ethereum Staking ETF, says its staking condition was met on 6 October 2025 and it began staking that day through third-party providers [6]. Its filing says that, as of that date, the sponsor's staking fee, the custodian's fee and the provider's share together took 23% of gross staking rewards, with the trust keeping the rest [6]. The sponsor decides whether rewards are distributed in ether, sold and distributed as cash, or kept [6].
| Date | What happened |
|---|---|
| 10 Jan 2024 | First spot bitcoin ETPs approved [1] |
| 23 May 2024 | Spot ether ETP rule changes approved [2] |
| 29 Jul 2025 | In-kind creations and redemptions permitted [3] |
| 17 Sep 2025 | Generic listing standards approved [4] |
| 6 Oct 2025 | A large ether ETP begins staking [6] |
Custody and pricing: read the filing
Each product's annual report sets out who holds the coins and how they are priced. For example, the iShares Bitcoin Trust's 2025 annual report names Coinbase Custody Trust Company and Anchorage Digital Bank as custodians, with a separate trading balance held at a prime execution agent for creations, redemptions and fees [7]. It values bitcoin for its daily net asset value using the CME CF Bitcoin Reference Rate New York Variant, struck after 4:00 p.m. Eastern time [7].
That benchmark is not necessarily the price used in the trust's audited financial statements. The iShares report warns that its index methodology may not be considered consistent with US GAAP [7], and the Grayscale ether product reports both an index-based NAV and a separate figure based on the price in what it treats as its principal market at 4:00 p.m. New York time [6]. If you reconcile your position to a fund's published NAV, be clear which of the two numbers you are using.
What you own when you hold the shares
Owning ETP shares is not the same as owning coins. The fair-value crypto guidance in ASU 2023-08 applies only to assets that, among other tests, meet the definition of an intangible asset and give the holder no enforceable rights to or claims on underlying assets [8]. A share in a trust is a claim on the trust's assets, so it does not fit that scope [8]. Most teams will therefore look to the investment-securities guidance instead; agree the classification with your auditor.
The practical differences show up in the books. You hold a brokerage position, not a wallet balance, so reconciliation is to a broker statement. Sponsor fees reduce the coins backing each share over time [7]. With a staking product, rewards build up inside the trust and reach you only if the sponsor chooses to distribute them [6].
What to do
- Keep ETP shares in a separate ledger category from directly held coins, and record the broker as the counterparty and evidence source.
- For each product you hold, note its custodian, benchmark rate, sponsor fee and creation model (cash or in-kind) from the latest annual report.
- When you compare to a fund's NAV, state whether you used the index-based NAV or the principal-market figure.
- For staking products, find out how the sponsor treats rewards and whether and when it distributes them before you decide how to record any distribution.
- Agree the accounting classification of ETP shares with your auditor before quarter end, and document why ASU 2023-08 does not apply.
Sources
- Statement on the Approval of Spot Bitcoin Exchange-Traded Products (U.S. Securities and Exchange Commission)
- Order Granting Accelerated Approval of Proposed Rule Changes, as Modified by Amendments Thereto, To List and Trade Shares of Ether-Based Exchange-Traded Products (Release No. 34-100224) (U.S. Securities and Exchange Commission)
- SEC Permits In-Kind Creations and Redemptions for Crypto ETPs (Press Release 2025-101) (U.S. Securities and Exchange Commission)
- SEC Approves Generic Listing Standards for Commodity-Based Trust Shares (Press Release 2025-121) (U.S. Securities and Exchange Commission)
- Crypto and Commodity-Based ETPs Poised to Boom Following SEC's Approval of Generic Listing Standards (Goodwin Procter)
- Grayscale Ethereum Staking ETF, Form 10-K for the year ended December 31, 2025 (U.S. Securities and Exchange Commission (EDGAR))
- iShares Bitcoin Trust ETF, Form 10-K for the year ended December 31, 2025 (U.S. Securities and Exchange Commission (EDGAR))
- FASB issues final ASU on crypto asset accounting (KPMG)
General information for finance teams, current as of publication. Not legal, tax or accounting advice.