Spot Bitcoin ETF
An exchange-traded fund that holds actual BTC at a regulated custodian and trades on a traditional stock exchange. Approved by the US SEC on January 10, 2024 after years of rejections.
A spot Bitcoin ETF is an exchange-traded fund that holds actual BTC at a regulated custodian. Each share represents a fractional claim on the BTC held by the fund. The shares trade on a stock exchange (NYSE Arca, Cboe BZX, Nasdaq) with normal tickers, market hours, and clearing.
The road to approval:
- 2013 - In July 2013, Cameron and Tyler Winklevoss filed with the SEC to register the Winklevoss Bitcoin Trust. The SEC turned down the exchange listing it needed in March 2017 and again in July 2018.
- 2017-2023 - More rejections. By SEC Chair Gary Gensler's count, the SEC disapproved more than 20 exchange filings for spot bitcoin products from 2018 through March 2023, including proposed funds from Bitwise, VanEck, ARK 21Shares, Valkyrie, WisdomTree and Grayscale. The orders turned on the Exchange Act requirement that an exchange's rules be "designed to prevent fraudulent and manipulative acts and practices."
- October 2021 - ProShares launched BITO, the first US bitcoin-linked ETF. It held CME bitcoin futures, not spot BTC. In 2022 the SEC approved exchange listings for two bitcoin futures funds, from Teucrium and Valkyrie.
- August 2023 - A three-judge panel of the D.C. Circuit ruled that the SEC's denial of Grayscale's proposal to list GBTC was "arbitrary and capricious," because the SEC had not explained why it approved those two futures funds but not Grayscale's fund.
- January 10, 2024 - Eleven spot Bitcoin ETFs approved together.
The eleven funds in the SEC's January 2024 order, with the bitcoin custodians named in their annual reports filed in 2026:
- BlackRock iShares Bitcoin Trust (IBIT) - Coinbase Custody (Anchorage Digital is named as a backup the fund had not put to use)
- Fidelity Wise Origin Bitcoin Fund (FBTC) - Fidelity Digital Assets (Fidelity's own custodian), with BitGo added in February 2026 as a backup the fund had no plans to use
- Bitwise Bitcoin ETF (BITB) - Coinbase Custody
- Ark 21Shares Bitcoin ETF (ARKB) - Coinbase Custody, BitGo and Anchorage Digital
- Grayscale Bitcoin Trust (GBTC) - Coinbase Custody, with part of its bitcoin at Anchorage Digital; previously quoted over the counter on OTCQX
- VanEck Bitcoin Trust (HODL) - Gemini Trust, with Coinbase Custody as an additional custodian
- Valkyrie Bitcoin Fund (BRRR) - Coinbase Custody, BitGo and Komainu (sponsored by CoinShares since June 2024)
- Franklin Bitcoin ETF (EZBC) - Coinbase Custody
- WisdomTree Bitcoin Fund (BTCW) - Coinbase Custody
- Invesco Galaxy Bitcoin ETF (BTCO) - Coinbase Custody
- Hashdex Bitcoin ETF (DEFI) - BitGo; it was a bitcoin futures fund until March 27, 2024, when it switched to holding spot BTC
As of those reports, Coinbase Custody was a custodian for nine of the eleven and the only one holding bitcoin for five (IBIT, BITB, EZBC, BTCW and BTCO). Some funds have added custodians since launch: ARK 21Shares signed Anchorage Digital and BitGo in September 2024, and Grayscale signed Anchorage Digital in August 2025.
How the wrapper actually works:
- NAV strikes daily as of 4:00 PM New York time. Several funds, including the iShares Bitcoin Trust, use the New York variant of the CME CF Bitcoin Reference Rate (BRRNY); others use different benchmarks, such as the Fidelity Bitcoin Reference Rate.
- Authorized Participants create and redeem shares in large blocks. The mechanism keeps the market price close to NAV. GBTC's closing price, for example, averaged less than 0.1% away from NAV from its January 2024 uplisting through 2025, per its annual report.
- Creation/redemption was cash-only at launch. Most of the applications had planned for in-kind creation, but all were revised to cash-only during SEC review. On July 29, 2025 the SEC, under Chair Paul Atkins, voted to allow in-kind.
- Expense ratios in the funds' annual reports filed in 2026 run from 0.19% to 0.25% for most products. The exceptions are Grayscale's Bitcoin Mini Trust (BTC, launched 2024), the cheapest at 0.15%, and GBTC at 1.50%, cut from 2.0% when it converted in January 2024.
What spot ETFs changed:
- Brokerage access. Investors can buy and sell shares through an ordinary brokerage account and skip handling bitcoin themselves, as the iShares Bitcoin Trust's annual report puts it. Institutions bought in too. In 13F filings, the State of Wisconsin Investment Board, which manages Wisconsin's public pension funds, reported IBIT and GBTC shares as of March 31, 2024, and Harvard Management Company, which manages Harvard's endowment, reported IBIT shares as of June 30, 2025.
- The basis trade. Some traders buy spot ETF shares and sell CME bitcoin futures against them to earn the gap between futures and spot prices. CF Benchmarks reported in June 2024 that net short positions held by leveraged funds in CME bitcoin futures had grown since the spot ETFs launched, which it read as a sign of this trade.
Editorial: spot ETFs were a structural win for Bitcoin's monetary thesis - regulated demand at scale, daily marks against a credible reference rate, and access from accounts that can never hold the asset directly. They are also not Bitcoin. The keys sit with a custodian. The shares are an IOU on someone else's custody arrangement. The whole pitch of Bitcoin - censorship-resistant, bearer, verifiable - is exactly what the ETF wrapper removes. Use the ETF when the use case demands it. For long-term holders who can self-custody, owning the keys is the point.
Key takeaways
- Holds physical BTC, not futures contracts or other derivatives
- Eleven US spot Bitcoin ETFs were approved simultaneously on Jan 10, 2024
- A regulated wrapper around BTC, not BTC itself - the keys belong to the custodian
Related chapters
Corrected
Was: The entry said approval came after eleven years of rejections, starting with a Winklevoss application rejected in 2013, and quoted the SEC as repeatedly citing "manipulation in the underlying market".
Now: The Winklevoss Bitcoin Trust filed with the SEC in July 2013, and the SEC first turned down its exchange listing in March 2017. By Chair Gensler's count, the SEC disapproved more than 20 spot bitcoin filings from 2018 through March 2023. The orders turned on the Exchange Act requirement that an exchange's rules be designed to prevent fraudulent and manipulative acts and practices. Details
Was: The entry presented all eleven funds as spot products that launched on day one, said eight of them held their bitcoin at Coinbase Custody in a concentration not structurally addressed, and called GBTC's 1.50% fee a legacy of its days before conversion.
Now: Hashdex's DEFI held bitcoin futures until March 27, 2024. In annual reports filed in 2026, Coinbase Custody was a custodian for nine of the eleven but the only one for five, and several funds had added custodians such as Anchorage Digital and BitGo. GBTC's fee was cut from 2.0% to 1.5% when it converted in January 2024. Details
Was: The entry said the funds strike NAV against the CME CF Bitcoin Reference Rate at 4:00 PM London time, and put WisdomTree's BTCW fee at 0.50%.
Now: NAV is struck as of 4:00 PM New York time. Several funds, including the iShares Bitcoin Trust, use the New York variant of the CME CF Bitcoin Reference Rate, built from trades between 3:00 and 4:00 PM. BTCW charges 0.25%, inside the 0.19% to 0.25% range most funds give in their annual reports filed in 2026. Details
Sources (28)
- iShares Bitcoin Trust ETF - Form 10-K for 2025: bitcoin valued with the CME CF Bitcoin Reference Rate - New York Variant (3:00-4:00 PM ET window) after 4:00 PM ET; 40,000-share baskets; the AP bears execution price differences on cash orders; Coinbase Custody is the Bitcoin Custodian, and Anchorage Digital Bank is an Additional Bitcoin Custodian the sponsor had no plans to move bitcoin to; investors can buy and sell shares through traditional brokerage accounts without managing wallets or private keys (filed February 27, 2026)
- Fidelity Wise Origin Bitcoin Fund - Form 10-K for 2025: Fidelity Bitcoin Reference Rate; shares valued daily as of 4:00 PM Eastern; custody at its affiliate Fidelity Digital Assets, N.A.
- Franklin Bitcoin ETF - Form 10-K for the fiscal year ended March 31, 2026: NAV from the CME CF Bitcoin Reference Rate - New York Variant after 4:00 PM ET; the Bitcoin Custodian is Coinbase Custody
- SEC press release 2025-101 - SEC Permits In-Kind Creations and Redemptions for Crypto ETPs (July 29, 2025)
- Deloitte - The ETP breakthrough (March 19, 2024): most initial spot bitcoin ETP applications planned in-kind creations; all were revised to cash-only during the SEC comment period
- WisdomTree Bitcoin Fund - Form 10-K for 2025: Sponsor Fee of 0.25% per annum; Coinbase Custody is the Bitcoin Custodian
- Grayscale Bitcoin Mini Trust ETF - Form 10-K for 2025: Sponsor's Fee at an annual rate of 0.15%
- Grayscale Bitcoin Trust ETF - Form 10-K for 2025: Sponsor's Fee at an annual rate of 1.5%; shares uplisted to NYSE Arca on January 11, 2024, previously quoted on OTCQX; Coinbase Custody remains the primary custodian and Anchorage Digital (agreement dated August 8, 2025) holds a portion of the bitcoin; from January 11, 2024 to December 31, 2025 the NYSE Arca closing price averaged a 0.06% premium on premium days and a 0.08% discount on discount days
- SEC - Order approving the first eleven spot bitcoin ETPs (Release 34-99306, January 10, 2024): lists the eleven funds, including the Valkyrie Bitcoin Fund, the VanEck Bitcoin Trust and the Hashdex Bitcoin ETF
- Bitwise Bitcoin ETF - Form 10-K for 2025: the Bitcoin Custodian is Coinbase Custody (filed March 2, 2026)
- Ark 21Shares Bitcoin ETF - Form 10-K for 2025: Bitcoin Custodians are Coinbase Custody, BitGo Bank & Trust, Anchorage Digital Bank and BitGo New York Trust; Anchorage and BitGo New York agreements signed September 11, 2024 (filed March 2, 2026)
- VanEck Bitcoin ETF (HODL) - Form 10-K for 2025: Gemini Trust is the Bitcoin Custodian and Coinbase Custody the Additional Bitcoin Custodian
- CoinShares Bitcoin ETF (BRRR) - Form 10-K for 2025: formerly CoinShares Valkyrie Bitcoin Fund, sponsored by CoinShares Co. since June 14, 2024; custodians are Coinbase Custody, BitGo Trust and Komainu (Jersey)
- Invesco Galaxy Bitcoin ETF - Form 10-K for 2025: Coinbase Custody holds all of the Trust's bitcoin (filed March 2, 2026)
- Fidelity Wise Origin Bitcoin Fund - Form 8-K (filed February 5, 2026): custodial services agreement with BitGo Bank & Trust dated February 2, 2026; Fidelity Digital Assets remains custodian, and the sponsor had no plans to move any bitcoin to BitGo
- Grayscale Bitcoin Trust - Form 10-K for 2023 (filed February 23, 2024): the Sponsor's Fee was 2.0% from inception to January 10, 2024 and was lowered to 1.5% effective January 11, 2024
- Hashdex Bitcoin ETF - Form 10-K for 2025: BitGo Trust Company is the Bitcoin Custodian; formerly the Hashdex Bitcoin Futures ETF, permitted to hold spot bitcoin from March 27, 2024 (filed March 31, 2026)
- Winklevoss Bitcoin Trust - Form S-1 registration statement, signed by Cameron Winklevoss and naming Cameron and Tyler Winklevoss as attorneys-in-fact (filed July 1, 2013)
- SEC - Order disapproving the listing of the Winklevoss Bitcoin Trust on Bats BZX (Release 34-80206, March 10, 2017): Section 6(b)(5) requires exchange rules to be designed to prevent fraudulent and manipulative acts and practices
- SEC - Order disapproving the VanEck Bitcoin Trust (Release 34-97102, March 10, 2023): applies the Section 6(b)(5) test that rules be designed to prevent fraudulent and manipulative acts and practices; footnote 11 lists earlier disapprovals, including the Winklevoss Bitcoin Trust (July 26, 2018), Valkyrie, Bitwise, Grayscale, WisdomTree, ARK 21Shares and an earlier VanEck order
- SEC - Statement by Chair Gary Gensler on the approval of spot bitcoin ETPs: from 2018 through March 2023 the Commission disapproved more than 20 exchange rule filings for spot bitcoin ETPs (January 10, 2024)
- ProShares - Bitcoin ETF (BITO) fund page: the first U.S. bitcoin-linked ETF; inception date October 18, 2021; invests in futures and swaps, not bitcoin directly (fetched October 10, 2026)
- U.S. Court of Appeals for the D.C. Circuit - Grayscale Investments, LLC v. SEC, No. 22-1142: the SEC approved the Teucrium and Valkyrie XBTO bitcoin futures funds in 2022; the denial of Grayscale's proposal was arbitrary and capricious because the Commission failed to explain its different treatment of similar products (decided August 29, 2023)
- State of Wisconsin Investment Board - Form 13F-HR for the quarter ended March 31, 2024: 2,450,400 shares of the iShares Bitcoin Trust and 1,013,000 shares of the Grayscale Bitcoin Trust (filed May 14, 2024)
- State of Wisconsin Investment Board - Who we are: SWIB manages the Wisconsin Retirement System trust funds, a public pension system
- Harvard Management Company - Form 13F-HR for the quarter ended June 30, 2025: 1,906,000 shares of the iShares Bitcoin Trust (filed August 8, 2025)
- Harvard Management Company - home page: HMC invests Harvard's endowment
- CF Benchmarks - Exploring Bitcoin Basis Trades: a basis trade buys spot and sells futures; since spot bitcoin ETFs launched, net short positioning among levered funds in CME bitcoin futures rose, suggesting basis trading (June 27, 2024)