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21Shares’ Bold Bet: Will the First U.S. Spot Dogecoin ETF Navigate SEC Scrutiny?

21Shares’ Bold Bet: Will the First U.S. Spot Dogecoin ETF Navigate SEC Scrutiny?
Dogecoin ETF

Summary

On April 29, 2025, Nasdaq submitted a Form 19b-4 to the SEC to list and trade shares of the 21Shares Dogecoin ETF, which would hold spot DOGE and track the CF DOGE-Dollar US Settlement Price Index with Coinbase Custody Trust as the custodian​Cointelegraph. This filing follows similar applications by Bitwise and Grayscale and comes amid over 70 pending crypto ETF reviews, signaling intense industry demand for regulated crypto access​CryptoSlate. While the SEC has already delayed Bitwise’s DOGE ETF decision to June 15, analysts from Bloomberg estimate about a 75% chance of a DOGE ETF approval in 2025​FXStreetMitrade. Approval would mark a watershed moment—transforming Dogecoin from a niche meme coin into a mainstream investment vehicle and further legitimizing digital assets in traditional finance.

Introduction

Dogecoin (DOGE) began as a joke in 2013 but has grown into the eighth-largest cryptocurrency by market cap (around $26 billion as of late April)​CryptoSlate. ETFs have long been the bridge between retail investors and complex asset classes—allowing broad exposure without the hassles of self-custody. So when 21Shares, through Nasdaq, files to offer a spot Dogecoin ETF, it’s a bold move poised to reshape how meme coins participate in regulated markets. In this article, we’ll:

  1. Unpack the details of the Nasdaq filing.
  2. Assess its approval chances amid the SEC’s cautious stance.
  3. Explore the broader implications for meme-coin legitimacy and the ETF landscape.

1. Inside the Nasdaq Filing

1.1 Fund Structure and Custody

  • Spot DOGE holdings: The proposed ETF would directly hold Dogecoin tokens, not derivatives or leveraged positions​etf.com.
  • Pricing index: It tracks the CF DOGE-Dollar US Settlement Price Index, ensuring transparency in valuation​AInvest.
  • Custodian: Coinbase Custody Trust Company will securely store the DOGE holdings, leveraging institutional-grade safeguards​etf.com.

1.2 Regulatory Filings

  • Form S-1: 21Shares first submitted its S-1 registration on April 10, joining Grayscale and Bitwise in filing for spot DOGE ETFs​Cointelegraph.
  • Form 19b-4: Nasdaq’s 19b-4 application on April 29 formally requests the SEC’s nod to list the ETF on its exchange​FXStreet.

2. SEC Review Process and Approval Odds

2.1 Current Review Landscape

The SEC is currently reviewing over 70 crypto ETF applications, spanning Bitcoin, Ethereum staking, Solana, XRP, and now Dogecoin—demonstrating evolving regulatory appetite for diverse crypto exposures​Cointelegraph.

2.2 Delays and Extensions

  • Bitwise DOGE ETF: Decision postponed to June 15, 2025, illustrating the SEC’s methodical pace​FXStreet.
  • Regulatory caution: The SEC has shown concern over market manipulation and surveillance—areas that Nasdaq addresses via its Intermarket Surveillance Group membership​CryptoSlate.

2.3 Market Expectations

Bloomberg analysts peg the odds of Dogecoin ETF approval in 2025 at ~75%, reflecting both industry pressure and improved exchange-level controls​Mitrade. However, final SEC action could still hinge on broader crypto market conditions and policy shifts under Chair Gary Gensler.

3. What Approval Would Mean for Meme-Coin Legitimacy

3.1 Mainstream Investment Access

A spot DOGE ETF would let investors buy Dogecoin via standard brokerage accounts—no wallets or private keys required—dramatically lowering the entry barrier​CryptoSlate.

3.2 Institutional Confidence

Listing on Nasdaq signals institutional credibility, potentially attracting pension funds, endowments, and asset managers who have so far shied away from unregulated exchanges​Crypto Tracker.

3.3 Ripple Effects on Altcoin ETFs

Success here could pave the way for a flood of memecoin and altcoin ETFs, accelerating a shift from Bitcoin-only products toward a diversified crypto ETF landscape​Cointelegraph.

Conclusion

21Shares’ Nasdaq filing for a spot Dogecoin ETF is more than just another ticker application—it represents a potential turning point for how mainstream finance perceives and interacts with meme coins. While regulatory approval is not guaranteed, the combination of robust surveillance measures, industry backing, and growing ETF precedent makes a compelling case. Should the SEC grant approval, Dogecoin would move from meme-coin fringe status to a fully regulated investment staple—opening the door for broader crypto acceptance and innovation.

References

  1. Nasdaq files to list 21Shares Dogecoin ETF (Cointelegraph) Cointelegraph
  2. Nasdaq seeks SEC approval for 21Shares Dogecoin ETF (FXStreet) FXStreet
  3. Nasdaq’s Dogecoin ETF filing: Milestone in crypto's institutional evolution (AInvest) AInvest
  4. Nasdaq files to list 21Shares Dogecoin ETF, signaling mainstream acceptance (CryptoSlate) CryptoSlate
  5. Mitrade: Analyst odds for DOGE ETF approval in 2025 (Mitrade) Mitrade
  6. ETF.com: Nasdaq seeks SEC nod to list Dogecoin ETF etf.com
  7. Bloomberg data on SEC crypto ETF pipeline (via Cointelegraph) Cointelegraph
  8. Bitwise DOGE ETF review extension (FXStreet) FXStreet
  9. Coinbase Custody as ETF custodian (Yahoo Finance) finance.yahoo.com
  10. Market cap and ranking of Dogecoin (CryptoSlate) CryptoSlate

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