Swiss asset management firm 21Shares has achieved a significant procedural milestone by listing its Dogecoin ETF under the ticker TDOG on the Depository Trust & Clearing Corporation (DTCC). This administrative step represents crucial back-office preparation for potential U.S. market access, though it remains separate from the ultimate regulatory approval required from the Securities and Exchange Commission.
The DTCC listing indicates that 21Shares has completed essential clearing and settlement infrastructure necessary for the fund to operate in the U.S. market once regulatory hurdles are cleared. However, this procedural advancement does not guarantee SEC approval, which remains the final barrier for the product to trade on U.S. exchanges.
The timing of this development aligns with growing institutional interest in digital assets beyond Bitcoin and Ethereum, as multiple major asset managers pursue similar Dogecoin ETF applications with the SEC. The regulatory body is currently reviewing more than 90 cryptocurrency ETF applications, with Dogecoin products representing a notable portion of pending submissions.
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21Shares originally filed its registration statement on April 9, 2025, via Form S-1, with the SEC officially acknowledging the filing in mid-May 2025. This acknowledgment marked the formal start of the review process for the ETF, which is designed to track Dogecoin’s performance as indicated by the CFGE-D US Settlement Index, with adjustments made for expenses and liabilities of the Trust.
The investment vehicle is structured to be passive, directly holding DOGE without engaging in leverage, derivatives, or similar strategies to achieve its investment goals. Coinbase Custody Trust has been designated to safeguard the fund’s tokens and will act as the official custodian for the ETF, providing institutional-grade security measures.
According to the filing details, the Trust’s primary objective is to reflect Dogecoin’s performance while maintaining a straightforward investment approach. This passive strategy appeals to institutional investors seeking exposure to the meme coin without the complexities of direct cryptocurrency custody and management.
Competitive Dogecoin ETF Landscape
21Shares faces significant competition in the race for the first approved Dogecoin ETF, with several major players having submitted applications to the SEC. Bitwise filed its application in January 2025 via Form 19b-4 for a spot DOGE ETF, with Coinbase Custody managing DOGE holdings and Bank of New York Mellon handling cash assets.
Grayscale Investment submitted its DOGE ETF application in March 2025 via Form S-1, with the SEC publicly acknowledging the application and delaying decision deadlines to November 2025. The company’s established track record in cryptocurrency investment products positions it as a formidable competitor in this emerging market segment.
Rex Shares Osprey filed its application in January 2025, with the SEC’s next major deadline for decisions potentially arriving between October and December 2025. The competitive landscape demonstrates significant institutional confidence in Dogecoin’s potential as a regulated investment product.
Current decision timelines for the various applications span several months, with most DOGE ETF applications likely to receive final decisions between October 2025 and January 2026. The SEC has repeatedly delayed decisions on several applications, citing the need for more comprehensive review periods.
Key decision deadlines include:
- Rex Shares Osprey DOGE ETF: October-December 2025
- Grayscale Investment DOGE ETF: November 2025
- 21Shares Dogecoin ETF: January 9, 2026
- Bitwise Dogecoin ETF: Extended review period ongoing
Regulatory Environment and SEC Scrutiny
The Securities and Exchange Commission has maintained a historically cautious approach toward approving spot crypto ETFs, particularly for assets like Dogecoin that lack the same institutional adoption as Bitcoin or Ethereum. Analysts note that the SEC’s scrutiny of crypto products typically focuses on investor protection, market manipulation risks, and fund structure considerations.
Under the current administration, there has been a notable push to accelerate approvals for crypto-related products, reflecting a pro-innovation stance toward digital assets. This regulatory environment has encouraged asset managers to explore new crypto ETF offerings, despite the SEC’s traditionally conservative approach to cryptocurrency products.
The Commission has stated that “institution of proceedings does not indicate that the Commission has reached any conclusions with respect to any of the issues involved.” Instead, the SEC actively seeks and encourages interested persons to provide comments on proposed rule changes, utilizing its 240-day review period before making final approval decisions.
The regulatory uncertainty persists despite administrative readiness demonstrated by DTCC listings and completed filing procedures. Market observers note that the SEC’s evolving stance on crypto products, shaped by recent approvals of Bitcoin and Ethereum futures ETFs, could influence the timeline for Dogecoin spot ETF approvals.
Market Implications and Institutional Adoption
If ultimately approved, the TDOG ETF and similar products could significantly impact Dogecoin’s market dynamics by providing institutional investors with regulated vehicles to access the asset. This development would likely enhance Dogecoin’s liquidity and market depth while bolstering its legitimacy as a financial asset within traditional investment frameworks.
Retail investors would benefit from simplified access through standard brokerage accounts, potentially driving broader participation in the cryptocurrency market. The institutional adoption facilitated by ETF approval could transform Dogecoin from its origins as a “meme coin” into a more mainstream investment asset with enhanced credibility.
The path forward for 21Shares involves continued engagement with the SEC, including responding to regulatory queries and refining the ETF’s prospectus to address specific concerns. This ongoing dialogue reflects the comprehensive review process required for cryptocurrency investment products in the current regulatory environment.
Industry stakeholders remain cautiously optimistic about approval prospects, though they acknowledge that the regulatory process remains unpredictable. The DTCC listing, while representing a positive procedural signal, underscores the important distinction between administrative readiness and actual regulatory endorsement.
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The successful approval of Dogecoin ETFs would mark a watershed moment for cryptocurrency adoption, potentially setting precedents for broader acceptance of alternative digital assets in regulated financial markets. This development could catalyze increased institutional investment flows into the cryptocurrency sector, while simultaneously providing traditional investors with familiar investment vehicles for accessing digital asset exposure through established brokerage platforms.
- DTCC
- The Depository Trust & Clearing Corporation is a financial services company that provides clearing and settlement services for financial markets. It handles the post-trade processing of securities transactions in the United States.
- Form S-1
- A registration statement required by the SEC for new securities offerings in the United States. It provides essential information about the company and the securities being offered to potential investors.
- Form 19b-4
- A form filed with the SEC by self-regulatory organizations to inform the Commission of proposed rule changes. It is commonly used by exchanges seeking approval to list new financial products like ETFs.
- Spot ETF
- An exchange-traded fund that directly holds the underlying asset rather than derivatives or futures contracts. For cryptocurrency ETFs, this means holding actual digital coins rather than futures contracts.
- Meme Coin
- A cryptocurrency that originated from internet memes or jokes, often characterized by high volatility and community-driven value. Dogecoin is the most prominent example, having started as a joke based on the “Doge” meme.