Generic Listing Standards For Crypto And Commodity ETPs: What It Means And What's Next

Key Takeaways

• Generic listing standards now allow qualifying crypto and commodity exchange-traded products to list without inpidual SEC approval.
• The new generic listing standards will result in significant time and cost savings for ETP issuers meeting the new criteria.
• Actively managed, leveraged, and novel-feature ETPs still require traditional 19b-4 approval.

Introduction

On September 17, 2025, the Securities and Exchange Commission approved proposed rule changes by three national securities exchanges to adopt generic listing standards (the "Generic Standards") for ETPs that hold spot commodities, including crypto assets.¹ The rule changes significantly ease the path forward for many crypto ETP issuers in particular, although some ETPs still remain outside the scope of the Generic Standards and will continue to require separate listing approval by the Commission.