On September 17th, the US SEC officially approved the "Universal Listing Standards for Commodity Trust Units" (Release No. 34-103995). This isn't just a simple technical document, but a true "institutional gate"—meaning that the future listing of crypto spot ETFs will shift from case-by-case approval to a standardized, expedited, universal process. Against the backdrop of the Federal Reserve's recent round of interest rate cuts and rising expectations of a depreciating dollar, this regulatory breakthrough has brought a dual resonance of "liquidity and institutionalization" to crypto assets, making it one of the most iconic regulatory events in the crypto market this year. In this article, we will answer the following questions: What exactly does the new regulation change, and what impact will it have? Which cryptocurrencies will benefit first, and which spot ETFs are expected to be approved first? What should investors pay attention to? With the implementation of new regulations and the reshaping of capital migration logic, how can ordinary investors seize opportunities and control risks? 1. What changes have the general standards made? Shifting from "whether to allow" to "how to regulate" Prior to the release of these new regulations, crypto spot ETFs were subject to a case-by-case approval process, requiring them to cross two approval thresholds: 1. 19b-4 Rule Change Approval—an application by the exchange to the SEC to amend its rules. This is a substantive review, subject to the possibility of rejection by the SEC. 2. S-1 Prospectus Approval—an ETF issuer submits the S-1 prospectus to the SEC for approval, disclosing details such as the fund structure, manager, and fees. This is more of a formal review. This dual approval process is not only lengthy but also often hindered by political wrangling and compliance disagreements. For example, there was a surge in applications for Bitcoin spot ETFs in 2021, but they were all rejected by the SEC at the 19b-4 stage in 2021 and 2022. A new batch of applications was submitted from May to July 2023, and finally, on January 10, 2024, both the 19b-4 and S-1 filings were approved on the same day, after nearly eight months of back-and-forth. The "Universal Listing Standard," adopted by the SEC on September 17, 2025, brought about fundamental changes. This standard clarified that eligible commodity ETFs no longer needed to submit 19b-4 applications on a case-by-case basis, sufficing solely through the S-1 approval process, significantly reducing approval time and costs. Eligible ETFs must meet one of the following three criteria: 1. The underlying commodity must be traded on an ISG (Intermarket Surveillance Group) member market, such as the NYSE, Nasdaq, CME, and LME. 2. The futures contract for the underlying commodity must have been traded continuously on a Designated Contract Market (DCM) for at least six months, and a Comprehensive Surveillance Sharing Agreement (CSSA) must have been established between the exchanges. A DCM is a compliant exchange authorized by the Commodity Futures Trading Commission (CFTC), such as CME, CBOT, and Coinbase Derivatives Exchange. 3. An existing ETF must be listed on a U.S. national securities exchange, with at least 40% of its assets allocated to the underlying commodity. Since most crypto assets are considered commodities, this rule is practically tailor-made for crypto spot ETFs. The second path is the most viable: as long as a crypto asset has a futures contract running for at least six months on an exchange like CME or Coinbase Derivatives, it can bypass the 19b-4 approval process, potentially allowing for a rapid launch of a spot ETF. Compared to the old model, the new regulations bring about changes in two aspects: 1) Simplified approval process: 19b-4 is no longer a "roadblock". Under the old model, crypto spot ETFs needed to complete the dual approval of the 19b-4 rule change and the S-1 prospectus, neither of which could be ignored. This was the case with previous Bitcoin and Ethereum ETFs: 19b-4 review times of up to 240 days were a key factor slowing down the process. Under the new regulations, as long as a product meets unified standards, exchanges can proceed directly to the S-1 approval process, eliminating the repetitive 19b-4 negotiations and significantly shortening the listing cycle. 2) Shift in Review Authority: The CFTC and DCMs Play a More Key Role. The eligibility review of futures contracts is gradually shifting from the SEC to Designated Contract Markets (DCMs) and the CFTC (U.S. Commodity Futures Trading Commission). Under the current system, DCMs have two main ways to list new contracts: Self-certification: DCMs simply submit a self-certification to the CFTC one business day before the contract launch. If there are no objections, the contract automatically becomes effective. This typically requires that the spot market possess price transparency, sufficient liquidity, and manageable market manipulation risks. Voluntary Approval: If a contract is controversial, the DCM can proactively apply for CFTC approval to obtain stronger legal protection. This means that as long as the spot market for a particular crypto asset is sufficiently healthy, the DCM has significant autonomy to promote the listing of its futures. Meanwhile, the SEC's review of the S-1 primarily focuses on the adequacy of information disclosure and compliance with the product structure, representing more of a "formal review." Overall, the SEC is transitioning from a case-by-case reviewer to a rule-maker. The regulatory approach is also shifting from "whether to allow" to "how to regulate." Under this framework, the launch of crypto spot ETFs will be more efficient and standardized. Which cryptocurrencies are most likely to benefit? The 10 major cryptocurrencies with existing futures contracts and ETF applications will be the first to see ETFs launched. Among existing DCMs (Designated Contract Markets), Coinbase's Coinbase Derivatives Exchange boasts the most comprehensive crypto futures product line, currently covering 14 cryptocurrencies. According to SoSoValue data, there are currently 35 crypto spot ETFs pending approval, covering 13 currencies. With the exception of SUI, TRX, and JitoSOL, the remaining 10 currencies have already had futures listed on Coinbase Derivatives for over six months, fully complying with the general requirements of the new regulations. This means: Approximately 30 spot ETFs covering 10 cryptocurrencies—LTC, SOL, XRP, DOGE, ADA, DOT, HBAR, AVAX, LINK, and BCH—are expected to be approved quickly in the coming weeks or months. The market is brewing the next wave of ETFs. For example, although cryptocurrencies like XLM and SHIB already have futures, no one has yet submitted a spot ETF application, making them likely to become the next wave of managers. Third, when interest rate cuts coincide with an ETF boom, what should investors pay attention to? ETF Issuance Progress, Macro Interest Rate Trends, Cross-Asset Allocation, and Capital Flows
In the short term, the implementation of universal standards will significantly accelerate the launch of crypto ETFs, lower the issuance threshold, and attract more institutional capital and compliant products.
Meanwhile, the Federal Reserve cut interest rates by 25 basis points as expected on Thursday, and the dot plot signaled two more cuts this year, ushering in a cycle of rate cuts. Expectations of a devaluation of the US dollar are beginning to ferment, and global capital is searching for new asset anchors.
The forces of macro liquidity and institutional reform are colliding head-on: on one hand, the massive liquidity released by the US dollar system, and on the other, the potential for a surge in crypto asset ETFs. The intertwining of these two factors may reshape capital allocation logic, accelerate the deep integration of traditional capital markets and crypto assets, and even mark the starting point for a reshaping of the global asset landscape over the next decade. Against this backdrop, investors need to focus on four key areas: 1. ETF Issuance Pace: For crypto spot ETFs that comply with common rules, the S-1 prospectus often undergoes multiple updates before final approval, supplementing details such as fee rates and initial offering size. These updates often signal a countdown to market launch. 2. Macroeconomic Environment: The Federal Reserve's interest rate path, dot plot projections, and the performance of the US dollar index will determine the direction of risk appetite and serve as key clues to asset pricing. 3. Cross-Asset Allocation: During periods of US dollar weakness, gold, commodities, and crypto assets often complement each other. By diversifying their exposure, investors can mitigate risk while capturing multiple yield curves. 4. Capital Flows: Compared to price fluctuations, daily net inflows into ETFs better reflect market sentiment and trends, often offering greater foresight and helping investors seize opportunities before market reversals. In summary, the new regulations, coupled with the interest rate cut cycle, are opening a "double floodgate" of institutional and liquidity for crypto ETFs. For investors, this presents both a new window of opportunity and a profound reshaping of asset allocation logic.