Desktop or tablet recommended

This interactive research dashboard is optimized for desktop and tablet. For the full experience — including maps, regulatory timelines, and data matrices — please switch to a desktop browser.

Talos Research
Talos Research · Q1 2026

Global crypto ETP landscape

Regulatory structures, market access and status by jurisdiction

Global ETP AUM
$184B
end-2025
US$145BEU/UK$28BHK$4BJP~2028KRPilot 2026AU$2B
Live - US, AU
Live - HK
ETNs only - EU/UK
Developing - JP ~2028
Pilot - KR 2026
Bubble ∝ AUM · Click any highlighted region

ETP product structure taxonomy

The term "ETP" encompasses two distinct legal structures across live jurisdictions, each with materially different counterparty exposures, redemption mechanics, and regulatory obligations.

ETP
Exchange-Traded Product - umbrella category
ETF
Exchange-Traded Fund
Open-end fund or commodity trust; investors hold fund shares, not issuer debt
United States
1933 Act Commodity Trust (BTC/ETH)
In-kind eligible Retail access Single-asset
United States
1940 Act Registered Fund (multi-asset / active)
No in-kind (s.22g) Exemptive relief needed Retail access
Hong Kong
SFC-authorised Spot ETF
In-kind eligible Retail access Licensed custodian req.
Australia
ASIC-regulated Spot ETF
Cash or in-kind Retail access Open-end structure
ETN
Exchange-Traded Note
Unsecured debt obligation of issuer; investors are senior creditors, not fund shareholders
European Union
EU Crypto ETN (MiFID II / Prospectus Regulation)
No retail spot ETF Professional only Issuer credit risk
United Kingdom
FCA-regulated Crypto ETN (PS21/22 framework)
Retail with conditions Issuer credit risk
Key structural distinction - counterparty exposure by product type
ETF
Investor owns fund shares. Counterparty risk is fund-level (NAV-based), not issuer balance sheet. Redemption rights governed by fund docs and applicable law.
ETN
Investor is a senior creditor of the issuer. Repayment linked to underlying asset performance but is an unsecured obligation. Issuer insolvency risk is material.
Cross-regional capability matrix
✓ Available ~ Partial ✕ Not available
* Partial reflects current ETN status. · US in-kind: 1933 Act commodity trusts only · US SOL staking: SSK (Cboe, Jul 2), BSOL (NYSE, Oct 28), GSOL (NYSE Arca, Oct 29) · US ETH staking: ESK (Cboe, Sep 25, 1940 Act), Grayscale ETHE/ETH (Oct 6, 1933 Act) · EU/UK retail: UK from Oct 2025; EU institutional only · US active management: pending individual approval
Legislative pathway to live ETF Steps completed · pending · blocked per jurisdiction
Regulatory milestones Key events Jan 2024 - end-2025 · pipeline markers for JP & KR
Regulatory approval
Market or data milestone
Pipeline (legislation pending)
ETP assets under management By jurisdiction · est. end-2025
Investor access by tier - ETPs Who can buy the product today
Institutional unlocks What regulatory changes mean for each firm type
Structure type & counterparty risk Commodity trust · Open-end fund · ETN

US: creation and redemption mechanics: cash model vs. in-kind model

The SEC's Release No. 34-103571 (July 29, 2025) permitted in-kind creations and redemptions for 1933 Act commodity trust shares only. The structural contrast below shows what changed operationally for authorised participants (APs) and custodians.

Pre Jul 2025
Cash-only model
All creations and redemptions settle in USD
Creation - AP delivers USD, receives ETP shares
Investor / Fund
Subscribes to ETP via secondary market or AP
USD cash ↓
Authorised Participant (AP)
Broker-dealer; delivers cash to trust, receives creation units. No crypto custody required.
USD cash ↓
ETP Trust / Issuer
Receives USD, instructs custodian to purchase BTC/ETH on open market
Market buy order →
Crypto Custodian
Licensed custodian holds BTC/ETH; does not interact directly with AP
✕ No direct crypto transfer
Underlying Asset (BTC / ETH)
Purchased at spot by trust intermediary; AP has no custody role

Limitations: Cash mechanics introduced tracking error, spread widening at creation/redemption, and cost inefficiencies. APs required no direct crypto custody capability.

Post Jul 2025
In-kind model
1933 Act commodity trusts only (BTC/ETH single-asset)
Creation - AP delivers BTC/ETH directly, receives ETP shares
Investor / Fund
Subscribes to ETP via secondary market or AP
BTC / ETH ↓
Authorised Participant (AP)
Now requires: direct crypto custody + net capital for haircut + operational connectivity to trust custodian
On-chain transfer ↓
ETP Trust / Issuer
Receives crypto directly from AP; no market purchase required. Tighter spread, zero slippage.
Segregated custody ↓
Crypto Custodian
Receives BTC/ETH directly from AP wallet; AP must be operationally connected
Held in segregated custody
Underlying Asset (BTC / ETH)
Held in segregated custody; no market slippage at creation or redemption
New AP requirements under in-kind mechanics
  • Direct crypto custody capability or qualified custodian relationship
  • Net capital capacity for crypto asset haircut treatment
  • Operational connectivity to trust custodian for on-chain transfers
  • 24/7 settlement window management - crypto markets do not close
Scope limitation - Release No. 34-103571

In-kind mechanics are currently available only to single-asset BTC and ETH commodity trust shares registered under the Securities Act of 1933. Multi-asset index funds and actively managed vehicles registered under the Investment Company Act of 1940 face a separate, unresolved regulatory pathway - including potential exemptive relief from Section 22(g) redemption requirements that do not map cleanly to 24/7 crypto market hours.

Talos
For institutional use · Data as of Q1 2026 · © 2026 Talos Global, Inc.