The U.S. Securities and Exchange Commission (SEC) on November 21 issued a formal notice that Nasdaq ISE (International Securities Exchange) has proposed a dramatic increase in the position and exercise limits for options on BlackRock’s iShares Bitcoin Trust ETF (ticker: IBIT), from the current 250,000 contracts to 1,000,000 contracts. The move signals a potential watershed moment for regulated bitcoin derivatives, promising deeper liquidity and broader institutional participation.
Why Nasdaq Wants Higher Limits
In its filing, Nasdaq argued that the existing 250,000-contract ceiling stifles liquidity, hampers hedging strategies, and forces institutional investors to rely on the less transparent over-the-counter (OTC) options market. Data presented by the exchange shows that IBIT has grown to rival top-tier ETFs in both market capitalization and average daily volume. Even a full exercise of 1,000,000 contracts would represent only 7.40% of IBIT’s float and 0.284% of all outstanding bitcoin, mitigating concerns about market manipulation or disruption.
The SEC acknowledged the need to balance “potential manipulative schemes and adverse market impacts” with the cost of “inhibiting potential hedging activity that could be used for legitimate economic purposes.” The agency is now seeking public comment to determine whether Nasdaq’s proposal aligns with the requirements of the Securities Exchange Act. The comment period will help shape whether the commission approves, disapproves, or opens further proceedings within the statutory timeline.
Potential Market Impact
If approved, the higher limit would allow market makers to offer tighter spreads and greater depth, reducing the bid-ask spread for IBIT options and making them more attractive to large institutional players such as hedge funds, pension funds, and asset managers. Enhanced liquidity in the listed options market would also decrease the need for custom OTC structures, shifting trading onto regulated exchanges where surveillance mechanisms—including FINRA-backed monitoring—provide transparency.
Proponents of the rule change argue that it would strengthen crypto-linked risk management without increasing systemic risk. The creation-redemption mechanism of the ETF itself acts as a natural arbitrage check, limiting price divergence between IBIT and spot bitcoin. Moreover, because the proposed limit is still capped relative to the total supply, any concentration of options exposure remains within a manageable fraction of the underlying market.
Broader Institutional Context
The proposal comes on the heels of growing institutional embrace of bitcoin ETFs. A recent SEC filing from Harvard University revealed that BlackRock’s Bitcoin ETF now leads the university’s public portfolio, underscoring the shift toward digital assets among traditional financial institutions. Should the SEC approve the 1M-contract limit, it could unlock new strategies—such as covered call writing and protective puts—that were previously constrained by the 250,000-contract barrier.
The SEC’s public comment window is expected to remain open for 30 to 60 days. Market participants, industry groups, and retail investors are invited to submit their views. The outcome will be closely watched as a bellwether for how U.S. regulators intend to oversee the rapidly expanding market for crypto-linked derivatives.

