Nasdaq has filed a proposal with the U.S. Securities and Exchange Commission to list and trade shares of the Coinshares XRP ETF, adding another major digital asset product to the growing pipeline of exchange-traded fund applications. The filing argues that XRP’s market structure, liquidity profile, and global trading activity make the asset less vulnerable to manipulation than critics may assume.
According to the proposal, the ETF would be listed under Nasdaq Rule 5711(d). The product is structured as a Delaware Statutory Trust and is designed to give investors exposure to XRP without requiring them to directly buy, hold, or custody the token themselves. That structure mirrors the broader appeal of crypto ETFs in traditional finance: regulated access through familiar brokerage infrastructure.
The filing states that the trust would hold only XRP and cash. Its value would track the Compass Crypto Reference Index XRP – 4pm NY Time, with the fund’s net asset value calculated on a daily basis. The ETF is described as a passive investment vehicle, and the XRP backing the trust would be stored by a third-party custodian rather than managed directly by investors.
How the ETF Would Operate
Nasdaq’s submission outlines a creation and redemption model based on large blocks of shares known as baskets. These baskets would be available only to authorized participants, which is standard for many ETF structures. In practice, the trust would issue baskets to authorized participants in exchange for cash, then use that cash to purchase XRP that would be placed in custody.
This framework is intended to provide a more transparent and regulated route for investors seeking XRP exposure. Instead of dealing with wallet management, private keys, exchange counterparty risk, or direct onchain custody, investors would be able to gain access through a listed securities product. Nasdaq presents this as a key advantage for both market accessibility and investor protection.
Nasdaq’s Core Argument: XRP Is Not Particularly Easy to Manipulate
The most notable part of the filing is Nasdaq’s direct claim that XRP is not particularly susceptible to manipulation, especially when compared with other reference assets already approved for exchange-traded products. To support that position, the exchange points to several characteristics of the XRP market.
First, Nasdaq emphasizes deep liquidity. A more liquid market generally means larger volumes can be absorbed with less dramatic price impact, making coordinated distortions more difficult and more expensive to sustain. Second, the filing points to the fragmented nature of XRP trading across multiple platforms. Because activity is spread across a wide set of venues rather than concentrated in a narrow market, the exchange argues that manipulating the asset’s price through continuous trading becomes more difficult.
Nasdaq also highlights increased adoption, user engagement, and trading volumes as evidence that XRP has developed into a mature enough market to support an ETF. In the exchange’s view, broader usage and geographically distributed trading strengthen price discovery and reduce the likelihood that a single participant or venue could easily exert lasting control over the market price.
Comparison With Bitcoin and Ether ETF Approvals
To strengthen its case, Nasdaq draws a comparison with previously approved bitcoin and ether ETFs. That comparison is strategically important. Rather than arguing that XRP should be evaluated under an entirely separate standard, the filing suggests that the SEC should view the product through a framework already applied to other digital asset ETPs.
The exchange’s position is that XRP shares enough of the relevant market characteristics—such as scale, trading activity, and decentralized participation—to justify similar treatment. In other words, Nasdaq is not only asking for approval of a single product; it is also attempting to place XRP within the emerging category of crypto assets that can support regulated, exchange-listed investment vehicles.
That does not mean the outcome is assured. The SEC has historically focused heavily on questions around surveillance, market integrity, custody, and whether a proposed exchange can demonstrate that the underlying market is resistant to fraud and manipulation. Nasdaq’s filing addresses those concerns by framing XRP as a globally traded asset whose pricing is shaped by a broad and active market rather than by isolated pockets of activity.
Why This Filing Matters
If approved, the Coinshares XRP ETF could expand the range of digital asset products available to traditional investors. For market participants who want exposure to XRP but prefer not to interact with crypto-native infrastructure, an ETF offers a more familiar route through brokerage accounts and regulated market rails.
The filing is also significant because it reflects a broader industry effort to move beyond bitcoin- and ether-only products. A successful XRP ETF application would signal that the regulated crypto investment landscape is continuing to widen, with exchanges and issuers seeking to bring additional large-cap digital assets into ETF form.
At the same time, the proposal underscores an important regulatory debate: whether broad trading activity, liquidity, and decentralization are enough to satisfy concerns about manipulation in digital asset markets. Nasdaq’s answer is clearly yes in the case of XRP, but the SEC’s review process will determine whether that argument is persuasive under current standards.
SEC Review Now Underway
The SEC is now reviewing the proposal and has invited public comment before reaching a final decision. As with other crypto ETF filings, the process is likely to center on the product’s structure, the robustness of market oversight, custody arrangements, valuation methodology, and the quality of the exchange’s evidence on resistance to manipulation.
For now, the filing marks another important step in the institutionalization of crypto investment products. Nasdaq is making a straightforward case: XRP’s market is liquid, globally traded, and decentralized enough to support a regulated ETF. Whether regulators agree will be closely watched by issuers, exchanges, and investors across the digital asset industry.