Approaching the two-year mark of the first U.S. spot Bitcoin ETFs seems like a reasonable juncture to review the current state of live crypto ETF filings for the last time in 2025.
Here’s the best-known list, as shared by Bloomberg’s James Seyffart and Eric Balchunas:
That said -- we expect liquidations to pick up too. Not sure the liquidation numbers can stay this low for US ETPs as launches explode
— James Seyffart (@JSeyff) December 11, 2025
If you're a Bloomberg terminal client and interested in seeing these charts and more, the report can be found here: https://t.co/ELvRQ1lTtS pic.twitter.com/drrGxC4BjI
The backdrop is overshadowed by the market’s anchoring asset, Bitcoin, floundering about 0.9 of a standard deviation below its circa $126k record.
(See NYU’s GARCH model here for the calculation. Note: ~1𝛔/1-year BTC drawdowns are historically normative for BTC.)
The market might look different by the time the SEC works through this wall of filings. At least for now though, this is the climate into which issuers are intent on pumping more inventory.
That adds backing to a first high-probability assumption on the trend of listed crypto products in 2026, as noted by the Bloomberg analysts: liquidations are likely to increase.
With a reasonable level of U.S. crypto ETF attrition already emerging over the last several months, further ‘wastage’ would not be surprising.
It is the concentration of interest in specific assets, the overall tenor of the filings slate, plus the regulatory undercurrents facilitating this stepped-up wave of paperwork that are more interesting.
We’ll take a closer look at these points a little lower down.
The forward-looking view on the 2026 crypto ETF landscape that you’re currently reading is nowhere near The Big Picture for the year ahead.

In ‘Risk-On Reloaded: Monetary Easing, Catch-up Trades, and the Tokenization Buildout’, Head of Research Gabe Selby, CFA and Research Analyst Mark Pilipczuk, guide us through what’s expected to be a “transformative” year.
All in all, our Market Outlook 2026 is one of the few freely available institutional-grade outlook reports focused on digital assets.
Click below to read or download the report.
Get the summary:
It was the instigation of Generic Listing Standards (GLS) in September that formalized the more accommodative but still prudent regulatory pathways needed for the asset class to grow way beyond Bitcoin and Ether within exchange listed wrappers.
Click below to read a concise overview of Generic Listing Standards by CF Benchmarks Head of Research Gabe Selby, CFA.
Now, as the list we shared above shows, issuers are building a dense pipeline across dozens of tokens—anchored by persistent demand for BTC and ETH, and an ascendant second tier led by SOL and XRP.
This means the competitive edge is migrating away from “getting exposure” and toward how exposure is engineered: including eligibility signals, governance-grade benchmarks – like those published by CF Benchmarks, with demonstrably representative liquidity – increasingly all alongside staking and yield design.
Worth underlining: Bloomberg’s early-December tally was only a snapshot. At the time of writing at the end of December, the count has risen, if not materially. We’ve kept the cut-off as December 11th, while acknowledging that the tenor of the list could soon change.
With a broader palette of ETF-eligible crypto assets now fully telegraphed by the SEC, it’s helpful to take a closer look at the filings slate to get an idea of what applicants are doing with this broader permission—i.e., where issuer focus has been concentrating.
Issuer attention is now split between what we can describe as:
To facilitate our absorption of of these clusters further, we’ve repackaged the filings slate into the ‘heat map’ below.

They're still worth noting.
It’s when we examine the ‘regulatory lanes’ where live filings are pooling that the most surprising and counter-intuitive concentration emerges.
With the snapshot showing 124 filings, split between 42 ’33 Act spot applications, and 82 proposed ’40 Act spot and/or derivatives-based funds, the bias is clear.
It’s important to outline why these new signs of ’40 Act prevalence go against the grain and the direction of travel for crypto ETPs.
First off, note that for traditional assets (stocks, bonds, etc.) – investors have historically favored ’40 Act ETPs over ’33 Act ETPs. Crudely speaking, investors have generally regarded investor safeguards as higher in the former vs. the latter.
One major observation from the relatively short history of crypto ETPs though, is that the trend and apparent market preference have generally been in the opposite direction.

Here, we feature a summary and excerpts from the CF Benchmarks Capital Market Assumptions report on Bitcoin, produced by Head of Research Gabe Selby, CFA and Research Analyst Mark Pilipczuk.
Capital market assumptions (CMAs) are the institutional “operating system” for strategic allocation: they convert an investment thesis into the inputs that portfolio construction and governance actually require—expected return, volatility, and correlation.
CMAs carry real weight. Because they can eventually be backed by real money. Their purpose is to make assumptions explicit, so committees can debate scenarios and sensitivities with discipline.
For Bitcoin, that discipline is especially important: outcomes are non-Gaussian, market structure has been evolving quickly, and the difference between a view and an implementable allocation is a framework that can be monitored and updated over time.
CMAs are the bridge between an investment thesis and portfolio weights: expected return, risk, and correlation inputs that governance bodies can debate and implement.
A new research report by the CF Benchmarks Research Team proposes a pragmatic Bitcoin CMA framework spanning strategic (1–10 years) and tactical (sub-1 year) horizons, integrating multiple lenses to support disciplined sizing and risk management.
1) The CMA is multi-model
The framework combines comparative valuation (store-of-value share vs gold), production economics (cost-of-production regimes), and a liquidity overlay (global M2) to avoid over-reliance on any single story.
2) The base case is probability-weighted
Rather than a single asserted path, long-run outcomes are framed via scenarios and weights—so committees can interrogate assumptions (scenario weights, gold growth assumptions, penetration paths) rather than debate narratives.
3) Risk is structurally evolving
The risk framework emphasizes volatility compression and evolving correlation dynamics as market structure deepens—positioning risk assumptions as something to be updated.
4) Portfolio relevance shows up at even modest weights
Using its CMA inputs (expected return / volatility / correlations), the report argues that even constrained allocations can improve portfolio efficiency—shifting focus toward implementable sizing under real governance constraints.
“This combination of high expected returns, moderating volatility, and persistently low correlations positions Bitcoin as a compelling addition to a multi-asset portfolio.”
From 'Building Bitcoin Capital Market Assumptions: A Practitioners Framework for Strategic and Tactical Allocations' by Gabe Selby, CFA and Mark Pilipczuk
Figure 8 (below) is an “at-a-glance” illustration of how the report treats valuation tactically, eschewing precision fair-value calls, in favor of regime profiles.
In the model illustrated below, when price trades materially below estimated production cost, conditions have historically reflected stress; near cost suggests equilibrium; far-above cost reflects elevated valuations – where sizing discipline and risk management matter most.
With this approach, production cost defines a useful reference range that can be combined with other lenses (e.g., comparative valuation and liquidity) to reduce decision noise and support repeatable, governed process.


CF Benchmarks' regulated CF Large Cap index is now available as a perp for the first time.
CF Benchmarks congratulates Kraken on the successful launch of its Large Cap DTF Perpetual (PF_LCAPUSD) futures contract, referencing the LCAP DTF deployed on the Reserve Protocol, marking Kraken’s first perpetual futures contract offering multi-token exposure.
As the digital asset derivatives landscape continues to evolve beyond single-asset products, this latest inflection point reflects growing demand for instruments that offer diversified exposure, capital efficiency, backed by institutional-grade reference standards.
Against this backdrop, Kraken has today launched a perpetual futures contract referencing the LCAP Decentralized Token Folio (DTF), broadening access to one of the market’s most institutionally aligned on-chain crypto portfolios.
The launch represents a further extension of the LCAP ecosystem following the deployment of the LCAP DTF as an on-chain spot instrument earlier this year.
The contract is based on the Large Cap DTF (LCAP). In turn, LCAP references the CF Large Cap (Diversified Weight) – US – Settlement Price, a CF Benchmarks index designed to represent the large-cap segment of the crypto asset market through a transparent, rules-based, and regulator-aligned methodology.
While multi-asset indices are well established in traditional finance, their adoption within crypto derivatives remains nascent. The LCAP perpetual represents Kraken’s first perpetual futures contract referencing a diversified, multi-token crypto portfolio, signaling growing market maturity and demand for index-based derivatives beyond single-asset BTC and ETH products.
Importantly, this development should be viewed less as a platform milestone in isolation, and more as evidence of the expanding role that benchmark-driven crypto portfolios can play across spot, on-chain, and derivatives markets.
Key Contract Specifications
(Note: contract specifications and trading conditions are determined and administered by Kraken.)
The information contained within is for educational and informational purposes ONLY. It is not intended nor should it be considered an invitation or inducement to buy or sell any of the underlying instruments cited including but not limited to cryptoassets, financial instruments or any instruments that reference any index provided by CF Benchmarks Ltd. This communication is not intended to persuade or incite you to buy or sell security or securities noted within. Any commentary provided is the opinion of the author and should not be considered a personalised recommendation. Please contact your financial adviser or professional before making an investment decision.
Note: Some of the underlying instruments cited within this material may be restricted to certain customer categories in certain jurisdictions.
As the 2-year anniversary of the first US spot Bitcoin ETFs approaches, a huge wall of filings points to a surprising turn in 2026 • Research Primer: Bitcoin Capital Market Assumptions • Kraken lists LCAP Portfolio Perp

Ken Odeluga
A massive build-up of crypto ETF filings suggests issuers are pivoting away from the '33 Act framework towards more flexible '40 Act structures. We explain why.

Ken Odeluga
Crypto markets are entering a transformative phase in 2026, where regulatory clarity and monetary easing outweigh macro uncertainty. We expect a dovish Fed pivot counter to consensus, fostering lower real yields. Meanwhile, the CLARITY Act and broader adoption should drive our secular themes.

Gabriel Selby