Understanding the TDOG Dogecoin ETF: A New Gateway to Crypto Exposure

Key Takeaways

• TDOG is a proposed physically backed Dogecoin trust designed to mirror the price of Dogecoin, trading around $0.25, less fees.

• DTCC listing does not equal SEC approval — TDOG still requires both S-1 and 19b-4 filings to be cleared by regulators before trading.

• Creations and redemptions occur in cash, with Coinbase acting as the prime broker and custodian of Dogecoin assets.

• Fees are paid in Dogecoin, meaning each share’s DOGE backing gradually declines over time.

• TDOG would compete with DOJE, a live ETF offering Dogecoin exposure via a different regulatory and structural framework.

Introduction

As traditional finance continues to merge with the digital asset world, a new product has entered the conversation: the 21Shares Dogecoin exchange-traded fund (ETF), known by its proposed ticker TDOG. The potential launch of TDOG represents another milestone for investors seeking exposure to cryptocurrencies through conventional brokerage accounts, without the need to directly hold or manage digital coins.

While the listing of TDOG on the Depository Trust and Clearing Corporation (DTCC) has sparked excitement, it’s important to understand that this step signals operational readiness, not regulatory approval. This article breaks down how TDOG works, what makes it different from holding Dogecoin directly, and how it compares to the already-listed REX-Osprey DOGE ETF (DOJE).

What Is TDOG and How Does It Work?

The 21Shares Dogecoin Trust (TDOG) aims to provide direct exposure to Dogecoin’s market performance without requiring investors to hold or manage the cryptocurrency themselves. If approved, TDOG would issue shares that track the price of Dogecoin (DOGE), which currently trades around $0.25, minus applicable management fees.

The fund’s net asset value (NAV) will be calculated daily using a multi-exchange Dogecoin price index, providing an accurate snapshot of the asset’s value. During trading hours, TDOG will also publish an intraday indicative value (IIV) roughly every 15 seconds, helping investors assess price alignment between the shares and underlying assets.

Authorized Participants (APs) play a key role in maintaining this balance. Typically, they deliver cash to the sponsor, who then instructs Coinbase Prime Broker to purchase Dogecoin or use existing holdings. These assets are stored securely with Coinbase Custody Trust Company. During redemptions, the reverse process applies — APs return shares, receive cash, and Coinbase sells DOGE as needed.

This creation and redemption mechanism helps TDOG’s market price remain close to its NAV, though small premiums or discounts can appear during volatile trading periods or when liquidity is thin.

A unique operational feature is that fees are paid in kind, reducing the Dogecoin-per-share ratio over time as sponsor fees are deducted from the trust’s holdings.

Importantly, until the U.S. Securities and Exchange Commission (SEC) grants approval for both the S-1 registration statement and Nasdaq’s 19b-4 filing, TDOG cannot begin trading. The DTCC listing simply indicates that brokers and clearing firms are preparing systems for potential trading — not that the fund is cleared for launch.

DTCC Listing: Operational Readiness, Not Regulatory Approval

Seeing TDOG listed on DTCC’s Active and Pre-Launch page has led some investors to believe approval is imminent, but that is a misconception. The listing only means that infrastructure and operational testing are underway between market participants.

TDOG still awaits two crucial approvals from the SEC:

1. The S-1 registration must be declared effective.

2. Nasdaq’s 19b-4 rule change must be approved to allow the ETF to list as a Commodity-Based Trust Share.

Several crypto funds, including Bitcoin and Ethereum products, appeared on DTCC before receiving final approval — this is simply part of the preparation process.

How TDOG Would Track Dogecoin

If greenlit, TDOG will rely on CF Benchmarks’ Dogecoin-Dollar U.S. Settlement Price — a once-daily reference rate calculated using executed trades across multiple qualifying exchanges.

This benchmark is regulated under the UK benchmark regime and is built to be both transparent and resistant to manipulation. TDOG’s daily NAV would be calculated from this benchmark price, while its shares would fluctuate intraday based on supply and demand in the secondary market.

It’s worth noting that the trust explicitly disclaims rights to forks and airdrops. Unless these are officially supported and distributed, any additional tokens resulting from network events will not be included in the fund’s valuation. Investors should not expect extra value from such events to be reflected in TDOG’s performance.

TDOG vs. Buying Dogecoin Directly

At first glance, investors might wonder: Why not just buy Dogecoin directly? The answer depends on personal preference and investment strategy.

TDOG offers an easier, regulated way to gain Dogecoin exposure through a traditional brokerage account. Investors can buy and sell shares like any other ETF, avoiding the need for crypto wallets, private keys, or seed phrases. Custody is handled by institutional-grade providers, and the pricing mechanism follows transparent, rule-based calculations.

However, the trade-off for this convenience is that sponsor fees are deducted in Dogecoin, gradually reducing the amount of DOGE backing each share. Additionally, shares may occasionally trade at small premiums or discounts to NAV, especially during volatile sessions.

In contrast, buying Dogecoin directly gives investors full onchain control and 24/7 utility — allowing them to spend, tip, or transfer their holdings freely. Yet, it also introduces the risks of private key management, exchange custody exposure, and operational complexity.

Ultimately, TDOG is ideal for those who value ease of access and regulatory protection, while direct DOGE ownership suits investors who prefer onchain autonomy and utility.

Where TDOG Fits Alongside DOJE

Investors already have one U.S. Dogecoin-linked ETF available: the REX-Osprey DOGE ETF (DOJE), trading on the Cboe BZX Exchange since September 18, 2025.

DOJE is a 1940 Act ETF designed to deliver roughly 1x Dogecoin performance (before fees) through a combination of spot DOGE holdings and DOGE-linked instruments. To meet U.S. regulatory and tax standards, it operates via a Cayman subsidiary, the REX-Osprey DOGE Cayman Portfolio, which holds the crypto exposures. DOJE’s expense ratio is 1.50%, and at launch, it included both spot Dogecoin and 21Shares’ DOGE ETP, though its composition can evolve over time.

If approved, TDOG would differ from DOJE in several key ways:

• Structure and Venue: TDOG would be a commodity-based trust listed on Nasdaq, holding Dogecoin directly with cash creations and redemptions. DOJE, meanwhile, is a regulated 1940 Act ETF on Cboe, combining direct and synthetic DOGE exposure.

• Valuation: TDOG’s NAV relies on the CF Benchmarks Dogecoin-Dollar rate, while DOJE’s valuation stems from a more flexible mix of DOGE and DOGE-linked products.

• Fees: DOJE’s expense ratio is fixed at 1.5%, whereas TDOG’s sponsor fee remains pending in its preliminary filings.

In essence, DOJE is a live, accessible option today, while TDOG represents a potentially simpler, physically backed alternative still awaiting regulatory clearance.

How to Buy TDOG (If and When It Lists)

Once both SEC approvals are finalized, TDOG would begin trading on Nasdaq. Here’s how retail investors could participate:

1. Locate the ticker in your brokerage account. Once approved, TDOG will appear like any other Nasdaq-listed ETF. Availability may vary depending on your broker and region.

2. Ensure account eligibility. Most standard brokerage accounts support ETF trading, but tax-advantaged or institutional accounts may have restrictions.

3. Place trades carefully. Early trading sessions often feature lower liquidity and wider spreads — limit orders are recommended over market orders.

4. Understand total costs. Beyond the bid-ask spread and any brokerage commissions, remember that TDOG’s sponsor fee is embedded in performance and deducted over time.

5. Track NAV and price performance. Investors can monitor the ETF’s real-time pricing against its published NAV to assess fair value.

Until official approvals are complete, TDOG remains non-tradable. For immediate Dogecoin exposure, investors can explore DOJE on Cboe, though suitability depends on individual risk tolerance and jurisdictional factors.

Conclusion

The emergence of TDOG underscores the continued evolution of crypto-linked investment products. By offering a regulated, exchange-traded vehicle that mirrors Dogecoin’s performance, TDOG could open the door for more investors to participate in the crypto ecosystem through familiar financial channels.

While its approval is still pending, the operational groundwork and DTCC readiness signal growing institutional appetite for digital assets. Once cleared, TDOG will likely stand alongside DOJE, giving U.S. investors two distinct — yet complementary — pathways to Dogecoin exposure.

FAQs

Is TDOG approved for trading yet?

No. TDOG’s listing on the DTCC reflects operational setup, not SEC approval. It must receive clearance for both its S-1 registration and Nasdaq’s 19b-4 filing before trading can begin.

How does TDOG differ from DOJE?

TDOG is a commodity-based trust that holds Dogecoin directly and lists on Nasdaq. DOJE is a 1940 Act ETF trading on Cboe that uses both spot and synthetic DOGE exposure.

What are the main risks of investing in TDOG?

Key risks include potential tracking errors, intraday price deviations from NAV, and the gradual reduction of DOGE per share due to in-kind sponsor fees.

Can I use TDOG to transfer or spend Dogecoin?

No. TDOG provides price exposure only; investors cannot withdraw or use Dogecoin held by the trust for onchain transactions.

When might TDOG start trading?

There is no set timeline. Approval depends on the SEC’s review process and the outcome of Nasdaq’s rule-change request.