Key Highlights
- VanEck submitted a third amendment to its SEC registration statement for a spot Avalanche ETF on December 18.
- The proposed fund will use a cash-only creation and redemption model, with Coinbase Custody managing the assets.
- The filing confirms the trust will not engage in staking activities to earn rewards from the Avalanche network.
VanEck filed Amendment No. 3 to its Form S-1 registration with the U.S. Securities and Exchange Commission (SEC) on December 18 in its constant pursuit of launching its VanEck Avalanche ETF. This filing is a crucial step in the regulatory approval process for the first exchange-traded fund linked to the native token of the Avalanche blockchain.
Through the revised submission, the asset manager seeks to address certain SEC requirements in an effort to achieve final approval.
The third amendment mostly relates to the enhancement of the fund’s operational mechanics and the association between the trust and the provider of its services. According to the filing, the VanEck Avalanche ETF will hold AVAX tokens, and the assets of the trust will be maintained in cold storage by the Coinbase Custody Trust Company.
The filing outlines how staking rewards would be earned, distributed, and partially retained to cover operational costs. It also details safeguards such as staking buffers and rebalancing thresholds designed to manage redemption timing mismatches and liquidity risks. As with many crypto ETF filings, VanEck notes that no public market currently exists for the shares and that investors face risks similar to holding AVAX directly.
Staking Restrictions
The trust will not participate in staking, most likely due to the regulatory hurdles that would otherwise come with proof-of-stake reward validation. This follows the structure that the SEC has always advocated for in spot cryptocurrency ETFs. Through this structure, all creation and redemption will be conducted in cash.
VanEck also reiterates that the trust will not be registered under the Investment Company Act of 1940 and will not fall under CFTC commodity pool regulation, placing it structurally closer to other spot crypto ETPs currently under SEC consideration.
VanEck’s past filings
VanEck had already given the push to its application for the listing of the Avalanche ETF by filing the Form 19b-4 together with Nasdaq before the SEC in April 2025. The recent filing is, in effect, a petition to the exchange for a ruling regarding the listing of the VanEck Avalanche Trust.
This follows VanEck making similar filings in the past, with the company being one of the biggest proponents of diversification in terms of the types of digital assets that are offered. The SEC had earlier approved spot Bitcoin and Ethereum-based exchange-traded funds, but an Avalanche-based one is the next level.
Despite the expanded operational disclosures, the filing remains explicitly marked as “subject to completion.” The implications of the filing represent an increased optimism in the regulatory viability of non-Bitcoin and non-Ethereum tokens. The latest amendment from VanEck represents the company moving closer to the launch of an investment vehicle for the Avalanche chain within the traditional financial markets.
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