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Key Insights:
- 21Shares filed to list the first spot-based SUI ETF on Nasdaq.
- ETF will track CME CF Sui-Dollar Rate with no leverage or derivatives.
- SUI price surged following the Nasdaq ETF listing proposal filing.
21Shares has filed to list the first-ever SUI ETF on Nasdaq, fueling a rally in SUI price. The filing proposes a spot-backed trust structure, triggering investor demand for institutional exposure to the Sui blockchain’s native asset.
Nasdaq SUI ETF Filing Sparks Price Momentum
SUI price surged after Nasdaq submitted a proposed rule change to the U.S. Securities and Exchange Commission (SEC) on May 23, aiming to list the 21Shares SUI ETF under its Rule 5711(d) for commodity-based trust shares.
According to the filing SR-NASDAQ-2025-042, the fund intends to track the CME CF Sui-Dollar Reference Rate, adjusted for expenses. Unlike futures-backed funds, this ETF will hold actual SUI tokens in custody with Coinbase Custody and BitGo.
The move positions 21Shares to offer U.S. investors direct exposure to the SUI token via a regulated product, similar to the path paved earlier this year by Bitcoin and Ethereum exchange-traded funds.
Spot Structure Avoids Leverage or Yield Farming
The trust will operate as a passive vehicle. It will not engage in leverage, derivatives, or lending, the filing states. This setup reflects the structure approved for Bitcoin and Ether ETFs, avoiding speculative strategies and focusing solely on tracking SUI’s spot market performance.
21Shares confirmed that the ETF would not accept SUI directly from Authorized Participants. Instead, only cash deposits will be accepted, which will then be used to acquire SUI through an intermediary designated as a “SUI Counterparty.”
Each share will represent a fractional interest in the SUI held in the trust. The ETF will calculate its net asset value (NAV) daily based on the CME CF Sui-Dollar Reference Rate — the same pricing source used for the fund’s valuation.
SUI Market Maturity Supports ETF Case
In supporting its proposal, Nasdaq emphasized SUI’s growing liquidity and decentralization. As of May 2025, the SUI market cap stands above $12 billion, and Coinbase alone accounts for over 94% of the Pricing Benchmark’s volume. Kraken fills the remaining share, indicating a narrow concentration of liquidity.
Yet the sponsor insists the market is deep and resilient enough to resist manipulation, citing arbitrage activity across platforms and real-time price dissemination.
The ETF’s benchmark provider, CF Benchmarks Ltd., uses a multi-step volume-weighted median methodology to reduce the influence of outlier trades or price manipulation attempts. The benchmark also complies with the UK Benchmarks Regulation and undergoes ISAE 3000 assurance audits.
A Test Case for Next-Gen Blockchain Exposure
The proposed ETF represents the first time a U.S. exchange seeks to list a product backed by a Layer 1 blockchain token that is not Bitcoin or Ethereum.
SUI powers the Sui Network, which uses a delegated proof-of-stake consensus mechanism and parallel transaction execution through Narwhal and Bullshark protocols. These features enable the network to process high volumes of activity in areas such as gaming and decentralized finance.
SUI has a capped supply of 10 billion tokens, and holders can stake assets, pay network fees, and vote on protocol upgrades. Its design mirrors Ethereum in function but attempts to improve on scalability and speed.
Regulatory Path Mirrors Spot Bitcoin, Ether ETFs
While no regulated futures market exists for SUI, Nasdaq and 21Shares argue that the proposal aligns with recent SEC decisions. In Jan. 2024 and May 2024, the SEC approved spot Bitcoin and Ether ETFs despite the absence of a regulated market of “significant size” — a key requirement in previous denials.
In those cases, the SEC accepted “other means” of preventing fraud, including price aggregation, surveillance mechanisms, and liquidity fragmentation, as adequate safeguards. Nasdaq believes SUI meets that bar.
If approved, the ETF would be listed under Nasdaq’s standard trading hours and monitored under its market surveillance program. Intraday Indicative Values (IIV) would be published every 15 seconds, while end-of-day NAV would be struck after 4:00 p.m. ET.
Institutional Onramp or Retail Catalyst?
The ETF could create a regulated onramp for U.S. institutions to gain exposure to SUI without engaging with token custody, wallets, or offshore exchanges.
Still, the final approval lies with the SEC. The Registration Statement filed with the Commission is not yet effective, and trading will not commence until the SEC gives the green light.
Until then, the SUI ETF joins a growing line of crypto products waiting for regulatory clearance — and a market eager for the next phase of token adoption.
Disclaimer
In this article, the views and opinions stated by the author or any people named are for informational purposes only. And they don’t establish the investment, financial, or any other advice. Trading or investing in cryptocurrency assets comes with a risk of financial loss.
