Winklevoss Files for a Zcash ETF at 0.25 Percent, a Tenth of the Grayscale Fee

Winklevoss Asset Services filed an S-1 with the US Securities and Exchange Commission on October 6, 2026 for a spot ETF on Zcash. The fund is to run on the Nasdaq under the ticker WINK and cost 0.25 percent a year. That is one tenth of what the only US Zcash ETF so far charges. For a portfolio in Germany the fund stays closed all the same, and the date that really lies ahead for ZEC holders here is not in this filing but in European anti money laundering law.

An S-1 is the registration form with which an issuer in the United States submits new securities for approval. It is an application, not a permission: the prospectus states explicitly that the information may change and that no shares may be sold while the registration is not yet effective.

An S-1 at the SEC: Winklevoss Asset Services applies for a spot ETF on Zcash

The applicant is Winklevoss Asset Services, LLC as sponsor. The issuer itself is a Delaware statutory trust, appearing in the prospectus as the Winklevoss Zcash ETF. The filing carries the SEC accession number 0001104659-26-113940 and is held in the register under identifier 0002158471, with a business address in Wilmington, Delaware.

Spot means the fund holds the cryptocurrency itself instead of tracking its price through futures contracts. The prospectus describes exactly that: the trust holds ZEC directly and works with neither leverage nor derivatives. The distinction matters for the price, because a spot fund has to take real coins off the market on an inflow, while a futures fund merely swaps contracts.

The exchange is named in the filing as the Nasdaq Stock Market, LLC, subject to notice of issuance. That too is a statement of intent and not an approval. The prospectus at the SEC is open to inspection.

0.25 against 2.5 percent: the fee gap to the Grayscale Zcash ETF

So far there is exactly one spot ETF on Zcash in the United States. Grayscale listed it on August 25, 2026 under the ticker ZCSH on NYSE Arca, converted from an existing trust that began as a private placement in 2017. It charges 2.5 percent a year. Grayscale has announced that it will channel the revenue from that fee back into the Zcash ecosystem in the first year, for instance into marketing and education.

The Winklevoss fund as filed sets 0.25 percent. The prospectus states that the trust pays the sponsor "an annual unified fee of 0.25% of the Trust's ZEC Holdings". Unified fee means that this single charge covers the running costs instead of billing custody, administration and auditing separately.

Convert the gap into a sum and it becomes tangible. On $10,000 invested, ZCSH costs $250 a year and the fund as filed $25. Over five years and with no change in price that is $1,250 against $125. On a product that does nothing beyond holding a cryptocurrency, the fee is the only item an investor knows for certain.

Unified fee: what a sponsor charge takes out of fund assets

The sponsor fee is not debited separately. It is taken out of the fund's assets, usually by the fund selling a small share of its coins on a running basis. An ETF with a 2.5 percent fee therefore holds around 2.5 percent fewer coins per share after a year than at the start, even if the price were unchanged. The share price follows the market, while the backing per share falls.

That is where the real leverage of this filing sits: a competitor ten times cheaper works on existing holdings and not only on new investors. A holder of ZCSH who sees WINK approved has a calculable reason to switch, and a switch between two spot funds runs through redemption at one and subscription at the other. That is precisely what produces outflow figures which look like selling pressure without a single coin leaving the market on balance.

Gemini Trust Company as custodian: a custodian from the same house

The custodian is to be Gemini Trust Company, LLC. The prospectus describes it as an affiliate of the sponsor. The ZEC are to sit in segregated cold storage, meaning custody with no connection to the internet.

That proximity is not an accusation, and it stands openly in the filing. It is, however, a point the regulator examines regularly in ETF applications, because sponsor and custodian then belong to the same circle of owners. What matters most here is the direction of travel: a house that runs both the exchange and the custody can offer a fund more cheaply than a sponsor who has to buy both in. The 0.25 percent are therefore a fighting price and a consequence of the firm's own structure at once.

A $100 million indication of interest: what a non binding undertaking is worth

The prospectus states that the Winklevoss Capital Fund, LLC has, through one or more affiliates, indicated an interest in purchasing shares worth up to $100 million. An indication of interest of this kind is expressly not binding. The prospectus itself says the buyers may acquire more shares, fewer, or none at all.

Undertakings like this appear in prospectuses because a fund with no starting volume is barely tradable on an exchange. As evidence of future demand the figure is of no use. It says the sponsor is willing to place its own money alongside the product, and it names an order of magnitude. It carries nothing beyond that.

ZEC at $1,219: the October 6 filing has not carried the price

Zcash trades at $1,218.82 on the OKX spot market and at $1,216.60 on Coinbase Exchange on October 9, 2026. Against the rolling 24 hour window that is a gain of 8.5 percent (OKX) to 9.1 percent (Coinbase). The day's range runs from $1,112 to $1,247, and market value stands at around $19.9 billion, putting it tenth.

That gain is no reaction to the filing, however, and reading it that way draws the wrong conclusion. On October 6, the day of submission, ZEC closed at $1,367.26. The price has lost 10.8 percent since. The daily gain is a recovery from the slide of October 8, when the price fell from $1,327.62 to $1,186.61 and touched $1,112.27 along the way.

Over seven days Zcash is therefore down while the broad market recovers on this day: Bitcoin adds 2.2 percent, Ether 2.1 percent. An application for a cheaper investment product is evidently no driver of the price while the approval remains open.

Since our report of October 5: 8.8 percent lower, a daily low of $1,112

On October 5 we reported on the first weekly outflow from the Grayscale Zcash ETF, $93.56 million in one week at the time. Against that day's close of $1,337.45, ZEC sits 8.8 percent lower today. The fourteen day high of $1,697.45 from September 26 now stands 28 percent above the current price.

The order of events produces a picture that neither report yields on its own. First money left the expensive fund, then the price fell to a multi week low, and only after that did a competitor file a product at a tenth of the fee. An issuer filing into a weak phase is aiming at tomorrow's fee market, hardly at today's price.

WINK on the Nasdaq: for a German portfolio the fund stays out of reach

A US spot ETF on crypto assets is practically unbuyable for retail investors in Germany. The reason sits in the European distribution rule: a fund may only be distributed to retail clients in the EU if a key information document under the PRIIPs Regulation exists in the relevant national language. US issuers do not produce that document, because they do not serve the EU retail market. Brokers in Germany therefore block such securities from trading.

The same applies to ZCSH, and a second, cheaper US fund will change nothing about it. The fee question currently being settled in the United States touches a German portfolio only if you are considering a route around that block. That is not advisable, because it removes the investor protection on which the block is founded.

The route via ETPs and crypto exchanges: holding period, custody and market access

Two other routes are open in Germany. The first runs through an exchange traded crypto security, usually called an ETP or ETN. This is a debt instrument that tracks the price of a cryptocurrency and is tradable on a European exchange, but legally it is not a fund. Whether you can buy one depends on which trading venues your broker offers. How the product categories differ is set out in our overview of crypto ETFs for investors in Germany.

The second route is buying the coin itself through a crypto exchange with MiCA authorisation. MiCA is the EU regulation on markets in crypto assets; since it took effect, providers need a permission from a European supervisor to offer services in the EU. Which houses can show that permission is set out in our overview of regulated crypto exchanges.

Tax treats the two routes very differently. With a directly held coin the speculation period under Section 23 of the German Income Tax Act applies: after a holding period of one year a gain on sale is free of tax, while within the year it counts as a private disposal. With a security the flat rate withholding tax on investment income applies, regardless of the holding period. Holding the coin yourself means keeping it either at the exchange or in your own hands; the device types for self custody differ considerably in handling and in how they are secured.

Article 79 of the EU anti money laundering regulation: regulated trading ends on July 10, 2027

Here lies the date that carries more weight for ZEC holders in Germany than any US approval. Regulation (EU) 2024/1624, the European anti money laundering regulation, prohibits credit institutions, financial institutions and crypto asset service providers in Article 79(1) from keeping anonymous accounts. The wording expressly covers accounts allowing the concealment of transactions, "including through anonymity enhancing coins".

Under Article 90 the regulation applies from July 10, 2027, with an exception for certain obliged entities for which July 10, 2029 is the relevant date. The text of the regulation in the Official Journal is freely available. Our report of October 5, 2026 gave July 1, 2027 at this point; the date in Article 90 is the one that governs.

The regulation addresses providers, not you. Private ownership of Zcash is untouched by it. What falls away is orderly market access: an exchange authorised in the EU will not be able to carry ZEC in trading or in custody after that date. The point at which selling or moving is still practically easy therefore lies before that date, not after it.

What the filing does not say: timetable, approval and the risk of a withdrawal

Three pieces of information are missing from the prospectus, and with a first filing that is normal. There is no date for approval, no launch date and no commitment from the Nasdaq on the listing. An S-1 can be amended, withdrawn, or commented on by the regulator over months before it becomes effective. The Grayscale fund needed the route through an existing trust and a conversion rather than a fresh registration.

It is also open whether the SEC will assess a second spot fund on a cryptocurrency with a shielding function differently from the first. The filing says nothing on that question, and an assessment at this point would be a guess without foundation.

Our assessment: a fee fight without approval stays a paper application

In this newsroom's view, this filing is significant for the American fund market and for the moment a footnote for German investors. Three pieces of evidence from this text support that: the fee difference from 2.5 to 0.25 percent is calculable and reaches existing holdings; the price reaction is absent, since ZEC sits 10.8 percent lower than on the day of filing; and the PRIIPs block keeps US funds out of German portfolios regardless of their fee.

One argument stands against it that we do not wish to play down: if fee competition in the United States draws capital into Zcash products, that works through the spot market onto the price paid in Europe as well. Only that route is indirect and tied to the approval, which is still outstanding. We derive no recommendation to buy or sell from it; crypto assets can lose their value entirely.

Zcash ETF: without approval, July 10, 2027 remains the harder date

Three steps follow from the situation:

1. Settle the product category before you place an order. ZCSH and the filed WINK are US funds and blocked for you; what is tradable are European securities and the coin itself. The differences are in our overview of crypto ETFs for investors in Germany.
2. Settle the venue's authorisation. If you buy or hold ZEC directly, take a provider with a European permission; the state of play is in our overview of regulated crypto exchanges.
3. Take July 10, 2027 into your planning. From that date, authorised EU providers may no longer trade or hold Zcash. Anyone moving the coins into self custody before then will find the device types in our overview of hardware wallets.

(As of October 9, 2026. This article is not investment advice. Prices and fee structures change; check the terms with the provider before you buy.)