Nasdaq’s ISE asks the SEC to lift iShares Bitcoin Trust options limits to one million contracts, enabling larger institutional hedging but potentially more volatility.
Nasdaq’s International Securities Exchange filed a proposal with the U.S. Securities and Exchange Commission on Nov. 26 to raise position limits on BlackRock’s iShares Bitcoin Trust options from 250,000 contracts to one million, according to regulatory documents.
The filing requests that the Bitcoin (BTC) exchange-traded fund be reclassified into the same derivatives tier as major equity indexes and large-cap stocks, including Apple, NVIDIA, the S&P 500, and the Nasdaq-100.
The exchange argued in its submission that the existing limit restricts trading and hedging strategies, noting that the fund’s market capitalization and average trading volume place it among the largest products listed on U.S. exchanges. The iShares Bitcoin Trust is currently the largest Bitcoin ETF by assets.
According to the filing, a fully exercised one-million-contract position would represent approximately 7.5% of the fund’s float and 0.284% of all bitcoin in existence.
The proposed limit expansion would enable market makers to hedge larger positions aligned with institutional flows from pension funds and hedge funds, the filing stated. Under current restrictions, dealers face constraints in managing delta, gamma, and vega exposures on large-scale trades.
The iShares Bitcoin Trust surpassed Deribit as the largest venue for Bitcoin options open interest this year, according to market data, indicating a shift in price discovery toward regulated U.S. venues.
Industry analysts note that higher position limits could facilitate the creation of structured products, including capital-protected baskets and yield-bearing instruments that provide Bitcoin exposure without direct ownership of the cryptocurrency. However, regulatory frameworks such as Staff Accounting Bulletin 121 continue to present challenges for how regulated entities custody digital assets.
The filing also requests the elimination of limits on customized, physically delivered FLEX options, which would allow large block trades to migrate from over-the-counter swaps to exchange-listed structures.
Market structure experts observe that expanded position limits typically tighten bid-ask spreads but can also amplify volatility during sharp price movements if dealers are forced to hedge large gamma exposures rapidly.
The SEC has not announced a timeline for its decision on the proposal. The commission typically allows a public comment period before ruling on exchange rule changes.
