Grayscale Files Fourth SEC Amendment to Convert Zcash Trust Into Spot ETF
Grayscale Investments submitted its fourth amended registration statement to the SEC on August 18, 2026, pushing its effort to list a spot Zcash exchange-traded fund on NYSE Arca under the ticker ZCSH one step closer to approval. If the SEC grants the conversion, ZCSH would become the first US-listed spot ETF for any privacy-focused cryptocurrency.
The filing builds on an original Form S-3 submitted May 12, 2026. The latest version names Jane Street Capital and Virtu Americas as authorized participants, designates Coinbase Custody Trust Company as custodian, and confirms Bank of New York Mellon as transfer agent and administrator. Authorized participants can create shares in baskets of 10,000 units, using either cash or in-kind ZEC contributions. In-kind redemptions are not currently permitted.
One notable disclosure in the amended filing involves Digital Currency Group's international investment subsidiary. DCG International Investments is in non-binding discussions to contribute roughly 200,000 ZEC, worth approximately $110 million at current prices, to the trust in exchange for shares. The filing is explicit that those talks carry no commitment. As Grayscale wrote in the document, the discussions are not binding, meaning the DCG affiliate could ultimately contribute more, fewer, or no ZEC at all. The Grayscale Zcash Trust already holds 391,103.89 ZEC, representing about 2.3% of ZEC's total circulating supply and valued at roughly $99.4 million as of March 31, 2026.
ZEC climbed approximately 9% on news of the latest amendment, trading between approximately $555 and $720 across the period surrounding the disclosure. That move fits a broader rally: the token traded near $74 in October 2025 and has since risen more than 750%. Market cap estimates now place ZEC in the $9.4 billion to $10.88 billion range, putting it among the top 15 crypto assets by that measure.
The regulatory window opened in January. The SEC closed its investigation into the Zcash Foundation on January 15, 2026, without enforcement action. The probe had started with a subpoena in August 2023, tied to broader crypto asset offering inquiries. Analysts had characterized the investigation as the single largest regulatory overhang that had suppressed institutional participation in Zcash for years, and its conclusion removed that barrier. Grayscale has also published a research paper titled Zcash: Financial Privacy in the Age of AI, arguing that Zcash's privacy tools are becoming more relevant, not less, as AI systems grow more capable of cross-referencing blockchain data with external datasets to identify users and financial relationships.
A serious security incident preceded the ETF push. In late May 2026, independent researcher Taylor Hornby identified a critical flaw in the cryptographic circuit underpinning Zcash's Orchard shielded pool during a Shielded Labs-supported security review. The bug theoretically allowed unlimited, undetectable creation of counterfeit ZEC. No exploitation was found, but the private nature of the shielded pool made a definitive audit impossible. The Zcash network responded with the Ironwood (NU6.3) upgrade, activated July 28, 2026, at block height 3,428,143. The upgrade isolated the original Orchard pool (which held roughly 3.66 million ZEC, worth about $1.7 billion) behind a turnstile mechanism, and launched a replacement pool backed by a machine-checked mathematical proof covering more than 2,700 theorems. Grayscale's filing acknowledges both the vulnerability and the corrective upgrade directly.
On-chain data shows continued growth in shielded usage. Shielded transactions now account for approximately 90% of all Zcash transaction count, up from about 86.5% in mid-March 2026. The shielded supply has reached roughly 4.9 million ZEC, about 30% of circulating supply, an all-time high that compares sharply to the 11% figure recorded at the start of 2025. Investors should weigh those adoption gains against a notable liquidity signal: OTC trust share volume for ZCSH has remained below $5 million per month since June 2026, down from a peak of more than $23 million in November 2025.
Outside the US, the picture is more complicated. India's Financial Intelligence Unit issued a directive on January 25, 2026, requiring all registered crypto exchanges to halt deposits, withdrawals, and trading of ZEC, along with Monero and Dash, citing anti-money laundering and counter-terrorism financing concerns. Major platforms operating in India, including Binance's Indian entity, CoinSwitch, and Mudrex, were required to comply. A follow-up FIU clarification in March 2026 addressed some ambiguity but left the core trading restriction intact. A US-listed ETF would not directly restore access for Indian retail users, but a regulated product backed by Coinbase custody and cleared by the SEC could pressure Indian regulators to revisit their categorization of Zcash. Unlike Monero, Zcash maintains a transparent transaction layer alongside its shielded one, a design feature that gives exchanges a compliance argument regulators can engage with.
In sub-Saharan Africa, no country has issued an explicit ZEC ban as of this writing, but Nigeria, Kenya, Ghana, and South Africa have all passed or enacted virtual asset legislation in 2025 and 2026 that mirrors Financial Action Task Force standards. Privacy coins tend to face informal delisting pressure in FATF-aligned regimes even without formal prohibitions. Zcash's selective disclosure tools, specifically the ability to share view keys with auditors or regulators while keeping other transaction details private, give it a structural argument that pure privacy coins cannot easily replicate.
The path to approval. As of this writing, the SEC has not announced a public timeline for a decision on the ZCSH conversion. Crypto.news analysis projects that approval could attract between $500 million and $2 billion in net inflows, citing the pattern set by Grayscale's Bitcoin ETF conversion in January 2024. That conversion is a useful reference point, though the figures involved require context: Grayscale's Bitcoin Trust held roughly $15 billion in assets before its conversion, while total Bitcoin ETF AUM across all products grew to approximately $75 billion within a single quarter as multiple ETFs launched simultaneously. The two figures are not directly comparable, and any modeling of ZCSH inflow potential should account for that distinction.