Alphabetical by ticker. Each ETF holds allocated, segregated bars or plates in named vaults; bar lists are published periodically by the sponsor.
Alphabetical by symbol. On-chain instruments backed by allocated physical metal in named vaults; reserve attestations published by the issuer or its auditor.
Last updated: 2026-07-09
Physical Commodity ETFs — Dual-Custodian Structures and the 2026 Flow Reversal
SPDR Gold Shares (GLD) and iShares Silver Trust (SLV) remain the two reference vehicles for
physically-backed commodity exposure, each disclosing custodian identity, bar counts, and audit cadence in
SEC filings rather than marketing material. After a record-setting inflow start to 2026, gold ETFs
recorded their first sustained net outflows of the cycle in May 2026, even as tokenized gold trading volumes
kept climbing — a divergence that is reshaping how the two structures compete for the same underlying
demand.
1. GLD and SLV: who actually holds the metal, and how often it is checked
SPDR Gold Shares (GLD) discloses two custodians rather than one: HSBC Bank plc
and JPMorgan Chase Bank, N.A. jointly hold the Trust's gold, with custody agreements
specifying that all gold is held in allocated form at the end of each business day, and each
custodian publishes its own separate gold bar list on the sponsor's website
(SPDR Gold Shares, Charts, Data and Downloads).
Bureau Veritas Commodities UK Ltd. (formerly Inspectorate International) conducts
two counts per year — an annual full count and a separate random-sample count —
at each custodian's vaults, with results published as Inspection Certificates alongside the bar list
(SPDR Gold Shares, Ticker 2840 disclosure page).
iShares Silver Trust (SLV) uses a single named custodian, JPMorgan Chase Bank, N.A.,
London branch, with The Bank of New York Mellon acting as trustee; JPMorgan's own
London and New York vaults, plus a Brink's London sub-custody arrangement, hold the physical silver
(iShares Silver Trust, Form 10-K).
A May 2026 Bureau Veritas inspection letter documents the granularity of these counts directly: a
full count of 523,802 silver bars as of 27 February 2026, comprising
435,905 bars (422,999,596.00 gross troy ounces) at JPMorgan's London vault and 87,897 bars
(88,168,893.500 gross troy ounces) at its New York vault, with every bar confirmed present against the
Trust's stated records
(iShares Silver Trust, Bureau Veritas Inspection Letter UKWPM-26-00662).
SLV's own prospectus is explicit that the custodian's inspection checks weight, fineness marks, and bar
numbers against the bar list but does not include chemical assay testing to independently
verify purity, relying instead on the London Good Delivery chain of custody established when the bar was
first refined
(iShares Silver Trust, Prospectus).
2. The 2026 flow reversal: record inflows, then the largest outflow of the cycle
Global gold ETF trading volumes hit an all-time high of 4,145 tonnes traded in January 2026,
surpassing the prior record set in 2020, according to World Gold Council data cited in contemporaneous
market coverage
(Kitco News, citing World Gold Council ETF flow data).
The World Gold Council's own monthly Gold ETF Flows series — the OTSFA reference for holdings and
flow data across the category — tracks this trajectory in successive published reports
(World Gold Council, Gold ETF Flows, March 2026 report;
World Gold Council, Gold ETF Flows, April 2026 report).
That momentum reversed sharply by mid-year: gold-backed ETFs recorded net outflows of 16 metric
tonnes in May 2026, with the bleed continuing into the first half of June, even as central-bank
gold buying continued on a separate track
(GoldSilver, 298 Tonnes of ETF Gold Is Underwater).
The divergence between ETF redemptions and continued sovereign accumulation is precisely the kind of
structural signal the World Gold Council's dedicated ETF flows dataset is designed to isolate, since it
reports holdings and flows separately by region and fund rather than blending ETF activity with OTC or
central-bank demand
(World Gold Council, Gold ETF: Stock, Holdings and Flows dataset).
3. Bar-list transparency as the ETF category's core differentiator versus tokens
The defining structural feature separating physical ETFs from tokenized alternatives is where the audit
trail lives: GLD's and SLV's bar lists and inspection certificates are filed as exhibits to SEC periodic
reports and cross-referenced against custodian-specific bar lists published directly on the sponsor's site,
meaning the chain of custody is anchored in securities law disclosure obligations rather than a private
attestation contract
(SPDR Gold Trust, Form 10-K, Custodian disclosure).
This filing-based model is why ETF sponsors can be forced, by regulatory requirement rather than choice, to
disclose custodian identity changes, sub-custodian arrangements, and count methodology in a standardized
document format auditable by any market participant — a structural contrast with token issuers, whose
attestations (discussed in Section 2) are contractual undertakings rather than statutory filings.
Current status: GLD and SLV remain the deepest,
most heavily audited physical commodity vehicles by filing obligation, but May-June 2026 marked the first
sustained ETF outflow period of the current gold cycle even as tokenized-gold trading volume kept expanding,
signalling that incremental demand is increasingly routing through token rails rather than fund creation
units.
Last updated: 2026-07-09
Tokenized Gold — PAXG, XAUT, and the Attestation-Not-Filing Model
Tokenized gold's spot trading volume surpassed the entirety of 2025 within the first quarter of
2026 alone — $90.7 billion versus $84.6 billion for the full prior year — with PAXG and XAUT
together accounting for the overwhelming majority of that flow. Both tokens rely on periodic
third-party attestations rather than the continuous SEC filing regime that governs physical ETFs.
1. PAX Gold (PAXG): Paxos Trust, KPMG monthly attestations, and the lookup tool
PAX Gold (PAXG), issued by Paxos Trust Company — a limited-purpose
trust company chartered by the New York State Department of Financial Services (NYDFS) and
separately subject to OCC oversight for its national trust functions — represents one
fine troy ounce of allocated London Good Delivery gold held in Brink's London vaults
(Paxos, Pax Gold (PAXG)).
Paxos publishes monthly attestation reports on its transparency page, with KPMG LLP
providing attestations under AICPA standards since 28 February 2025, confirming that
circulating token supply matches allocated bar inventory
(Paxos, Pax Gold (PAXG) Transparency Reports).
Uniquely among tokenized commodities, Paxos also operates a public Gold Allocation Lookup Tool
letting any holder enter a wallet address or transaction hash and retrieve the specific bar serial number,
purity, vault location, and weight backing their tokens — a bar-list-equivalent disclosure mechanism
built for individual retail verification rather than aggregate fund-level reporting
(Paxos, PAXG Transparency Reports).
Reserves undergo a separate annual physical audit by Bureau Veritas — the same
inspection firm used by GLD and SLV — layering an independent physical count on top of the monthly
KPMG attestation cycle
(Raptor Group, Paxos: Bringing PAXG to Solana).
2. Tether Gold (XAUT): quarterly BDO attestations and 2026 market-share milestones
Tether Gold (XAUT), issued by TG Commodities S.A. de C.V. within the
Tether corporate group, represents one troy ounce of London Good Delivery gold held primarily in Swiss
vaults, with BDO Italia providing quarterly limited-assurance attestations under ISAE 3000
standards. Tether's own January 2026 announcement stated that XAUT's value had surpassed
$4 billion, accounting for more than half of the entire gold-backed stablecoin market by
value
(Tether.io, Tether Gold Accounts for More Than Half the Entire Gold-Backed Stablecoin Market).
By February 2026, market data aggregated on CoinMarketCap showed circulating XAUT supply had grown to over
712,000 ounces, up from roughly 246,000 ounces a few years prior, with a market
capitalization of approximately $2.22 billion at a price near $4,697 in mid-January 2026
(CoinMarketCap, Tether Gold (XAUT) market data).
Trading intensity spiked further into March 2026, when XAUT recorded a single-day perpetual futures volume
of $6.40 billion on Binance on 23 March 2026, according to CryptoQuant data cited in trade
press, though that figure reflects derivatives activity rather than direct spot purchases of the underlying
token
(TradingView News, Over $6B: XAUT Futures Volume Rewrites Records on Binance).
3. Market structure: PAXG/XAUT duopoly and the $90.7 billion Q1 2026 milestone
Aggregated CoinGecko data covering fifteen months of activity shows PAXG and
XAUT together dominating tokenized-gold spot volume, with PAXG's monthly share ranging from
34.2% to 82.5% and XAUT's from 14.8% to 64.6%; average monthly spot
trading volumes stood at $5.72 billion for PAXG and $5.32 billion for XAUT,
against an overall category average of $11.69 billion per month, while smaller entrants — Kinesis
Gold (KAG) averaging $0.57 billion, Tether's omnichain XAUT0 deployment at $0.10 billion, and XAUM at just
$0.007 billion — remain a distant tail
(BeInCrypto, Tokenized Gold Crosses 2025's Full-Year Volume in Just One Quarter).
Total Q1 2026 tokenized-gold spot trading reached $90.7 billion, already exceeding the
$84.64 billion recorded across the whole of 2025, according to the same CoinGecko-sourced
reporting
(Phemex News, Tokenized Gold Trading Volume Surpasses 2025 Total in Q1 2026).
Current status: PAXG and XAUT have consolidated
into a durable duopoly on trading volume, both relying on periodic third-party attestation rather than
continuous statutory filing, and tokenized-gold volume growth in 2026 has outpaced the physical ETF category
even as the underlying custody chains (Brink's, Swiss vaults, Bureau Veritas) closely mirror ETF-industry
practice.
Last updated: 2026-07-09
Hong Kong Distribution, European ETPs, and MiCA's Asset-Referenced Token Regime
Commodity-backed tokens sit inside MiCA's Asset-Referenced Token (ART) category rather than the
e-money regime, triggering a full authorization, reserve-segregation, and disclosure framework that has been
fully applicable to new issuers since 30 June 2024 — while Hong Kong's HashKey Exchange and
Switzerland's Backed Finance illustrate two distinct non-EU distribution and issuance models operating
alongside it.
1. MiCA's ART classification: why gold tokens are not e-money tokens
Under MiCA (Regulation (EU) 2023/1114) Article 3(1)(6), an asset-referenced token
(ART) is defined as a crypto-asset that is not an e-money token and that purports to maintain a
stable value by referencing any other value or right — including one or more commodities —
rather than a single official currency; PAX Gold and Tether Gold are the explicit worked examples cited by
supervisory guidance as commodity-backed ARTs precisely because they reference physical gold rather than a
fiat currency
(Eco, MiCA EMTs vs ARTs Explained).
The European Banking Authority (EBA) holds direct supervisory responsibility over
issuers once a token crosses defined significance thresholds under Article 43 — at least three of:
a holder base above 10 million, a reserve above €5 billion, daily EU transaction volume above
€500 million, daily transaction count above 2.5 million, use as a means of payment above 1 million
transactions per day, or material interconnection with the financial system
(European Banking Authority, EBA's Supervisory Role under MiCA).
For commodity-backed ARTs specifically, EBA-aligned guidance requires the underlying commodity to be held
with a regulated custodian, with daily inventory reconciliation and quarterly third-party physical
audit — explicitly citing PAXG's LBMA-vaulted, serial-number-tracked model as the reference
custody structure any commodity-backed ART issuer must replicate to obtain authorization
(Eco, MiCA Reserve and Authorization Rules).
2. Authorization mechanics: own funds, reserve segregation, and the 30 June 2024 cutover
Any legal person seeking to issue an ART to the public in the EU must obtain authorization from the
competent authority of its home member state under Article 21, or, if a credit institution,
follow the simplified notification path under Article 17, in either case submitting an
approved crypto-asset white paper before public offering
(CSSF, Issuers of Asset-Referenced Tokens (ARTs)).
Own-funds requirements are calibrated to the greatest of €350,000, 2% of the
average reserve (rising to 3% for significant ARTs), or a quarter of the prior year's fixed
overheads, held in addition to — not as part of — the segregated reserve itself
(Finconduit, Issuing an ART Under MiCA Title III: 2026 Guide).
Reserve assets must be fully segregated from the issuer's own balance sheet and, under Article
47, are excluded from the issuer's insolvency estate in the event of failure, made available for
redemption ahead of other creditors
(Eco, MiCA Reserve and Authorization Rules).
As of 30 June 2024, any ART or EMT offered to the public or admitted to trading within the
EU must be authorized under MiCA, with crypto-asset service providers required to restrict services
facilitating acquisition of non-compliant tokens after a transitional sell-only window that closed
31 March 2025
(Lexters, ARTs and EMTs Status under MiCA — EBA No-Action Letter and Compliance Deadlines).
3. HashKey's compliant on-ramp model and Backed's Swiss DLT-Act structured products
Hong Kong's HashKey Exchange positioned itself in early 2026 as a compliant distribution
venue for existing tokenized-gold products rather than an issuer, launching licensed XAUT
over-the-counter trading on 15 January 2026 — described as the first compliant gold-token
trading available on a licensed Hong Kong exchange — available to professional investors through its
Marketplace OTC platform
(MEXC, HashKey Launches XAUt Trading, Marking the First Time a Compliant Gold Token Trades on a Licensed HK Exchange).
A promotional access campaign let users acquire small XAUT allocations from roughly $100,
with early flow data showing $401.5 million in leveraged futures volume against $36.7 million in spot volume
within the first 24 hours — open interest of $466.7 million signalling predominantly speculative
rather than long-term-holding demand for the newly listed access route
(AInvest, HashKey's Gold Token Launch: Flow Analysis of a $100 Promotional Offer).
By contrast, Backed Finance, headquartered in Zug, Switzerland, issues its
tokenized real-world-asset suite — including commodity- and equity-tracking tokens — under
Switzerland's Distributed Ledger Technology (DLT) Act framework, describing each token as
1:1 backed by the underlying asset, held with third-party licensed custodians, and redeemable for the
underlying asset's cash value
(Backed Finance, Tokenized Assets).
Backed's institutional tokenization platform, launched in December 2025, extends this same Swiss
structured-product model to a broader roster of tokenized securities, positioning the firm as a
Swiss-regulated alternative to the US-trust-company (Paxos) and Tether-group (XAUT) issuance models that
dominate the gold-token category specifically
(Backed Finance, Backed Launches Tokenization Platform for Institutions).
Current status: MiCA's ART regime has been fully
binding on new EU issuers since 30 June 2024, with commodity-backed tokens such as PAXG and XAUT treated as
the reference case for custody and reconciliation standards; HashKey's 2026 Hong Kong OTC listings and
Backed's Swiss DLT-Act structured-product model illustrate two parallel non-EU frameworks operating alongside
the European regime. Watch: whether any commodity-backed ART crosses the EBA's significance
thresholds, and whether Hong Kong's SFC or HKMA extends dedicated licensing to gold-linked tokens beyond the
current securities/virtual-asset treatment.