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2026 Proof of Custody. Published by Onramp Bitcoin. Editorial Independence.PrivacyTermsproofofcustody.io
Research

Bitcoin is decentralized. Its custody is not.

The protocol has thousands of independent nodes and no operator who can be removed to sever it. A growing share of the bitcoin those nodes secure sits behind the key-management operation of a single company.

Bitcoin's mining and node decentralization are measured continuously by several public dashboards. Its custody concentration is measured by nobody. This page is our attempt at the missing half, built from fund SEC filings rather than from press coverage.

By Steve L, Editorial Lead·Reviewed by Proof of Custody Editorial
Published Aug 3, 2026
84.5%
Named sole or primary custodian
One company
85.9%
Names that company anywhere
Including additional custodians
14.1%
Fully independent of it
FBTC + DEFI
1
Custody Nakamoto coefficient
Mining is 3
Who holds the ETF bitcoin

Share of 1,216,021 BTC held by US spot bitcoin ETFs, by the custodian each fund names as sole or primary in its SEC filings. As of July 31, 2026.

Coinbase Custody9 funds84.0%
1,021,387 BTC
Fidelity Digital Assets1 fund14.1%
171,561 BTC
Gemini Trust Company1 fund1.4%
16,616 BTC
Coinbase Prime1 fund0.5%
6,231 BTC
BitGo Trust Company1 fund0.0%
226 BTC

Coinbase Custody and Coinbase Prime are the same parent company. Taken together they are the named sole or primary custodian for 84.5% of ETF bitcoin.

Nakamoto coefficient, by layer

The minimum number of entities whose failure or collusion controls a majority. Higher is more decentralized.

3Mining pools

Foundry, AntPool and F2Pool together produced just over half of recent blocks. Independent research grouping pools by shared block templates argues the true figure may be 2.

mempool.space pool data, 0xB10C template-similarity research

1ETF custody

One custodian is named as sole or primary for the large majority of US spot ETF bitcoin. No second entity is required.

Fund SEC filings, this dataset

Bitcoin's custody layer is more concentrated than its mining layer. Mining decentralization is measured continuously by several public dashboards. Custody concentration is measured by nobody, which is why this figure of 1 has not been published before.

Proof of Custody, from fund SEC filings (10-K, 10-Q, 424B3). Measures control of keys, not beneficial ownership. Funds naming several custodians without disclosing the split are counted at their primary.
A correction to the record

The widely repeated version of this story says two funds are independent of Coinbase: Fidelity's FBTC and VanEck's HODL. That is wrong.

VanEck's FY2025 10-K names Gemini and Coinbase Custody as the bitcoin custodians who hold all of the trust's bitcoin. HODL is not independent. The only two funds with no Coinbase entity named anywhere in their filings are FBTC and DEFI, together 14.1% of ETF bitcoin.

Three shapes, and the one everybody misnames

Paul Baran drew these topologies in 1964 to study which networks survive attack. His argument is routinely inverted by people citing it.

Centralized
Exchange or single custodian

Every holder depends on one operator. Its compromise, insolvency, or unilateral action reaches everyone at once.

Decentralized
A handful of large custodians

Several hubs instead of one. Baran put this word in scare quotes and judged it fragile, because destroying a small number of hubs still severs the network. Most arrangements marketed as decentralized are this.

Distributed
Multi-institution and vendor-diverse multisig

No node whose removal severs the whole. This is the topology bitcoin's protocol has, and the one its custody layer largely does not.

Proof of Custody. Topologies drawn from scratch; the canonical 1964 illustration of these forms is Paul Baran's and remains under RAND copyright.

Baran described two poles, centralized and distributed. He put the word “decentralized” in scare quotes, attributed it to others, and treated it as a fragile middle case, noting that destroying a small number of nodes in such a network still destroys communication.

That middle panel, a federation of a few large hubs, is precisely what bitcoin custody looks like today. It is also what most products marketed as decentralized custody actually are. The distributed panel on the right, where no single node's removal severs anything, is what bitcoin's protocol achieved and what its custody layer has not.

This is the same measurement as our Custody Independence Standard, drawn as a picture: how many independent things must fail before the bitcoin is gone.

What this measures, and what it does not

This measures control of keys. It does not measure beneficial ownership. A custodian holding coins for millions of ETF shareholders is a concentration of control and a dispersion of ownership at the same time. Both are true, and the distinction matters because the main counter-argument is correct as far as it goes: pooled custody does spread beneficial ownership across many more people than the address count suggests.

It does not rebut the control claim. Ownership dispersion tells you who benefits if nothing goes wrong. Control concentration tells you how many parties have to fail before it does. Our timeline of custody failures is fifteen years of the second question mattering more.

A second honest limit: 6 of the 13 funds name more than one custodian without disclosing how the bitcoin is split between them. Those are counted at their primary custodian, which is why the headline is a range rather than a single number, and why the conservative reading is lower than 84.5%.

Finally, this covers US spot ETFs only, because prospectus filings make the custodian a matter of public record. Corporate treasuries, private funds and institutional accounts hold a great deal more bitcoin, and almost none of them disclose who holds the keys. The true custody concentration across all custodied bitcoin is not publicly knowable, and is very unlikely to be lower than this.

Fund by fund

Custodians as named in each fund's own filings. Holdings as of July 31, 2026.

FundBTCPrimary custodianAlso namedFiling
IBIT
iShares Bitcoin Trust
The FY2025 10-K states the sponsor has no plans to move any of the trust's bitcoin to the additional custodian. The diversification is documentary rather than operational.
739,066Coinbase CustodyAnchorage DigitalFY2025 10-K
FBTC
Fidelity Wise Origin Bitcoin Fund
Self-custodied by an affiliate of the sponsor. One of only two funds with no Coinbase dependency.
171,561Fidelity Digital Assets—Fund disclosures
GBTC
Grayscale Bitcoin Trust
133,439Coinbase Custody—Fund disclosures
BTC
Grayscale Bitcoin Mini Trust
Anchorage holds a portion; the split is not disclosed.
58,894Coinbase CustodyAnchorage Digital10-Q / FWP
BITB
Bitwise Bitcoin ETF
36,999Coinbase Custody—Q1 2026 10-Q
ARKB
ARK 21Shares Bitcoin ETF
Four custodians named as holding the trust's bitcoin. No allocation disclosed.
33,802Coinbase CustodyBitGo Bank & Trust, BitGo NY Trust, Anchorage Digital10-Q
HODL
VanEck Bitcoin ETF
Widely reported as Coinbase-independent. The FY2025 10-K names Gemini AND Coinbase Custody as the bitcoin custodians who hold all of the trust's bitcoin. It is not independent.
16,616Gemini Trust CompanyCoinbase CustodyFY2025 10-K
MSBT
Morgan Stanley Bitcoin ETF
6,231Coinbase PrimeBNYFund disclosures
BRRR
CoinShares Bitcoin ETF
Three custodians named. Allocation undisclosed.
5,890Coinbase CustodyBitGo Trust, Komainu (Jersey)FY2025 10-K
EZBC
Franklin Bitcoin ETF
5,634Coinbase Custody—Fund disclosures
BTCO
Invesco Galaxy Bitcoin ETF
5,433Coinbase Custody—Fund disclosures
BTCW
WisdomTree Bitcoin Fund
2,230Coinbase Custody—Fund disclosures
DEFI
Hashdex Bitcoin ETF
The only fund custodied solely by BitGo, and one of only two with no Coinbase dependency.
226BitGo Trust Company—FY2025 10-K
Total1,216,021
How to cite
Proof of Custody, Bitcoin ETF Custodian Concentration, proofofcustody.io/research/custody-concentration
Frequently asked questions
Who custodies the bitcoin in US spot bitcoin ETFs?+

One company, Coinbase, is named as sole or primary custodian for about 84.5% of the bitcoin held by US spot bitcoin ETFs, and is named somewhere in the filings of funds holding about 85.9%. Only FBTC and DEFI name no Coinbase entity at all.

What is bitcoin's custody Nakamoto coefficient?+

One. The Nakamoto coefficient is the minimum number of entities whose failure or collusion controls a majority. For US spot ETF custody, a single custodian exceeds a majority on its own. For mining pools the figure is three, so bitcoin's custody layer is more concentrated than its mining layer.

Is VanEck's HODL ETF independent of Coinbase?+

No. It is widely reported as one of two Coinbase-independent funds, but VanEck's FY2025 10-K names Gemini and Coinbase Custody as the bitcoin custodians who hold all of the trust's bitcoin.

Does custody concentration make bitcoin centralized?+

Not at the protocol layer. Nodes and mining remain distributed, and holding coins confers no protocol power. The concentration is in control of keys: how many parties must fail before specific bitcoin is lost. That is a different question from who benefits from the bitcoin, and the historical record of custody failures is about the first one.

The Independence StandardFifteen years of failures