market abuse and upholding the integrity of digital asset markets. MiCA was formally approved by the European Union’s member states in 2023. Certain parts of MiCA became effective as of June 2024 and the remainder applied as of December 2024. There remains significant uncertainty regarding foreign governments’ future actions with respect to the regulation of digital assets and Digital Asset Trading Platforms. Such laws, regulations or directives may conflict with those of the United States and may negatively impact the acceptance of AVAX by users, merchants and service providers outside the United States and may therefore impede the growth or sustainability of the AVAX ecosystem in the United States and globally, or otherwise negatively affect the value of AVAX held by the Trust. The effect of any future regulatory change on the Trust or the AVAX held by the Trust is impossible to predict, but such change could be substantial and adverse to the Trust and the value of the Shares. The CFTC has regulatory jurisdiction over the AVAX futures markets because the CFTC believes that most digital assets are non-security “commodities” under the CEA and the rules thereunder, it takes the position that it has jurisdiction to prosecute fraud and manipulation in the cash or spot market for those non-security digital assets. Beyond instances of fraud or manipulation, the CFTC generally does not oversee cash or spot market exchanges, spot Digital Asset Trading Platforms or retail transactions involving spot AVAX that do not utilize collateral, leverage, or financing. The National Futures Association (“NFA”) is the self-regulatory agency for the U.S. futures industry, and as such has jurisdiction over AVAX futures. However, the NFA does not have regulatory oversight authority for the cash or spot market for AVAX trading or transactions. In April 2024, Coinbase Derivatives as a designated contract market (“DCM”) registered with the CFTC launched new contracts for AVAX futures products. DCMs are boards of trades (commonly referred to as exchanges) that operate under the regulatory oversight of the CFTC, pursuant to Section 5 of the CEA. To obtain and maintain designation as a DCM, an exchange must comply on an initial and ongoing basis with twenty-three Core Principles established under Section 5(d) of the CEA. Among other things, DCMs are required to establish self-regulatory programs designed to enforce the DCM’s rules, prevent market manipulation and customer and market abuses, and ensure the recording and safe storage of trade information. The CFTC engaged in a “heightened review” of the self-certification of AVAX futures, which required DCMs to enter direct or indirect information sharing agreements with spot market platforms to allow access to trade and trader data; monitor data from cash markets with respect to price settlements and other AVAX prices more broadly, and identify anomalies and disproportionate moves in the cash markets compared to the futures markets; engage in inquiries, including at the trade settlement level when necessary; and agree to regular coordination with CFTC surveillance staff on trade activities, including providing the CFTC surveillance team with trade settlement data upon request. The Coinbase Derivatives AVAX futures contracts are cash-settled, based on the MarketVector Coinbase Avalanche Benchmark Rate. On December 4, 2025, CFTC Acting Chairman Caroline D. Pham announced that listed spot crypto asset products will begin trading on a CFTC-registered futures exchange (DCM). This is the first initiative in the CFTC’s “crypto sprint” to start implementation of the recommendations in the President’s Working Group on Digital Asset Markets report. Members of the public were invited to provide written input by August 18, 2025 through the CFTC website. See “Risk Factors—Risk Factors Related to the Regulation of Digital Assets, the Trust and the Shares— Regulatory changes or actions by the U.S. Congress or any U.S. federal or state agencies may affect the value of the Shares or restrict the use of AVAX, validating activity or the operation of the Avalanche Network or the Digital Asset Markets in a manner that adversely affects the value of the Shares.” Description of the Trust The Trust is a Delaware Statutory Trust that was formed on November 11, 2021 by the filing of the Certificate of Trust with the Delaware Secretary of State in accordance with the provisions of the Delaware Statutory Trust Act (“DSTA”). The name of the Trust is Grayscale Avalanche Staking ETF as of the date of this prospectus. On March 11, 2026, the Trust changed its name from Grayscale Avalanche Trust (AVAX) to Grayscale Avalanche Staking ETF by filing a Certificate of Amendment to the Certificate of Trust with the Delaware Secretary of State in accordance with the provisions of the DSTA. The Trust operates pursuant to the Trust Agreement.
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