Grayscale’s filing for a proposed Worldcoin ETF has revealed that the 100 largest wallets control roughly 90% of the circulating WLD supply.
Summary
- Grayscale’s proposed Worldcoin ETF filing says the largest 100 wallets hold about 90% of the circulating WLD supply.
- The filing states that governance remains largely under the World Foundation while World Chain continues to rely on centralized infrastructure.
- The disclosures come days after Grayscale sought SEC approval to launch a spot Worldcoin ETF that would hold WLD directly.
According to a recent SEC registration statement filed by Grayscale for its proposed Grayscale Worldcoin ETF, the largest 100 wallets held approximately 90% of all WLD in circulation as of the filing date. The disclosure appeared in the fund’s risk factors, where the asset manager outlined ownership concentration and governance risks tied to the token that would back the proposed exchange-traded fund.
The filing comes only days after Grayscale sought approval to list the product on Nasdaq under the ticker GWLD, offering investors direct exposure to Worldcoin through a traditional brokerage account instead of requiring them to purchase and store the token themselves.
If approved, the trust would hold WLD directly, use the CoinDesk Worldcoin Benchmark Rate to determine its net asset value, and rely on BitGo Bank & Trust as custodian, while The Bank of New York Mellon would serve as administrator and transfer agent.
The ownership data disclosed by Grayscale differs from Worldcoin’s original vision for token distribution.
Worldcoin’s whitepaper said most WLD tokens would eventually be claimed by individuals who verified themselves as unique humans through the project’s identity system. Grayscale instead warned that a relatively small group of early adopters currently controls a substantial share of the tokens already released.
The registration statement adds that it is “reasonably likely” that early holders own a significant portion of the circulating supply, making WLD more concentrated than its long-term distribution goals suggest.
One of the largest addresses identified in public blockchain data belongs to the bridge connecting Ethereum and World Chain, meaning part of the concentrated holdings may represent assets deposited by multiple users rather than a single owner. Even so, Grayscale’s filing presents the overall concentration level as a material risk for prospective investors.
Filing outlines governance and decentralization risks
Beyond token ownership, the filing also describes several parts of the World Network that remain under centralized control.
According to Grayscale, governance of the network continues to be substantially guided by the World Foundation despite previous plans to decentralize decision-making over time. The filing states that WLD may eventually be used for governance, although the mechanisms required to support that transition remain new and untested at scale.
The disclosure contrasts with earlier statements from the project, which had promoted proof-of-personhood as a foundation for one-person-one-vote governance. Grayscale’s prospectus says governance has not yet reached that stage and continues to rely largely on the World Foundation.
The filing also identifies operational risks linked to the blockchain itself. World Chain currently depends on a centralized sequencer, while upgrade functions remain under the coordinated control of a limited group associated with the World Foundation, Tools for Humanity, and Optimism, the Ethereum layer-2 infrastructure supporting the network.
Grayscale further states that the Orb devices used to verify users are still manufactured and distributed mainly by or under the direction of Tools for Humanity. The filing also notes that the World Foundation continues to exercise significant influence over the protocol, the WLD treasury, and ecosystem grants.
ETF proposal arrives after recent ecosystem developments
The governance disclosures accompany Grayscale’s broader proposal to launch the first U.S. exchange-traded fund holding WLD directly.
Under the proposed structure, the trust would function as a passive investment vehicle without leverage or derivatives. Authorized participants would create and redeem shares in blocks of 10,000, known as baskets, either by delivering WLD directly or through cash transactions facilitated by liquidity providers. Grayscale has not yet disclosed the management fee, seed investment, or the number of WLD represented by each share, leaving those details for future amendments.
The SEC filing does not guarantee regulatory approval, and Nasdaq cannot list the product unless regulators approve the registration process.
The proposed ETF follows several developments that have increased attention on Worldcoin during recent months. In June, Robinhood added WLD to its trading platform, giving the token access to a larger retail audience.
Despite the listing, WLD fell nearly 15% on the day as traders focused instead on allegations reported by third parties involving Sam Altman and entities connected to the Worldcoin ecosystem, alongside continuing criticism of the project’s biometric identity verification system and token distribution model.
