BlackRock has challenged an Invesco-led market structure by submitting listing documents to the U.S. Securities and Exchange Commission for an “iShares Nasdaq-100 ETF” that tracks the Nasdaq 100 index.

BeInCrypto, a blockchain media outlet, reported on Sunday that BlackRock proposed “IQQ” as a tentative ticker for the new ETF. ETF analyst Eric Balchunas estimated total fees at around 0.12 percent. That would be lower than 0.18 percent for the Invesco QQQ Trust (QQQ) and 0.15 percent for the Invesco Nasdaq 100 ETF (QQQM). Balchunas said if fees are set at 0.1 to 0.12 percent, there is room for new money in 401(k) plans, robo-adviser platforms and advisers’ model portfolios to shift.

BlackRock has previously used an entry strategy built on low fees and distribution networks. Its iShares Bitcoin Trust (IBIT) quickly attracted inflows into spot bitcoin ETFs using the same approach.

Scale and ecosystem are also strengths. BlackRock’s total assets under management exceed $14 trillion, and it has also run Nasdaq 100-related products in Canada, Europe and Hong Kong. Advisers using existing iShares products can add a Nasdaq 100 product within the same system. The Aladdin analytics platform is also seen as favorable for securing institutional clients.

Some observers say IQQ could start out with an advantage in product structure as well. The existing QQQ only converted from a unit investment trust structure to a typical open-end fund ETF in December 2025. Critics had said the earlier UIT structure could create inefficiencies such as “cash drag,” where cash remains during the dividend reinvestment process. BlackRock is also seen as having strengths in generating securities-lending revenue, which could offset some costs.

Invesco’s existing moat remains solid. QQQ is seen as a highly liquid ETF, with tens of millions of shares trading a day and very tight bid-ask spreads. It is also used as a key underlying asset in options and futures markets, deeply embedded in institutional investors’ trading strategies. Invesco currently manages more than $430 billion in assets, including about $360 billion to $370 billion in QQQ and about $70 billion in QQQM. In taxable accounts, switching can trigger capital gains burdens, and in retirement accounts, advisers need to actively decide to rebalance, creating some friction in moving money.

The market therefore leans toward the view that the competition is more likely to expand the overall market than to fully replace existing products. BeInCrypto laid out a scenario in which BlackRock could attract $20 billion to $50 billion in assets over the next 2 to 3 years. It said a realistic approach would be to absorb new inflows while shifting some fee-sensitive long-term investment money from QQQM. With the full prospectus and final fees not yet disclosed, early demand for IQQ is expected to depend heavily on the fee level.