Best practices for your ETF website: How to make your ETF website an asset

4/16/2025

Introduction

Exchange-traded funds (ETFs) have been a cornerstone of modern investing since their inception in the early 1990s. Once known for tracking major indices like the S&P 500, ETFs have evolved into diverse investment products, including active and passive strategies, commodity-focused ETFs, leveraged ETFs, and innovative offerings like non-transparent funds. With assets surpassing $10 trillion in 2024 and inflows totaling $1.1 trillion, ETFs have experienced unprecedented growth in recent years.

This white paper explores:

The regulatory framework surrounding ETF websites
Best practices for structuring your ETF website
How to make your ETF website accessible
How you can leverage your ETF website as a marketing asset

Bar chart titled "Number of Active and Passive ETFs" showing data from 2015 to 2024. Passive ETFs (blue bars) consistently outnumber Active ETFs (red bars), but Active ETFs show significant growth over the period, especially from 2020 onward. By 2024, the number of Active ETFs nearly equals that of Passive ETFs. Source is Morningstar Direct with data as of December 31, 2024

Source: Morningstar Direct. Data as of Dec. 31, 2024

The regulatory landscape for ETF websites

When building your ETF website, it is important to plan to account for the various regulatory requirements that ensure investor protection and transparency. A key piece of recent legislation is SEC Rule 6c-11. Additionally, requirements from Rules 30-e1, 30e-3, and 19a-1 must also be complied with.

We must note that laws and regulations do change. This is not legal advice, and this should not be considered an exhaustive list of regulations. Consult with your legal counsel regarding regulatory requirements.

SEC Rule 6c-11

ETF websites must comply with various SEC regulations to ensure transparency and help investors make informed decisions. Under SEC Rule 6c-11, ETFs must display or disclose:

Their portfolio holdings daily, including details such as ticker symbols
CUSIP numbers
The percentage weight of each holding

Additionally, they must provide:

The current NAV per share
The market price
Any premium or discount relative to the NAV, along with a premium/discount history over the past year
Disclosure if premium/discount was greater than 2% for more than seven consecutive trading days

ETFs using custom baskets of securities must also disclose policies and compliance procedures for their construction. To enhance transparency, ETFs are required to display the median bid–ask spread over the past 30 days and provide clear information about trading costs and risks.

For full details of SEC Rule 6c-11, see the SEC: Exchange-Traded Funds: A Small Entity Compliance Guide.

SEC Rule 30e-1

Further, SEC Rule 30e-1 mandates that ETFs post their annual and semi–annual financial statements on their websites within 60 days after the close of their fiscal periods. The reports must include details on proxy voting results, director and officer compensation, and investment advisory contracts.

For full details of SEC Rule 30e-1 see the Code of Federal Regulations.

SEC Rule 30e-3

SEC Rule 30e-3 also requires mutual funds (and, by extension, ETFs) to prepare detailed annual and semi-annual reports tagged with inline XBRL and to make available the statutory prospectus (in addition to the not required, but often provided, summary prospectus).

Reports must be posted within 60 days of the close of the reporting period and remain available for at least one year. Additionally, you are required to send a notice to investors within 70 days after the period’s close.

These disclosures provide investors with crucial insights into fund performance, governance, and financial health, reinforcing transparency and trust in the ETF market.

For full details of SEC Rule 30e-3 see the SEC: Optional Internet Availability of Investment Company Shareholder Reports Rules.

SEC Rule 19a-1

SEC Rule 19a-1 requires investment companies, like mutual funds and ETFs, to provide written notice to shareholders when distributing dividends, capital gains, or returns of capital that are not derived solely from net income. The notice should specify the source of the distribution (e.g., income, realized gains, or return of capital) to ensure transparency.

For full details of SEC Rule 19a-1 see SEC Rule guidance.

How to structure your ETF website

When designing your website, it is important to consider both regulatory requirements and website users’ needs. Below, we outline key sections and features that your ETF website should include, highlighting considerations for day 1 through the close of your first year, and taking into account SEC requirements.

Importance of structured data

The approach detailed below structures your data on your website to optimize how it is collected, ensuring that the information is read correctly when crawled and gathered by aggregator sites. The SEO on your website must also be a priority, and properly structuring the data optimizes it for SEO. Additionally, the data on your ETF website will be accessible to people with disabilities and those using assistive technology (we get into more details about website accessibility below).

Custodial banks, data providers, and the importance of accurate information

While properly structuring your data is important, the accuracy of the data is equally as important. For this reason, we recommend that you choose a website vendor who will work directly with custodial banks and the exchanges to collect that data, which will assure accuracy and flexibility and also mitigate the risk of error. While this may be more difficult on a technical level than using a data provider, we find that introducing an aggregator introduces an additional level of risk.

1. Fund overview

About the fund: A concise description of the ETF’s investment strategy and focus
Key features: Highlight what sets the ETF apart, whether it’s its low fees, unique strategy, or tax efficiency
Benchmark information: Provide details about the benchmark that the ETF tracks, so investors can understand how the fund compares to the broader market

2. Fund details

Include the following basic fund information:

Inception date
NAV ticker
Exchange
CUSIP

3. Performance data

Provide investors with a comprehensive view of the ETF’s performance:

Daily NAV: Display the daily NAV and market price to give investors an accurate picture of the ETF’s performance
1-Year, YTD, and since inception returns: Allow investors to compare returns for the fund and benchmark over various time periods
Premium/Discount: Show the ETF’s premium or discount relative to its NAV, and provide historical context, especially if the ETF has traded at significant premiums or discounts

What performance data to expect on Day 1:

Limited data, no charts or performance history

What performance data to expect on Day 90:

Data showing the last three months of performance with benchmark data for comparison

What performance data to expect at 1-Year:

Fully populated data with performance, yield, distributions, and full portfolio breakdown

4. Yield information

30-Day SEC yield (with and without waivers): Clearly show yield information for investors, especially as it affects income-based decisions

5. Distributions

Provide a history of any distributions paid by the ETF, including dividends and capital gains. This should be clearly explained for both qualified and unqualified dividends.

6. Pricing & premium/discount history

Display the premium/discount history of the ETF’s shares. This includes:

Premium/Discount percentages over time (displayed in a table and a line graph)
Key SEC requirements: As mentioned above, if an ETF’s premium/discount exceeds 2% for seven consecutive trading days, the website must include additional disclosures

What to expect on Day 1:

No data on premium/discount

What to expect on Day 90:

Data from the past three months is displayed with charts showing premium/discount trends

7. Full investment holdings listings

Daily updates: The SEC requires that ETFs disclose daily updates of:

Their holdings, including the ticker
CUSIP
Description of each holding
Percentage weight within the portfolio

8. Documents section

A dedicated section for official documents is essential for compliance and investor confidence:

Annual reports
Semi-annual reports
Statutory prospectus

Which documents to expect on Day 1:

Access to the Statutory Prospectus, as required by the SEC
Other optional contextual documents such as the Summary Prospectus and/or Fact Sheet

Which documents to expect 6 months into the ETF’s fiscal year:

Access to the Semi-Annual Report that provides a mid-year update on the ETF’s financials and performance
Similar to the Statutory Prospectus, access to Semi-Annual Reports is required by the SEC

Which documents to expect 12 months into the ETF’s fiscal year:

Access to the Annual Report that covers the ETF’s financials and performance over the previous 12-month period, typically coinciding with the ETF’s fiscal year-end
Similar to the Semi-Annual Report, access to the Annual Report

Best practices for ETF Websites

To remain competitive in the rapidly expanding ETF space, it is important for your website to not only be structured properly and meet SEC requirements but also to:

Meet WCAG website accessibility guidelines
Address privacy requirements for your ETF website & limit liabilities
Become a marketing asset and create an exceptional user experience by addressing SEO, mobile, and content strategy

ETF Website accessibility

With roughly 1 in 4 Americans experiencing a temporary or permanent disability, it is critical to be sure to build any website, including ETF websites, to WCAG guidelines. Doing so requires that all aspects of your website, from color contrast to headlines and documents, are easily accessible to people using assistive technology. Overlays or widgets will not address this need, and according to UsableNet’s 2024 Year End Report, 1,023 companies with an accessibility widget live on their website received lawsuits.

While there are not any laws that reference ETF website accessibility specifically, there is an abundance of case law spanning more than the last half-decade that sets a precedent for website accessibility. The following laws could apply to your corporate and ETF websites:

Federal - Americans with Disabilities Act (ADA)

Many lawsuits and proposed regulations rely on the federal Americans with Disabilities Act of 1990 (“ADA”), a civil rights act meant to end discrimination against and increase accessibility of those with disabilities. While the ADA mentions places of public accommodation, the rapidly evolving digital landscape and the importance of websites in everyday business create an argument that websites should be considered public accommodations.

The ADA consists of three titles:

Title I applies to protections in the workplace
Title II applies to protections in government
Title III applies to protections in business. Many suits filed and demand letters sent to businesses cite a violation of Title III.

State and local civil rights laws cited in lawsuits

While many states have implemented civil rights laws that expressly prohibit discrimination based on disability, more than 80% of all website disability lawsuits are filed in New York State. These laws are also cited in the website accessibility cases filed at the federal district court level. You can learn more about the evolving legal landscape by visiting our Website accessibility and the evolving legal landscape page.

WCAG guidelines

We recommend building and maintaining your website to the WCAG 2.2 guideline. As with all websites, you should be sure to pay special attention to the following areas of accessibility on your ETF website.

Color contrast: The difference in brightness between text and background.

Requirement: WCAG 2.2 recommends a contrast ratio of 4.5:1 for normal text and 3:1 for large text. Avoid using color alone to convey information.

Text & fonts: The text content and its style/size.

Requirement: Use clear, legible fonts and ensure text is readable. Sans-serif fonts (e.g., Arial) are easier to read online.

Charts & graphs: Visual data representations.

Requirement: Include text descriptions or interactive alternatives to convey data. Avoid using color alone to convey meaning in charts.

Descriptive alt and link text: Descriptions for images (alt text) and links (link text).

Requirement: Provide clear alt text for images and descriptive link text.

Audio descriptions or media alternatives: Spoken or closed caption descriptions for video visuals or text alternatives for audio.

Requirement: Provide audio descriptions for key visuals in videos and captions or transcripts for audio content.

Additionally, it is necessary to discuss website accessibility with your legal counsel and stay abreast of evolving legislation that pertains to your website in particular.

Leveraging your ETF Website as a marketing asset

Your ETF website not only serves compliance, it can and should also serve your marketing efforts. You can do this by:

Creating a clear value proposition: Engaging investors and advisors to drive informed investment decisions
Performance data & transparency: Highlight value through easy-to-understand charts and graphs
SEO-optimized content & thought leadership: Create blog posts, educational investment information, white papers, and market commentary that position you as a leader, optimizing content for search engines with relevant keywords. (more on SEO below)
Email capture: From financial advisors to individual investors, it is important to clearly communicate with your investors and communicate the value of your fund
Branding: Apply your branding to ETF website, creating consistency across touchpoints

Content strategy, SEO, and mobile

Creating and prioritizing an exceptional user experience is essential and also works in service of your brand. In addition to following the accessibility best practices outlined above, there are several key considerations:

Begin with a clear content strategy: Develop a content strategy that effectively markets your ETF by communicating the value proposition. This should address your audience's key questions, concerns, and interests in a transparent manner.
Integrate SEO considerations: Ensure that your content strategy aligns with your SEO goals. A well-structured, accessible website not only enhances user experience but also improves search engine optimization by organizing content in a way that is both user and search-engine-friendly.
Mobile optimization and fast page loading: Given the increasing number of users accessing content via mobile, it is important to make sure your website is mobile-responsive and provides optimal viewing and interaction experience across all device types.

By addressing these elements, you will create an effective and compelling online presence for your ETF.

Privacy and liabilities

ETF websites may have surprising privacy implications. You should be aware of the following risks, which can be mitigated by using a cookie management system and a privacy policy.

Search functionality

If you have a search bar on your fund website, you may be subject to potential claims and demand letters under the California Invasion of Privacy Act. A 2024 case sparked a wave of demand letters alleging that search terms entered into the search bar are unlawfully being communicated to third parties.

Email alerts

Email sign-up functionality is great for communicating with potential and current investors and advisors. However, email alerts require collecting and storing personally identifiable information (PII). This is primarily governed by the patchwork of U.S. state privacy laws, many of which have varying requirements or applicability based on the data collected. It is important to ensure that your collection and storage of this information comply with the relevant privacy laws applicable to your state.

Cookies and pixels

Along with the patchwork of U.S. state privacy laws that your ETF website may be subject to, Europe's General Data Protection Regulation (GDPR) may also be implicated. If you are marketing your ETF to the EU or UK and you have cookies or pixels on your website that are used on EU or UK visitors, the GDPR is likely applicable to your site. This is the case even if you are not intentionally targeting EU or UK member states.

Solution

As we mentioned above, the best way to address these privacy liabilities is to have a comprehensive cookie management system. Additionally, it is important to have an up-to-date privacy policy.

Privacy law is rapidly evolving, and the above is not legal advice. We recommend discussing your website's privacy requirements with your general counsel or privacy lawyer.

Conclusion

ETFs represent one of the most dynamic segments of the investment market, and their growth trajectory shows no signs of slowing down. As new investors flock to ETFs for their flexibility, tax efficiency, and cost-effectiveness, it is crucial to build ETF websites that meet regulatory requirements, are accessible, and offer a seamless user experience. As the ETF industry evolves, staying ahead of regulatory changes, technological advancements, and investor needs will be key to staying competitive and fostering long-term growth.