Roundhill puts an AI power ETF in registration as APOW

Four listed funds already offer a book of companies that generate or deliver electric power for AI, or cool the data centers that use it. The largest, the Defiance AI & Power Infrastructure ETF CAIPO, had $915 million in assets on Monday, and through Friday it was down 16% over three months. Roundhill ETF Trust asked the SEC on Friday to add a fifth.

The filing is Post-Effective Amendment No. 343 on the trust’s 2023 shelf, a Rule 485(a) amendment that would add the Roundhill AI Power & Infrastructure ETF APOW as a new series. The prospectus is marked “Subject to Completion September 18, 2026.” The trust selected automatic effectiveness 75 days after filing under paragraph (a)(2), a clock the SEC or a later amendment can still interrupt. The listing exchange is blank, the management fee is printed as 0.__%, and the shares may not be sold until the registration statement is effective. The filing does not name a commencement date.

What the APOW prospectus proposes

The fund is described as actively managed and has not commenced operations. Under normal circumstances it would invest at least 80% of net assets, plus borrowings for investment purposes, in equity securities of AI power companies and AI infrastructure companies, or in instruments such as swaps or forward contracts that provide that exposure.

The adviser, Roundhill Financial Inc., defines those companies as businesses whose core technology, products, or services involve the design, manufacture, construction, generation, delivery, or enabling of electric power and power-delivery equipment used to support AI and other high-density computing. The examples in the filing are data-center power systems, power-generation equipment and capacity, electrical-grid infrastructure, and grid-modernization technologies. Portfolio weights would follow a modified market-cap method, with the book rebalanced at least quarterly. The draft defines those companies by what they make and do; it does not impose a minimum-revenue screen.

Distribution and 12b-1 fees are 0.00%, other expenses are 0.00%, and the advisory contract is a unitary arrangement: Roundhill would pay the fund’s ordinary operating costs, with the usual exclusions for its own fee, interest on borrowings, and similar items.

The amendment’s prospectus and statement of additional information are written for APOW only. The paper does not recast the fees or strategies of Roundhill’s listed funds, and it does not present APOW as a rename or conversion of an existing series.

The AI-power funds already trading

CAIPO holds U.S.-listed electrical-grid, data-center, and AI-infrastructure companies, began trading on July 24, 2025, and charges 0.69%. Through Friday it was up 29% year to date and 33% over 12 months. Its largest positions on the latest holdings file were Eaton, Quanta Services, GE Vernova, Vertiv, and Bloom Energy, with Alphabet, NVIDIA, and Broadcom still inside the top 10.

The three-month loss is not CAIPO’s alone. The VistaShares Electrification Supercycle ETF DPOW, listed on October 28, 2025 and marketed by its issuer as an AI-power infrastructure fund, was down 18% over the same stretch. The Dan Ives Wedbush AI Power & Infrastructure ETF DIVEP, listed in April, was down 12%. Among CAIPO’s largest holdings, Vertiv fell 25%, GE Vernova 15%, and Bloom Energy 19% over three months; Eaton was little changed. Bank of America analyst Andrew Obin, in a note published Sunday, said demand from Microsoft, Amazon, Google, and Meta was holding up and that order books at the cooling and power vendors remained strong. He reiterated buy ratings on Eaton, GE Vernova, and Vertiv.

Defiance’s index takes U.S.-listed companies that derive at least half their revenue from AI hardware, data centers, power infrastructure, or related businesses. That is a wider screen than the power-and-grid definition in Roundhill’s draft. DIVEP’s Solactive index also requires that at least half of revenue come from designated AI power businesses. APOW’s draft does not publish a portfolio. Any comparison of overlap is, for now, a comparison of prospectuses.

DIVEP held $16.3 million and charges 0.75%. DPOW held $61.6 million at the same fee. A fourth product, the VegaShares AI Thermal, Cooling & Power Management ETF —COOL, listed on August 13, held $1.6 million and also charges 0.75%.

At DIVEP’s launch, Cullen Rogers, chief investment officer of Wedbush Fund Advisers, said energy and infrastructure were “emerging as critical bottlenecks,” and that “every dollar spent on AI ultimately requires energy.”

Roundhill’s other AI products

Roundhill has spent this year listing narrower AI-infrastructure books. The Roundhill Memory ETF CDRAM, which holds semiconductor-memory companies and listed on April 2, had $25.9 billion in assets on Monday and charges 0.65%, a scale the later slices have not approached. On August 6 the firm listed a neocloud fund, —NCLD ($92 million), and a photonics and optics fund, —LYTE ($263 million), both at 0.65%; the launch release described those two as “the compute and connectivity layers powering the AI infrastructure buildout.” On September 9 it listed an MLCC and electronic-components fund, —CCML ($6.1 million), also at 0.65%.

APOW would be the power-and-grid cut of that sequence, filed nine days after —CCML began trading. Roundhill already runs a separate generative-AI equity fund, CCHAT, with $1.84 billion. That portfolio is semiconductor, software, and platform names, not the electrical kit in Friday’s draft. The 0.65% fee on CDRAM, —NCLD, —LYTE, and —CCML is the closest live Roundhill analogue; it is not APOW’s fee.

Roundhill is on its fifth thin slice of AI infrastructure in six months. The power-and-grid book the filing would enter is already four funds deep, and the three that have a three-month record are all down.