Nasdaq Caps Options Fees to Ease Market Maker Wallet Woes
Published Date: 12/18/2025
Notice
Summary
Nasdaq PHLX is updating its rules to change the monthly fee caps for market makers and firms trading certain options. This affects traders dealing with multiply listed options like stocks, ETFs, and indexes (but not SPY or broad-based indexes). The new fee caps take effect immediately, aiming to keep trading costs fair and clear.
Analyzed Economic Effects
4 provisions identified: 0 benefits, 3 costs, 1 mixed.
Market-Maker Cap: New Fee Exclusions
If you are a Lead Market Maker or Market Maker, the Monthly Market Maker Cap remains $500,000 but the Exchange explicitly excludes Crossing Order Fees and FLEX Electronic Transaction Fees from that cap. The cap still excludes surcharges and options overlying broad-based index symbols listed in Options 7, Section 5.A, and the Exchange migration of new functionality completes on December 8, 2025.
Per-Contract Fees When Cap Is Reached
The filing reiterates that Lead Market Makers or Market Makers who are on the contra-side of an electronically-delivered and executed Customer order and have reached the Monthly Market Maker Cap are assessed per-contract fees: $0.05 per contract for Adding Liquidity in Penny Symbols and $0.18 per contract for Removing Liquidity in Penny Symbols, Non-Penny Symbols, and non-Complex electronic auctions.
Firm Monthly Cap Clarified — Electronic Fees Excluded
Firms remain subject to a $250,000 Monthly Firm Fee Cap, and the Exchange now explicitly states that Electronic Options Transaction Charges are excluded from that cap. The filing also adds a citation for QCC Transaction Charges.
Which Options This Covers
The amended Pricing Schedule and caps apply to Multiply Listed Options — including options overlying equities, ETFs, ETNs and indexes — but explicitly exclude SPY and broad-based index option symbols listed within Options 7, Section 5.A. Changes described in the filing apply to those multiply listed classes.
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