Nasdaq Ends Partial Refunds for ETF Liquidations in Fee Overhaul
Published Date: 1/22/2026
Notice
Summary
Nasdaq is updating its fees and rules for Exchange-Traded Products (ETPs). They’re adding a new Class ETF Shares fee, stopping partial refunds when ETPs close, and tweaking how they reward market makers who keep trading smooth. These changes kick in right away and could affect anyone listing or trading these products on Nasdaq.
Analyzed Economic Effects
5 provisions identified: 1 benefits, 3 costs, 1 mixed.
No More Prorated Liquidation Refunds
Nasdaq will eliminate the prorated refund of the $4,000 annual listing fee when an ETP liquidates. If an ETP ceases operations during the calendar year, its issuer will no longer receive a months-prorated refund of that annual fee.
Class ETF Shares: Annual $4,000 Listing Fee
If you issue Class ETF Shares on Nasdaq, there will be no initial listing or application fee, but Nasdaq will charge an annual listing fee of $4,000 per product. This change applies to Class ETF Shares listed pursuant to Rule 5703.
DLP/MQS: 50% Notional-Day Requirement
For certain market-quality metrics, if a Designated Liquidity Provider (DLP) or Market Quality Supporter (MQS) does not meet a notional threshold on a trading day, that day will be excluded from the monthly average for that metric. The DLP or MQS must meet the applicable notional thresholds on at least 50% of trading days in a month or it will be deemed to have failed that monthly metric.
Class ETF Shares Eligible for DLP/MQS Support
Nasdaq will add Class ETF Shares to the list of ETPs that may be designated as Qualified Securities for the Designated Liquidity Provider (DLP) and Market Quality Supporter (MQS) programs. That means future Class ETF Shares can receive the same rebates and stipends available to other Nasdaq-listed ETPs under those programs.
MQS Eligibility: Assignment-Time Measurement and Annual Review
An ETP will qualify as a 'Low Volume' ETP for MQS assignment if it had a monthly average daily volume (ADV) of 1 million shares or less in the prior month measured at the time the MQS is assigned. Nasdaq will also review MQS assignments annually and remove ETPs that average more than 1 million shares ADV over the prior year from the program.
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