Cboe Exchange Spells Out Fee Exemptions for Market Data
Published Date: 4/28/2026
Notice
Summary
Cboe Exchange just updated its fee schedule to officially include a User Fee exemption and clarify what counts as “Non-Display Usage” of market data. This change affects traders and firms using Cboe’s market data, making fees clearer and fairer starting immediately. No new fees are added, but the rules about who pays and who doesn’t are now spelled out in black and white.
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Analyzed Economic Effects
2 provisions identified: 1 benefits, 1 costs, 0 mixed.
Non-Display Definition Expanded to Cover LLM Use
Cboe is codifying an amended definition of "Non-Display Usage" to mean any access or facilitation of access to market data by a machine or automated device for purposes not solely supporting display for a person. The amended definition (adopted in the Cboe North American Data Policies effective April 1, 2026 and filed into the Fee Schedule on April 21, 2026) may require firms that feed data into "black box" systems (including Large Language Models) to obtain non-display licensing.
Display Fee Exemption Codified for Controlled Distributors
Cboe formally put into its Fee Schedule an existing exemption that says Controlled Distributors will not be charged Display Usage fees when the market data is used only for software development, quality assurance, testing, sales support for redistribution, or technical monitoring (the "Permitted Purposes"). The Exchange says this codifies an existing practice and was filed on April 21, 2026, so no substantive change in how fees are applied is being introduced.
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