Cboe C2 Tightens Up Fee Definitions for Data Traders
Published Date: 4/28/2026
Notice
Summary
Cboe C2 Exchange just updated its fee schedule to officially include a User Fee exemption and a clearer definition of “Non-Display Usage.” This change affects traders and firms using market data, making fees fairer and easier to understand. The new rules kicked in right away on April 21, 2026, so everyone should check their fees now!
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Analyzed Economic Effects
2 provisions identified: 1 benefits, 1 costs, 0 mixed.
Broader 'Non-Display' Definition Covers AI Uses
The Exchange amended and codified the definition of "Non-Display Usage" to mean any access (or facilitating access) to a Market Data product by a machine or automated device for a purpose not solely in support of display for a natural person. Firms that feed data into Large Language Models (LLMs) or other "black box" solutions may now fall under Non-Display and need a non-display license; this was codified effective April 21, 2026.
Fee Exemption for Development and Testing
If you are a Controlled Distributor, you will not be charged Display Usage fees when a Data Product is used solely for software development, quality assurance, testing, sales support relating to redistribution, or technical monitoring of systems. The Exchange codified this User Fee exemption in its Fee Schedule effective April 21, 2026.
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