Cboe Fees Shuffle: Trading Costs Get a Minor Makeover
Published Date: 12/8/2025
Notice
Summary
Cboe BZX Exchange just updated its fee schedule to add 12 new fee codes and 3 volume-based discounts for their new Complex order feature, which started in October 2025. Traders using these Complex orders will see these changes immediately, aiming to reward higher trading volumes with better fees. This means if you trade complex orders on BZX, expect new fees and chances to save money based on how much you trade!
Analyzed Economic Effects
4 provisions identified: 3 benefits, 1 costs, 0 mixed.
New Customer Complex Order Rebates
If you are a Customer trading Complex orders on the BZX Complex Order Book (COB), the Exchange will give rebates of $0.40 per contract (fee code ZA) for Customer vs Non-Customer trades in Penny Program Securities and $0.80 per contract (fee code ZB) for Customer vs Non-Customer trades in Non-Penny Program Securities. Customer-to-Customer Complex orders (fee code ZC) will be charged no fee and receive no rebate.
Non-Customer Complex Order Fees
If you are a Non-Customer trading Complex orders on the BZX COB, the Exchange will charge fees of $0.50 per contract for Non-Customer add or remove liquidity in Penny Program Securities (fee codes ZF and ZG) and $0.90 per contract for Non-Customer add or remove liquidity in Non-Penny Program Securities (fee codes ZH and ZJ).
Volume Tiers Offer Bigger Rebates and Discounts
BZX added three volume-based tiers for Complex Customer (contra Non-Customer) orders and one tier for Complex Non-Customer Penny add volume. For fee code ZA (Customer vs Non-Customer in Penny securities) rebates rise to $0.43, $0.45, and $0.47 per contract at ADV thresholds of >=0.10%, >=0.15% (plus ADAV >=0.35% for Market Maker orders), and >=0.25% (plus ADAV >=0.35%), respectively. For fee code ZB (Non-Penny) rebates are $0.84, $0.88, and $0.92 per contract at the same ADV/ADAV thresholds. For fee code ZF (Non-Customer Penny add), qualifying members pay a reduced fee of $0.49 per contract if they meet ADV >=0.15% and ADAV >=0.35% of average OCV.
Zero Fees for Legs and Open Complex Trades
Some Complex-related executions will have no fee or rebate: Customer Complex orders that leg into the Simple Book (fee code ZD) and certain Non-Customer legs (fee codes ZO, ZP), Complex orders that trade at the open (fee code OC), and Simple order trades that interact with a Complex order (fee code ZE) will not be charged a fee or given a rebate.
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