Cboe Tweaks Options Fees: Only Customers Pay Up Starting 2026
Published Date: 12/18/2025
Notice
Summary
Starting July 1, 2026, Cboe C2 Exchange is changing how it charges the Options Regulatory Fee (ORF). Now, only options trades that clear as customer transactions will be charged this fee, making the process fairer and clearer. Traders and firms using Cboe C2 should get ready for this new way of paying the ORF, which could affect their costs.
Analyzed Economic Effects
5 provisions identified: 1 benefits, 2 costs, 2 mixed.
Estimated On‑Exchange ORF Jump to $0.01521
The Exchange estimates that, if the On-Exchange ORF model were in effect today, the ORF would increase from $0.0002 per contract side to an estimated $0.01521 per contract side based on 2026 estimates of regulatory revenue, costs, and customer volume. The Exchange will file the applicable On-Exchange ORF rate in a separate filing and provide at least 30 days' notice before assessing that rate.
ORF Only on C2 On‑Exchange Customer Trades
Starting July 1, 2026, Cboe C2 proposes to assess the Options Regulatory Fee (ORF) only on options transactions that occur on C2 and would clear in the OCC "Customer" range. C2 would no longer assess ORF on customer trades that occur on other exchanges. Implementation is conditional: C2 will implement July 1, 2026 if all U.S. options exchanges charging an ORF file to adopt similar exchange-limited methodologies by April 1, 2026; otherwise C2 will delay implementation and will give at least 30 days' notice of the On-Exchange ORF rate.
CMTA Transfers Limited to Exchange‑Reported
Under the proposed On-Exchange ORF, the Exchange will account for Clearing Member Trade Assignments (CMTAs) only if the CMTA is reported to the Exchange and will exclude CMTAs reported directly to OCC. That means ORF adjustments tied to CMTAs reported only to OCC would not be considered in C2's On-Exchange ORF calculation, which may change which clearing firm is billed for ORF on some transfers.
Planned Small ORF Increase Jan 2, 2026
The Exchange intends to file an ORF increase to $0.0003 per contract effective January 2, 2026. This is a separate, earlier rate filing the Exchange states it will submit prior to any On-Exchange ORF implementation.
ORF Revenue Cap and Semiannual Monitoring
C2 will monitor On-Exchange ORF revenue at least semi-annually to ensure combined regulatory fees do not exceed total regulatory costs; the Exchange expects ORF revenue to remain no more than 75% of total annual regulatory costs and states ORF revenue will not be used for non-regulatory purposes. If revenues exceed or are insufficient, the Exchange will file to adjust the ORF and will notify TPHs in advance.
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