Cboe BZX Mirrors Fee Shift: Customers Alone Bear ORF Burden
Published Date: 12/18/2025
Notice
Summary
Starting July 1, 2026, Cboe BZX Exchange is changing how it charges the Options Regulatory Fee (ORF). Only options trades that clear as customer transactions on the Exchange will be charged this fee. This update affects traders using the Exchange and aims to make fee collection clearer and fairer.
Analyzed Economic Effects
7 provisions identified: 1 benefits, 3 costs, 3 mixed.
ORF Charged Only for On-Exchange Customer Trades
Starting July 1, 2026, the Exchange plans to assess the Options Regulatory Fee (ORF) only on options transactions that occur on Cboe BZX and would clear in the OCC Customer range. Trades that occur off the Exchange would no longer be assessed an ORF by BZX under the proposed methodology.
Example: ORF Rate Would Rise to $0.00467
The Exchange estimates that if the On-Exchange ORF model were in effect today, the ORF would increase from $0.0001 per contract side to an estimated $0.00467 per contract side using 2026 estimates of regulatory revenue, regulatory costs, and customer volume.
Exchange Will Exclude CMTAs Reported Only to OCC
Under the proposal, the Exchange will account only for CMTA transfers reported to the Exchange and will exclude CMTA transfers reported directly to OCC when calculating On-Exchange ORF. The Exchange says CMTA reports to OCC may not reliably identify the original exchange where the trade occurred.
Exchange Expects Members to Pass Through ORF to Customers
The Exchange states it expects that Members from whom On-Exchange ORF is collected will pass the fee through to their customers, as the Exchange understands occurs today.
Planned Jan 1, 2026 ORF Increase to $0.0002
The Exchange states it intends to file to increase the current ORF to $0.0002 per contract effective January 1, 2026.
Implementation Contingent on Industry Coordination
BZX will collect ORF under the current method until at least June 30, 2026 and is prepared to implement On-Exchange ORF effective July 1, 2026 only if by April 1, 2026 all U.S. options exchanges charging an ORF have filed to adopt a similar on-exchange methodology; otherwise the Exchange will delay implementation. The Exchange will file the On-Exchange ORF rate separately and provide at least 30 days' notice before assessing the fee.
ORF Revenue Capped and Monitored (≤75% of Costs)
The Exchange says revenue from On-Exchange ORF, combined with other regulatory fees and fines, is intended not to exceed 75% of total annual regulatory costs; the Exchange will monitor revenues at least semi-annually and will file to adjust the ORF if revenues exceed or are insufficient to cover a material portion of regulatory costs.
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