Cboe Exchange Updates: Fee Exemptions and Non-Display Data Rules
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 some fees clearer and potentially saving money. The new rules kicked in right away on April 21, 2026, so users should check how this impacts their costs now.
Analyzed Economic Effects
2 provisions identified: 1 benefits, 1 costs, 0 mixed.
Non-Display Definition Expanded (LLMs)
Cboe updated and codified its definition of “Non-Display Usage” to include any access or facilitating access to market data by a machine or automated device that is not solely for display to a person, expressly capturing use cases such as feeding data into large language models (LLMs) or other “black box” solutions. The Exchange states firms that transmit Data Products into such automated/LLM environments may now need to obtain non-display licensing; this change took effect April 21, 2026.
Display-Usage Fee Exemption Codified
Cboe formally put into its Fee Schedule an exemption that lets Controlled Distributors avoid Display Usage fees for Data Products when the sole purpose is software development, quality assurance, testing, sales support for redistribution, or technical monitoring (the “Permitted Purposes”). The Exchange says this codifies an existing practice and the change became effective April 21, 2026.
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