Cboe C2 Codifies Fees: Exemptions and Clearer Non-Display Rules Apply
Published Date: 4/28/2026
Notice
Summary
Cboe C2 Exchange just updated its fee schedule to officially include a User Fee exemption and clarify what counts as “Non-Display Usage.” This means some users won’t have to pay certain fees, and the rules about data use are clearer. These changes took effect right away on April 21, 2026, helping traders and data users save money and avoid confusion.
Analyzed Economic Effects
3 provisions identified: 2 benefits, 1 costs, 0 mixed.
User Fee Exemption for Controlled Distributors
As of April 21, 2026, Controlled Distributors will not be charged Display Usage fees for the Exchange's listed market data products when the sole purpose of receiving the data is software development, quality assurance, testing, sales support relating to redistribution, or technical monitoring of systems (the "Permitted Purposes"). The Exchange codified this existing fee exemption into its Fee Schedule so those Controlled Distributors and their Users will not be assessed Display Usage fees in those situations.
Expanded Non-Display Usage Definition (LLM Impact)
The Exchange codified an amended definition of "Non-Display Usage" that includes "accessing, or facilitating access to, a Market Data product that involves access or use by a machine or automated device for a purpose that is not solely in support of display for a natural person or persons." The Exchange notes this amendment (the Cboe North American Data Policies version became effective April 1, 2026) may mean firms that feed data into "black box" solutions, including Large Language Models (LLMs), may now need to obtain non-display licensing for their use of Data Products; the Fee Schedule codification took effect April 21, 2026.
Definitions Codified for Greater Clarity
On April 21, 2026 the Exchange added formal definitions for Controlled Distributor, Display Usage, and Uncontrolled Distributor directly into its Fee Schedule. This codification is intended to give market participants clearer terms so they can determine whether the Display Usage exemption or Non-Display rules apply to them.
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Department and Agencies
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Previous / Next Documents
Previous: 2026-08186 — Self-Regulatory Organizations; Cboe Exchange, Inc.; Notice of Filing and Immediate Effectiveness of a Proposed Rule Change To Amend Its Fee Schedule To Codify a User Fee Exemption and the Amended Definition of “Non-Display Usage” in Its Fee Schedule
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.
Next: 2026-08188 — Self-Regulatory Organizations; Cboe BZX Exchange, Inc.; Notice of Filing and Immediate Effectiveness of a Proposed Rule Change To Amend Its Fees Schedule To Codify a User Fee Exemption and the Amended Definition of “Non-Display Usage” in Its Fee Schedule
Cboe BZX 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 BZX’s market data, making fees clearer and fairer starting immediately. No new fees are added, but the rules on who pays what just got tidier and easier to follow.