Nasdaq's Fee Shuffle and Liquidity VIP Club Launch
Published Date: 9/1/2026
Notice
Summary
Starting September 1, 2026, Nasdaq is updating its fees for listing exchange-traded products (ETPs) and launching a new Quality Liquidity Provider program to boost market quality. This means companies with ETPs will see some fee changes, and traders who provide steady, reliable liquidity can join the new program for perks. These changes aim to make Nasdaq’s market smarter and smoother while keeping costs clear and fair.
Analyzed Economic Effects
6 provisions identified: 3 benefits, 1 costs, 2 mixed.
Optional $50,000 Premier ETP Listing Fee
Starting September 1, 2026, Nasdaq adds a new optional Premier Annual Listing Fee of $50,000 per exchange-traded product (ETP) as an alternative to the existing $4,000 Standard Annual Listing Fee. Issuers that pay the $50,000 fee become eligible for the Exchange's Quality Liquidity Provider (QLP) program; issuers may switch mid-year (Premier→Standard: no credit or offset; Standard→Premier: Premier fee prorated and credited for unused months of the Standard fee).
New Quality Liquidity Provider Program
Nasdaq adds a Quality Liquidity Provider (QLP) program in Equity 7, Section 114(h) effective September 1, 2026. A QLP is a registered Nasdaq market maker selected by Nasdaq for a Qualified Security; QLP assignments are limited to one QLP per Qualified Security and QLP incentives are paid from the Exchange's general revenues.
QLP Stipends and Tape C Rebates
Under the QLP program, a qualifying QLP earns a fixed stipend of $3,000 per month for each assigned ETP that meets the program's metrics. QLPs may also earn incremental Tape C ETP rebates per displayed executed share based on tiered minimum monthly average assigned ETP counts: Tier 1 (20 assigned ETPs) $0.00025/share; Tier 2 (35) $0.00035/share; Tier 3 (75) $0.00040/share; Tier 4 (135) $0.00045/share; Tier 5 (200) $0.00055/share; rebates apply only to executions at $1.00 per share and above.
QLP Limited to Low‑Volume Qualified ETPs
The QLP program only applies to Low Volume ETPs defined as monthly average daily volume (ADV) of 1 million shares or less in the prior month; Nasdaq will annually remove ETPs whose average ADV over the prior year exceeds 1 million shares. Additionally, a Qualified Security must be an ETP listed under a specified, narrower set of Nasdaq listing rules and the issuer must pay the Premier Annual Listing Fee of $50,000 to be eligible.
QLP Performance Metrics, Waivers, And Forfeit Rules
QLPs must meet program Market Quality Metrics (MQMs) — generally 5 of 7 monthly metrics — that vary by Investment Strategy Group (A/B/C) with specific numeric thresholds (e.g., Time at NBBO 50%; Average Notional Depth $65,000/$50,000/$40,000 for Groups A/B/C; Average Spread 25/45/85 basis points; auction-related metrics) and certain notional/percent-of-days requirements. If a QLP fails monthly MQMs, fees/credits revert to the normal schedule; failure in 3 of the past 4 months can lead to forfeiture of QLP status. New QLP allocations or launches are automatically eligible for the monthly stipend and Tier 5 rebate for the current month and the immediately following month (QLP MQM waiver for those months).
Program Interaction With DLP and MQS Roles
A QLP is not eligible to receive DLP program incentives for the same ETP, and a DLP is not eligible to receive QLP incentives for the same ETP; however, a QLP that also serves as a Market Quality Supporter (MQS) may receive the MQS stipend if it meets both programs' MQMs. DLP and QLP assignments both count toward the minimum monthly average number of assigned ETPs used to determine Tape C rebate tiers.
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