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Cboe BZX ends the $4,000 legacy-ETP discount, raising some 2027 listing fees

Pre-2019 ETPs will lose their special $4,000 category and move to the lowest other applicable fee, while transfer listings retain the $4,000 incentive and the volume schedule runs from $5,000 to $7,000.

Cboe BZX is ending the special $4,000 annual listing fee for exchange-traded products that were already listed before 1 January 2019. Despite the filing’s phrase “eliminate the annual listing fee applicable to Legacy Listings,” the change does not make those products free. It removes their legacy category and sends them to the lowest other fee for which they qualify.[1][2]

For many former legacy products, that means the volume-based schedule: $7,000 where fourth-quarter consolidated average daily volume is 0-10,000 shares, $6,000 at 10,001-100,000, $5,500 at 100,001-1,000,000 and $5,000 above one million. The $4,000 rate remains for Transfer Listings, preserving a lower fee for products moved from another national exchange.[1][2]

Removing the category raises the fee for many older products

At a glance01

BZX annual ETP fee treatment

BZX annual ETP fee treatment
Product categoryCurrent or retained treatmentEffect of the 2026 filing
Legacy ListingETP listed before 1 January 2019 pays $4,000Category is deleted; product moves to the lowest otherwise applicable fee from 2027Source 1Source 2
Transfer Listing$4,000 annual feeUnchangedSource 2
New Listing$4,500 under the separate new-listing treatmentUnchangedSource 1
Standard CADV schedule$5,000-$7,000 depending on preceding Q4 volumeBecomes relevant to former legacy products that do not qualify for another categorySource 1

BZX says the legacy discount was created when the current structure was introduced and is no longer justified solely by a pre-2019 listing date. The filing is immediately effective as a fee change, although the SEC continues to accept comments and retains its statutory suspension authority. Issuers should therefore distinguish procedural effectiveness from the later 2027 billing impact.[1][3]

The commercial asymmetry is notable. An older product can lose the historic $4,000 rate, while a product transferred from a rival exchange keeps it. That preserves an explicit acquisition incentive for new transfer listings even as BZX normalises the pricing of its established inventory.[1][2]

A former legacy product that moves from $4,000 to the $7,000 low-volume tier would pay $3,000 more each year, a 75% increase. That is the largest increase within the quoted volume schedule; an issuer’s actual assessment still depends on the product’s other eligibility and preceding fourth-quarter volume.[1][2]

Follow the evidence

Sources & further reading

  1. SR-CboeBZX-2026-085: legacy ETP annual listing fee change U.S. Securities and Exchange Commission · 21 Oct 2026 · Accessed 30 Oct 2026
  2. BZX Rule 14.13 fee-schedule amendments U.S. Securities and Exchange Commission · 21 Oct 2026 · Accessed 30 Oct 2026
  3. Cboe BZX rule filings: SR-CboeBZX-2026-085 Cboe Global Markets · 8 Oct 2026 · Accessed 30 Oct 2026

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