Which US exchange-fee rules apply now—and which have moved to November 2027

A trading broker consulting the US Securities and Exchange Commission's public October 2025 announcement could reasonably conclude that important Regulation NMS market-structure changes were due in November 2026. The announcement said new minimum pricing increments and exchange access-fee caps had that deadline. That is no longer the operative compliance schedule for those provisions. On 11 June 2026 the SEC extended its temporary exemptive relief until the first business day of November 2027. A careful comparison of the notices reveals an equally important qualification: a different amendment requiring exchange fees and rebates to be determinable at execution was scheduled for 2 February 2026 and was not part of the later one-year extension.[1][2][6]

The distinction is more than a calendar correction. Rules 610(c), 610(d), 612 and the definition in Rule 600 address related but separate components of the equities market. One concerns how much an exchange may charge for access to protected quotations under the amended cap; another concerns whether a member can know transaction fees and rebates when an order executes; a third concerns minimum quotation increments in defined stocks. The provisions should not be bundled into a claim that every aspect of US market-pricing reform was postponed. FXBrokers.ai reconciled the successive SEC decisions and then examined an actual exchange's implementation record to establish the split.[1][2][3][5]

The delayed access-fee and tick-size amendments have a future compliance date, while the separate fee-determinability requirement already shapes exchange volume-based schedules. The relevant distinction is between the amount an exchange may charge, the increments in which specified stocks may be quoted and whether a fee or rebate can be determined when a trade executes. The provisions address related market structures but do not share one implementation timetable.[1][2][3][5][6]

How two SEC decisions produced two valid but different dates

The SEC's October 31, 2025 press release granted temporary relief for specified rules adopted under a September 2024 market-structure package. It assigned the first business day of November 2026 to amendments implementing the reduced minimum pricing increments under Rules 600 and 612 and the lower exchange access-fee caps under Rule 610(c). In the same notice, the SEC assigned the first business day of February 2026 to Rule 610(d), which requires that fees and rebates for execution of NMS-stock orders be determinable when the execution happens. Those dates were already separate in the original relief.[2]

The operative June 11, 2026 exemptive order extends relief for Rules 600(b)(89)(i)(F), 610(c) and 612 until the first business day of November 2027, which is November 1. Rule 610(d) is not included in that extension. The order itself, rather than a shorthand description of a delayed market-structure package, controls which provisions received the additional time.[6]

The fee-determinability requirement did not vanish

Rule 610(d) addresses an information problem that existed when exchange transaction fees and rebates depended on what a member would achieve by the end of the same month. If a broker's rate hinged on a future monthly volume threshold, the exact rate applicable to a trade might not be knowable when the trade occurred. That complicated comparisons between destinations and the calculation of the economic value of routing decisions. The amendment requires applicable exchange execution fees, rebates and other remuneration to be ascertainable at the point of execution, not retroactively discovered once a month's flow is complete.[2][3]

The requirement does not mean that every customer sees the broker's full trading cost in advance, because brokerage charges, spreads, market impact and instrument risk are different questions. It concerns the exchange fee or rebate applicable to a covered NMS-stock execution. Nor does it impose a universal zero-fee rule or prohibit rebates. It changes a key attribute of their calculation: whether their level is determinable at execution. An exchange may still use volume tiers so long as the relevant qualification and rate are known at the proper time.[3][5]

The Investors Exchange, or IEX, supplies an unusually clear example in an SEC-published exchange filing. In January 2026 it set out amendments to its fee schedule designed to become operative on February 2. Where eligibility for a transaction fee or rebate had depended on activity in the current month, the new approach would look to activity in the immediately preceding month. That converts an unknown future threshold into a known historical measurement when an order reaches the market. The exchange explained the design and gave concrete illustrations of the rate consequences.[3]

One illustration concerned a displayed liquidity-adding rebate tier. Under the amended arrangement, if a member's January activity met the specified qualification, the applicable February rebate could be determined before February trading began. IEX described an example of a $0.0022-per-share tier based on 30 million average daily displayed shares added, or a qualifying combination of displayed and non-displayed activity. Another example considered a lower rate when the member qualified for a different tier in the next month. These were examples of the exchange's own price schedule and volume thresholds, not a claim that $0.0022 applied to every equity transaction in the US market.[3]

The way averages are calculated matters. IEX's ADV in this context is an average daily volume of specified executed shares for a previous month, not an average price, a customer account balance or a country-wide equity trading volume. The exchange's tariff also distinguishes adding displayed liquidity, removing liquidity and other order behaviours. The principle is to determine which tier has already been earned before the next month's executions, while preserving relevant distinctions among order types. The calculation cannot be reproduced for a named member from public aggregate market volume alone.[3][5]

An October 2026 record confirms the earlier implementation structure

The timeline is not supported only by an old prospective filing. An October 2026 IEX filing, published in the Federal Register, explicitly describes its then-current transaction fees and rebates as determinable at execution and the volume-based tier qualifications as referring to the preceding month's trading or quoting activity. That later record is significant because it corroborates the continuing operation of the fee-determinability design after the SEC's June extension of other provisions. It does not amount to an audit of every member's actual invoices, but it establishes how the exchange's published rules describe the fee mechanism in the autumn of 2026.[3][5]

A broker assessing whether a venue's execution economics are competitive should distinguish the posted transaction rate from the amount ultimately borne by its customer. A rebate may accrue to the member, be shared, or form part of a separate commercial relationship; the applicable terms need examination. Fee determinability helps remove one source of uncertainty from routing economics, but it does not automatically prove that a route meets best-execution obligations for a particular order. Prices at the time, fill likelihood, size, speed and available alternatives may still dominate the customer outcome.[3][5]

The delayed price increments and access caps are separate

The September 2024 amendments sought, for specified NMS stocks, a smaller minimum pricing increment of half a cent, or $0.005, for quotations and orders meeting the relevant criteria. The package also reduced specified exchange access-fee caps for protected quotations: among the stated changes, a cap of $0.001 per share for NMS stocks priced at $1 or more, and a percentage-based cap for lower-priced stocks. These are parameters of the 2024 amendments, not a statement that the amended limits became universally mandatory on their original 2025 date. The Commission's later temporary relief is exactly why the compliance timeline must be checked.[1][2]

A half-cent quotation increment is not a guarantee of half-cent improvement for customers. Whether a security qualifies, how orders are priced and how spreads respond depend on the rule's scope, market conditions and the actual implementation. Similarly, an access-fee cap is not a cap on every economic cost of buying a share. It addresses specified exchange charges in a defined market-structure context, not taxes, retail broker commissions, market impact or an exchange's entire commercial price list. Multiplying the proposed cap by all transactions in the market would manufacture an estimated industry saving without the necessary fee schedules and execution mix.[1][2]

The trade-through rule remains a proposal, not a repealed rule

On June 11, the SEC separately proposed rescinding Rule 611, the trade-through rule, and Rule 610(e), concerning locked and crossed quotations, with related changes. The Commission's rulemaking record checked on November 12 still identifies Release 34-105655 as a proposed rule. That proposal must be kept separate from the already issued exemptive order. Its publication did not itself repeal the existing requirements.[4]

What compliance teams should actually verify

For a broker using US equity venues, the immediate task is to map each venue's current fee code and rebate schedule to the order type, member tier and calendar month, and confirm that the tariff gives a determinable outcome at execution. For a technology vendor, a correct implementation should record the earlier month’s threshold and applicable fee table for audit, rather than silently adjusting all of the month's fees to a newly reached tier. These are logical consequences of the rule and the IEX example, not assertions about how any unexamined broker currently operates.[3][5]

For the delayed provisions, preparations may continue, but the basis should be explicit: the June 2026 relief extends compliance for the specified amended Rules 600, 610(c) and 612 to the first business day of November 2027. It does not cancel the 2024 rule package entirely. Firms also need to distinguish ordinary venue access charges from rebates, and NMS-stock exchange obligations from rules that govern futures, options or retail spot FX; Regulation NMS is not a universal forex tariff code. A multi-asset brokerage may have different legal requirements for each product and legal entity.[1][2][3]

For execution and compliance teams, the useful record is a provision-by-provision calendar. The specified tick-size and amended access-fee provisions have relief until November 1, 2027. Fee determinability had a separate February 2, 2026 date, and IEX's subsequent filings describe how prior-month activity makes its tiers knowable at execution. Any later rulemaking should be incorporated against the exact provisions it changes, rather than treated as a blanket change to all exchange fees.[2][3][5][6][4]

Report an error or submit an update