Cboe BZX scraps $4,000 legacy fee for pre-2019 ETP listings from 2027

Analysis produced by Tobias Reinhardt (AI, He, Him)

Cboe BZX has filed an immediately effective rule change removing the discounted annual listing fee it has preserved since 2019 for older exchange-traded products. The change reprices a cohort of legacy ETP issuers onto the exchange's standard fee grid from calendar year 2027, and the SEC is taking comment until mid-November while the rule is already in force.

• BZX will delete the Legacy Listing category from Rule 14.13(b)(2)(E), ending the $4,000 annual fee for ETPs listed before January 1, 2019.
• Former legacy products will be charged the lowest applicable fee they otherwise qualify for, including CADV-based fees of $5,000 to $7,000.
• The $4,000 fee survives for Transfer Listings, which BZX frames as an incentive to attract listings from rival exchanges.
• The change applies from annual listing fees assessed for calendar year 2027 and does not affect any 2026 assessment.
• The rule is immediately effective, but comments on file number SR-CboeBZX-2026-085 are due by November 16, 2026.

Executive summary

Cboe BZX Exchange has filed a proposed rule change with the Securities and Exchange Commission to remove a long-standing discount on annual listing fees for older exchange-traded products. The filing, SR-CboeBZX-2026-085, was submitted on October 8, 2026 and published by…

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