Exchange rulebooks contain the legal terms governing your market data subscriptions — but they are written for lawyers, not engineers. This navigator extracts the sections that matter most to market data managers, compliance teams, and operations professionals. Each summary links to the official source.
NYSE market data rules are primarily governed by NYSE Rule 7 (Co-location Services) and the NYSE Market Data Policy. Key rules for data professionals:
NYSE follows the CTA/CQ Plan definition of professional subscriber. A professional subscriber is any natural person who receives market data in connection with their employment in the securities, commodities, banking, financial, or investment industries. This includes: traders, portfolio managers, analysts, compliance officers, IT staff supporting trading systems.
Key implication: Professional user fees are per-seat. Each person accessing a terminal or application using NYSE data counts as one professional user unless they qualify for non-professional status.
Non-display use of NYSE data (automated trading, risk systems, algorithmic engines) requires a separate non-display license. Key requirements:
NYSE reserves the right to audit subscriber usage annually. Requirements include:
NYSE conducts audits through the CTA/CQ Plan administrator. Non-compliance can result in back-billing and termination.
Nasdaq market data rules are in Rules 7000–7059 of the Nasdaq rulebook. Key rules:
Nasdaq defines professional users under UTP Plan rules. A professional subscriber receives data for business use. Non-professional status requires the subscriber to be: a natural person, using data solely for personal investment decisions, not employed in a financial capacity, not redistributing data.
Key implication: Nasdaq charges significantly higher rates for professional users on TotalView. A single professional user accessing TotalView costs $24/month. Firms must track every person accessing Nasdaq data through their systems.
Nasdaq Rule 7015 covers non-display use — data consumed by machines rather than humans:
Enterprise licenses available when professional user counts exceed thousands — contact Nasdaq Data directly.
Nasdaq conducts market data audits through its Market Data Compliance team. Requirements:
Failure to report accurately results in back-billing at standard rates for the audit period.
Cboe market data rules span four equities exchanges (BZX, BYX, EDGA, EDGX) and four options exchanges. Key rules:
Cboe files separate SRO amendments for each of its exchanges — changes to BZX do not automatically apply to EDGX.
View Cboe US Equities RulesCboe follows the UTP Plan definition for equity data. For options data, Cboe uses its own definition aligned with OPRA plan rules. Professional status applies to anyone using data in a professional financial capacity.
Key point: Cboe charges flat fees for many of its data products rather than per-seat fees, making it more predictable for large organizations.
Cboe non-display license required for:
Annual usage declarations required. Derived data (indices, ETF calculations using Cboe data) require separate licensing agreements negotiated with Cboe Data Services.
Cboe market data compliance requirements:
Cboe conducts audits jointly across all four equities venues — one audit covers BZX, BYX, EDGA, and EDGX.
FINRA market data rules primarily govern CAT reporting, TRACE, and ADF connectivity:
CAT (Consolidated Audit Trail) is governed by the CAT NMS Plan, not FINRA rules directly, but FINRA is the Plan Processor. Key obligations for firms:
FINRA SLATE (Securities Lending and Transparency Engine) launched January 2, 2026 under Rule 10c-1a. Requirements:
FINRA petitioned SEC to delay but launch proceeded on schedule.
FINRA Alternative Display Facility (ADF) rules affect market data for firms using FINRA as their primary quotation venue. New ADF Participant ID D added to CTS and CQS March 27, 2026. TRACE data fees apply to firms accessing fixed income trade data for compliance and analytics purposes.
CME Group market data rules span CME, CBOT, NYMEX, and COMEX rulebooks. Key rules:
CME Group issues technical notices (Globex Notices) separate from formal rulebook amendments — both have compliance implications.
View CME RulebookCME MDP 3.0 (Market Data Platform 3.0) is the primary real-time data feed for all CME Group products. Key licensing requirements:
CBOT agricultural futures data (corn, wheat, soybean, livestock, dairy) has specific licensing provisions:
Firms in agricultural commodities with CME data access should review contracts annually as new products add channels.
CME Group market data audit requirements:
Contact CME Global Account Manager for connectivity and licensing questions.
ICE market data rules cover ICE Futures US (New York), ICE Futures Europe (London), and ICE Endex (Amsterdam). Key provisions:
ICE uses its own professional subscriber definition for non-equity products (futures and options). Professional status applies to firms and individuals using data for commercial purposes including trading, risk management, and pricing.
Non-professional rates generally not available for futures market data — most subscribers are commercial entities.
ICE non-display license required for:
ICE Fundamentals data (warehouse stocks, grading reports) subject to separate redistribution restrictions — contact ICE Data Services for enterprise licensing.
ICE market data compliance requirements:
ICE has expanded capacity for energy feeds following Iran war supply disruption — firms should verify feed capacity is adequate.
| Term | NYSE / CTA | Nasdaq / UTP | Cboe | CME Group | ICE |
|---|---|---|---|---|---|
| Professional User | CTA Plan: employed in securities, banking, or investment industry | UTP Plan: business use, not solely personal investment | UTP Plan (equity); OPRA-aligned (options) | Commercial entities and individuals using data for business purposes | Own definition: commercial use in trading, risk, or pricing |
| Non-Display Use | Automated, machine-readable use without real-time human viewing; separate license | Rule 7015: machine consumption; per-device fee | BZX Rule 11.22(d): algorithmic and automated system use | MDP 3.0 Policy: automated systems; license in connectivity agreement | iMpact feed automation; separate license required |
| Audit Notice Period | Annual right via CTA/CQ Plan administrator | Annual certification + monthly user counts | Annual per venue; joint audit across all four equities exchanges | Annual per connectivity agreement; quarterly MEP surcharges | Annual certification; ICE reserves right across all subscriptions |
| Termination Notice | 30–90 days written; check specific product agreement | 60 days written notice required | 30 days for most Cboe products | Per connectivity agreement; varies by product | Per product agreement; EU requirements apply for Endex |
| Derived Data | Indices, analytics, models may require additional licensing | External distribution requires license; internal indices generally permitted | Separate licensing with Cboe Data Services for indices, ETF calcs | All CME-derived products require separate license; DataMine for historical | Brent and TTF-derived products require licensing; Fundamentals restricted |
| Sub-Distributor | Required; vendor of record must be designated | Required; agreements must be filed with Nasdaq | Required for any redistribution across all Cboe venues | Required; separate agreement per connectivity arrangement | Required for all ICE data redistribution |
| Annual Attestation | Yes — Annual Usage Declaration; pro vs non-pro counts | Yes — annual cert plus monthly professional user reporting | Yes — annual declaration per Cboe exchange subscription | Yes — per connectivity agreement; MEP benchmarks reviewed | Yes — annual subscriber certification required |
| Fee Model | Per-seat display; flat or per-device non-display; annual SRO filings | Per-seat professional ($24/mo TotalView); enterprise above threshold | Primarily flat fees; predictable for large organizations | Connectivity-based; MEP surcharges; 10Gbps now required | Per-subscription; energy feeds priced by product and venue |
Exchange fees are in the official fee schedule, not the main rulebook. Search for the most recent SRO fee filing on the Federal Register — file numbers like SR-NYSE-2026-XX. The fee schedule attached to the filing is the current authoritative version.
How does the exchange define a professional user? Does your firm count individual login IDs, named users, or concurrent users? The exchange rulebook definition controls — your internal method may differ.
Search the rulebook or fee schedule for the terms non-display, automated, or machine. If your systems consume market data without a human viewing it in real-time, you likely need a non-display license.
How much notice do you need to give to cancel? What happens if you miss the renewal window? Most exchanges require 30–90 days written notice. Missing this window can lock you in for another year.
If you create any product derived from exchange data — an index, an analytics product, a pricing model — check whether you need a separate derived data license. This is a common source of audit findings.
The exchange can audit your usage. Know what records you need to keep (typically 3 years), what they can request, and what the remedies are for non-compliance.