CSA Staff Notice 21-336 and Consultation on Proposed Revisions to the Data Fee Methodology for Professional Real-Time Market Data Fees

The Canadian Securities Administrators (CSA) are publishing for comment proposed revisions to the Data Fee Methodology (DFM) set out in CSA Staff Notice 21-319 Data Fees Methodology. The Proposed Revisions reflect recommendations made by the DFM industry committee in its report published by the CSA on December 5, 2025 (DFM Report).The Proposed Revisions also include additional changes identified by the CSA based on experience applying the DFM, stakeholder feedback, and market developments since the DFM was implemented.

Closing Consultation Date: December 27, 2026

Submit your feedback

A copy of the Consultation Paper can be found on the website of the following jurisdictions:

Alberta, British Columbia, Manitoba, New Brunswick, Nova Scotia, Ontario, Québec, Saskatchewan

Questions about this proposal? Please refer to any of the following:

Ontario Securities Commission
Alina Bazavan
Market Specialist, Trading and Markets
abazavan@osc.ca

Andrew House
Trading Specialist, Trading and Markets
Ontario Securities Commission
ahouse@osc.ca

Alberta Securities Commission
Jesse Ahlan
Senior Regulatory Analyst, Market Structure
jesse.ahlan@asc.ca

British Columbia Securities Commission
Liz Coape-Arnold
Senior Legal Counsel, Legal Services
Lcoape-arnold@bcsc.bc.ca

Anton Lunyov
Legal Counsel, Legal Services
alunyov@bcsc.bc.ca

Autorité des marchés financiers
Kim Legendre
SRO Analyst, Markets and Derivatives Policy and International Affairs
kim.legendre@lautorite.qc.ca

Nova Scotia Securities Commission
Doug Harris
General Counsel, Director of Market Regulation and Policy and Secretary
doug.harris@novascotia.ca

Technical questions about submitting your comments? Click here to contact the CSA Secretariat. Or alternatively please reach out to info@acvm-csa.ca.

Consultation on Proposed Revisions to the Data Fee Methodology for Professional Real-Time Market Data Fees

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1. Please discuss any risks of making this information public.

2. Should the revised DFM include confidence intervals as part of the published calculated fee ranges? Please discuss the potential benefits and risks of doing so.

3. Is there additional information that should be published alongside calculated fee ranges? If yes, please discuss the potential benefits and risks of publishing it.

4. Should the revised DFM continue to apply the same methodology across listing markets, or should different methodological factors or parameters be considered for senior and junior listing markets? Please discuss the potential benefits and risks of such an approach, including any impact on transparency, consistency, comparability, complexity, and the treatment of marketplaces that trade securities listed on more than one type of listing market.

5. Should the revised DFM include an annual CPI adjustment to the reference points by listing market based on approximately one-half of CPI? Please discuss the potential benefits and risks of this approach, including whether it appropriately balances inflationary pressures and technology-related efficiencies.

6. Please discuss the potential benefits and risks of treating non-charging marketplaces as though they were charging, including any impact on the stability of the reference points by listing market, marketplace behaviour, competition, and RTMD fee levels.

7. Should intentional crosses be excluded from post-trade metrics? Please discuss how this would reflect marketplace contributions to price discovery and trading activity.

8. Please discuss the potential benefits and risks of including opening and closing volume and odd-lot trades in the post-trade metrics, including whether their inclusion would improve the DFM’s ability to reflect marketplace contributions to trading activity and price discovery.

9. If confidence intervals were introduced, what would be the most appropriate approach for calculating and presenting them? What benefits and risks would such an approach create for stakeholders?

10. Should the revised DFM be implemented as a new baseline rather than as a continuation of the existing DFM? Please discuss the potential benefits and risks of a new baseline implementation, including any transition or market structure considerations.

11. Does the introduction of product-specific RTMD fees constitute a form of RTMD segmentation? If so, does such segmentation raise regulatory concerns and what factors should the CSA consider in assessing those concerns?

12. What impact, if any, could product-specific RTMD feeds have on the ability of dealers, vendors, investors, and other market participants to access RTMD, including any implications for market transparency, price discovery, competition, complexity, or the integrity of access to RTMD?

13. Where a marketplace charges fees for both comprehensive Level 1 or Level 2 RTMD feeds and use of product-specific RTMD, should the fees for product-specific RTMD be assessed within the marketplace’s overall calculated fee range under the DFM rather than as standalone fees? Please discuss any benefits, risks, or implementation considerations associated with this approach.

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Consultation on Proposed Revisions to the Data Fee Methodology for Professional Real-Time Market Data Fees

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