Nasdaq PHLX filed SR-Phlx-2026-30 proposing a pricing change for Nasdaq-100 Index options (NDX) and Nasdaq-100 Reduced Value Index options (NDXP): replace a one-size-fits-all “taker” surcharge with a premium-tiered schedule for certain professional orders that remove liquidity.
If you trade NDX/NDXP as a retail “Customer,” you may not directly pay the Non-Customer surcharge described here. But changes in how professionals are charged can still matter indirectly by shifting quoting incentives, spreads, and displayed depth - especially in higher-premium series where the proposed tiers step up.
This article is for informational and educational purposes only. It is not financial advice.
Event date (filing / fee schedule amendment): May 12, 2026 (SR-Phlx-2026-30)
What changed (confirmed)
According to the PHLX Options 7 fee schedule (as published on Nasdaq Listing Center), the Exchange assesses a surcharge on electronic simple Non-Customer orders that remove liquidity in NDX/NDXP based on the executed option premium. The schedule is:
- Premium < $3.00: $1.00 surcharge (per contract)
- Premium ≥ $3.00 and < $10.00: $1.50
- Premium ≥ $10.00 and < $25.00: $2.00
- Premium ≥ $25.00 and < $50.00: $2.50
- Premium ≥ $50.00: $3.00
The key market-structure point is the direction of the change: as the option premium increases, the surcharge increases for this specific class of “liquidity-removing” Non-Customer activity.
Why it matters for options traders
NDX/NDXP are products where execution quality can be shaped by small structural frictions - fees, rebates, and how different participant categories are charged for taking vs. providing liquidity.
Even if you are not the one paying the Non-Customer surcharge, it can still influence:
- Quoted spreads (the prices you see)
- Displayed depth (how much size is shown at each price)
- Fill quality (especially for marketable orders during fast markets)
The effect, if any, is most likely to show up in higher-premium series where the proposed surcharges step up.
Who is (and isn’t) directly affected
PHLX fee schedules generally distinguish Priority Customers from Non-Customer participants (which can include market makers and professional/customer-like accounts classified as “Professional,” firms, broker-dealers, and other non-retail categories).
Practical takeaway: the fee impact depends on how your broker routes your order and how your account is classified by the exchange. Many self-directed traders are “Customers,” but highly active accounts can be classified differently depending on the exchange and broker setup.
Why premium-tier fees show up in index options
Index options like NDX/NDXP can trade with very high dollar premiums per contract, especially in longer-dated or deep-in-the-money series. A fee model that scales with premium is an attempt to align charges with:
- The notional value and capital tied up per contract
- The Exchange’s desire to shape liquidity-provider vs. liquidity-taker behavior
- The reality that proprietary index products often carry product-specific fee structures that differ from multiply-listed equity options
This doesn’t automatically mean “worse” or “better” execution. It means the venue is explicitly trying to adjust incentives in parts of the chain that retail traders don’t always see.
Options-market implications (interpretation, not guaranteed)
1) Spreads vs. depth can move in different directions
A surcharge aimed at “takers” can theoretically encourage more displayed quoting (more “makers”). But higher marginal costs at higher premiums can also reduce the willingness of some participants to aggressively take liquidity in those series.
So two plausible (and opposite) outcomes can both be consistent with the stated goal:
- Tighter quoted spreads in certain strikes/expirations if liquidity providers compete harder.
- Thinner depth / more fragile top-of-book in higher-premium series if takers step back or split orders.
Which one dominates is an empirical question - and it can vary by expiration, moneyness, and time of day.
2) High-premium series are the “sensitivity zone”
The proposed tiering matters most when contracts sit in premium bands where a small premium change can bump a trade into a higher surcharge bucket (for participants subject to it). That can shift:
- Where liquidity providers quote size (displayed vs. hidden)
- How professionals choose to execute (single-leg vs. complex; staged vs. swept)
- Venue preferences for certain order types
3) Retail doesn’t pay the surcharge - but can still feel it
Even if you are not charged the Non-Customer surcharge directly, the people quoting to you may price in their expected costs and risks. The most common way that shows up is not a line-item fee on your ticket - it’s the bid/ask you see and the fill quality you get when you cross it.
NDX vs. NDXP vs. QQQ: why the vehicle choice comes up
NDX and NDXP track the same index but have different settlement conventions. Many traders also consider QQQ options for Nasdaq-100 exposure.
This filing is not a reason to “pick one” - but it’s a reminder that:
- Cash-settled index options and physically-settled ETF options can have very different microstructure and cost surfaces.
- For large premiums, venue fee mechanics can become a non-trivial component of the ecosystem that shapes quotes.
Common misunderstandings to avoid
- “All traders pay these taker fees.” Not necessarily. The premium-tiered surcharge described here targets Non-Customer electronic simple orders that remove liquidity.
- “If I’m retail, I can ignore exchange fees entirely.” You might not see them directly, but they can still influence spreads and liquidity.
- “A fee change predicts direction.” It doesn’t. It’s a market-structure change; price direction depends on many other drivers.
What’s unknown (what to watch after implementation)
- Whether quoted spreads in NDX/NDXP tighten or widen in the higher-premium bands.
- Whether displayed size changes materially around premium thresholds.
- Whether execution quality shifts for common retail use cases (smaller size, limit orders, staged entries/exits).
- How brokers and liquidity providers adjust routing and quoting across venues over time.
Related OptionsTrading.Zone reading
- https://optionstrading.zone/education/cash-settled-vs-physically-settled-options-explained/ - settlement differences that often matter in NDX/QQQ comparisons.
- https://optionstrading.zone/education/implied-volatility-(iv)-in-options-trading-what-it-is-and-why-it-matters/ - why “premium” can change fast, and why fees tied to premium can be nonlinear.
- https://optionstrading.zone/education/options-trading-terminology-a-beginner-friendly-glossary/ - quick definitions (including liquidity, spreads, and order types).
Sources
- Nasdaq Listing Center - SR-Phlx-2026-30 (rule filing PDF):
https://listingcenter.nasdaq.com/assets/rulebook/phlx/filings/SR-Phlx-2026-30.pdf - Nasdaq Listing Center - PHLX Options 7 fee schedule (pricing schedule page): https://listingcenter.nasdaq.com/rulebook/phlx/rules/Phlx Options 7
https://listingcenter.nasdaq.com/rulebook/phlx/rules/Phlx%20Options%207 - Nasdaq Listing Center - SR-Phlx-2025-22 (prior NDX/NDXP “taker” surcharge filing):
https://listingcenter.nasdaq.com/assets/rulebook/phlx/filings/SR-Phlx-2025-22.pdf - Nasdaq Listing Center - SR-Phlx-2024-33 (premium-threshold surcharge filing):
https://listingcenter.nasdaq.com/assets/rulebook/phlx/filings/SR-Phlx-2024-33.pdf
Risk and disclosure
This article is for informational and educational purposes only and is not financial, investment, or trading advice. Options trading involves risk and is not suitable for all investors.
