RCB: Reasonable Commercial Basis

We are changing the commercial model to be compliant with the new reasonable commercial basis (RCB) legislation introduced by ESMA, effective Q3-26. 

The reasonable commercial basis regime is a new EU‑level framework introduced by ESMA under the MiFIR Review to regulate how pre‑ and post‑trade market data is priced and made available by trading venues and data providers. Its core objective is to ensure that market data is accessible, fairly priced, and non‑discriminatory, while still allowing providers to recover costs and earn a reasonable return. 

Key elements of RCB include:

• Cost‑based pricing with a reasonable margin
• Each client in one client category
• Limitations on unit of count and audit policies
• Mandatary definitions
• Euronext pricing effective 1 October 2026.

Depending on their type of usage, clients may have to: do nothing, sign a new order form or sign a new EMDA.

Clients who currently create and distribute derived data, create indices or distribute data via public display policies under the EDSA will need to sign an EMDA.

Many clients will be informed by Euronext of the licences they require. This information will be made available for the client to review in the MyMarketData portal. Clients will only need to contact Euronext if they disagree with the proposed licence set up. 

Clients to whom neither of the above scenarios apply will need to sign a new order form (note: this is a new order form, not a new agreement).

A document (name of document) has been added to the Euronext market data website detailing the changes to the EMDA and the EDSA. This can be found at: 

connect2.euronext.com/data/market-data-agreements

As detailed above, clients will need to review which category applies to their usage and take the appropriate action. In some cases, where Euronext has made the changes on behalf of the client, no action may be needed.

The new commercial model is applicable from 1 October 2026. However, as this is a significant change to how you will be charged for market data, we recommend you engage with the process as soon as possible.

Non-Display clients can:

1. start by checking the new product fee schedule and client categories;
2. determine the number of simultaneous accesses; and
3. confirm the client category/tier per product to Euronext.

Your client category depends upon the types of activity you use the data for. Below is a table summarising the types of activity, allowing you to determine at a high level which group of client categories relates to that usage. 

The client category is determined in combination with the number of non-display devices. 

See below a high-level description of non-display usage. This table can also be found in the Euronext Market Data Fee Schedule on the market data website.

Non Display

Non-Display Data Fees apply once per Market Data Client based on the Client Category applicable to the Market Data Client, per Information Product. 

Definitions used:

• Non-Display Trading Activities means the Use of Non-Display Data as part of automated calculations or algorithms that result in trading decisions. This also includes, but is not limited to, Use of Non-Display Data for high-frequency trading, automated order or quote generation, smart order routing and trading with manual intervention. It does not include the internal matching of orders.
• Trading Platform means the Use of Non-Display Data for the organisation of a market, irrespective of whether buy-side and sell-side interests are brought together on a bilateral or multilateral basis. This includes Systematic Internalisers (SIs), Multilateral Trading Facilities (MTFs), Organised Trading Facilities (OTFs) or comparable alternative trading systems, dark pools and/or crossing networks. 

Client Categories are based on the Use of Non-Display Data by the Market Data Client and are applied per Information Product. The relevant Client Categories are detailed in the below paragraphs of this Information Product Fee Schedule:

To continue to receive Milan Derivatives you must subscribe to the Euronext Group Equity and Index derivatives data product. Milan Derivatives no longer exists as a separate product.

Level 3 data is:

• The full depth of the order book with updates for each new order, modification or cancellation (market by order) of the applicable financial instrument(s) traded on the applicable market(s). 

Level 3 also includes Level 2, Level 1 and Last Price.

This differs from Level 2 data which is:

The full depth of the order book with aggregated volumes and associated number of orders by price level (market by limit) of the applicable financial instrument(s) traded on the applicable market(s).

Level 2 also includes Level 1 and Last Price.

Euronext offers the following levels of depth:

Available Information is offered at different levels of depth. These levels are described in the following table: 

Euronext will extend its information products, offering additional levels of depth for certain markets:

• Level 1 information products will be introduced to the fee schedule in addition to Last Price and Level 2 for Euronext Dublin Equities, Euronext Oslo Børs Cash and Euronext Continental Equities.
• Level 3 information products will be introduced to the fee schedule for all Euronext cash markets, apart from Euronext Warrants & Certificates.
• Level 2 will be limited to full order book information by market update
• Level 3 will include full order book information by order update (i.e. order-by-order).

Information product changes per 1 October 2026

Euronext will implement the following changes to its information products for professional subscribers:

• Euronext Equity & Index Derivatives and Euronext Milan Derivatives (Milan DER) will be combined in the fee schedule and offered under a new name, “Euronext Group Equity & Index Derivatives”, offered as Last Price and Level 2 book depth.
• TAH and GEM will be combined into one information product called “Euronext Milan Global Equity Market & Trading after Hours (Euronext Milan GEM/TAH)”.
• The professional display fees for Euronext Milan All Markets will be removed from the fee schedule. Clients are instead requested to report and pay for Euronext Milan AFF, Euronext Milan MOT, Euronext Milan GEM/TAH and Euronext Group Equity & Index Derivatives separately.
• Euronext Milan Professional Snapshot Premium will be removed from the fee schedule.
• EuroTLX All Markets, EuroTLX Shares, EuroTLX Certificates and EuroTLX Bonds will be removed from the fee schedule:
  • EuroTLX Share data and EuroTLX Certificates data will be included in Euronext Milan AFF information products.
  • EuroTLX Bonds data will be included in Euronext Milan MOT information products.
• Euronext Best of Book will continue to be offered as a separate product only and will no longer be included in Euronext Continental Cash.

Information products for retail investors

Euronext will implement the following changes to its information products for non-professional subscribers:

• Euronext Equity & Index Derivatives data and Euronext Milan Derivatives data will be split off from the current non-professional information products, and offered as a separate non-professional Euronext Group Equity & Index Derivatives information product.
• For non-professional users, EuroTLX data will be included in the Euronext Milan Cash non-professional user products.

For professional users, the EuroTLX fixed income data is now included in the Euronext Milan MOT data product. The EuroTLX equities and certificates data is now included in the Euronext Milan AFF data product.

Page views are no longer used as a unit of count. Exceptions will not be made since the commercial policies must be applied equally across all clients.