Fee regulations: 1. Revised availability of ETD P-Account fee for Disclosed Clients; 2. Uniform application of FX alternative fee

1.   Introduction

The Executive Board of Eurex Clearing AG decided with effect from 1 December 2025 to charge Disclosed Clients, who are neither Trading Participants of Eurex Deutschland nor affiliated to a Trading Participant, the A-Account fee for volume transacted in respective P-Accounts, pursuant to Number 3 of the Price List of Eurex Clearing AG, as outlined in Attachment 1.

Furthermore, from 1 December 2025, the alternative fee currency will be applied to all eligible FX Derivatives uniformly in an “all-or-none” approach. Before that date, Members could choose the alternative fee on a product-by-product basis.

In this context, the following measures will apply:

• Amendments to the Price List of Eurex Clearing AG (Price List), effective date 1 December 2025.
• Amendments to the form “Choice of Fee Currencies for FX Products”, re-submission deadline 31 October 2025.

2.   Required action

A. Availability of P-Account fee for Disclosed Clients

Disclosed Clients who wish to make use of the affiliate status are kindly requested to get in touch with their Key Account Manager and to provide the necessary documentation to prove their affiliation to a Eurex Deutschland Trading Participant so that the P-Account fee can be applied for transaction volume on their P-Accounts going forward. To benefit from the P-Account fee from start of the initiative, the documentation needs to be provided by 31 October 2025 to the Key Account Manager.

B. Uniform application of FX alternative fee

Members who wish to make use of the alternative fee currency in eligible FX Derivatives are kindly asked to fill in the form “Choice of Fee Currencies for FX Products” provided in Attachment 2 and send it to their Key Account Manager until 31 October 2025. This also applies if they have previously handed in a respective form indicating individual products they wanted to utilize for the alternative fee currency. No action is required for Members who prefer to use the standard currency.

3.   Details of the initiative

A. Revised availability of ETD P-Account fee for Disclosed Clients

Eurex traditionally differentiates ETD fees between Trading Participants and non-Trading Participants: While the former enjoy the dedicated P-Account fee (= proprietary), the latter are charged the A-Account fee (= agent).

The introduction of the “Disclosed Clients (DC)” segregation models resulted in some DCs – who are neither Trading Participants nor affiliated to a Trading Participant – being charged with P-Account fees on their P-Accounts. However, the P-Account fee was not intended to be available for non-Trading Participants.

The objective of this initiative is to discontinue the general availability of P-Account fees for Disclosed Clients. In general, Disclosed Clients not eligible for current P-Account fee levels will be charged the A-Account fee for their P/A-Account business.

The P-Account fee will remain available for Disclosed Clients that are:

• Trading Participants of Eurex Deutschland or
• Disclosed Clients affiliated to a Trading Participant of Eurex Deutschland.

Disclosed Clients who wish to make use of the affiliate status are kindly requested to get in touch with their Key Account Manager and to provide the necessary documentation to prove their affiliation to a Eurex Deutschland Trading Participant. The P-Account fee can only be applied upon the successful completion of a registration procedure of the Disclosed Client.

To benefit from the P-Account fee from start of the initiative, the documentation needs to be provided by 31 October 2025 to the Key Account Manager. The criteria for an affiliate company are defined according to §§ 15 et seq. of the German Stock Corporation Act (“Aktiengesetz”).

With C7 Release 12.0, the new fee setup will be reflected in the Fee Identification Code. To that end, a new valid value (“D – Disclosed Client”) will be introduced for the “Fee Trade Originator Qualifier” within the Fee Identification Code. 

For further information, please see the “Fee Identification Code – User Guide”. The document is available on the Eurex Clearing website  www.eurex.com/ec-en/, initiative page for C7 Release 12.0 under the following link: Support > Initiatives & Releases > C7 Releases > C7 Release 12.0 > Overview & Functionality.

The following guidance may be particularly helpful for clients who do not yet utilize the Fee Identification Code and instead rely on report-based reconciliation to determine applicable fees: 

Static data related to P-Account fee:

To support clients identifying the correct fee on a respective account, Eurex Clearing provides the following features:

• C7 GUI window “Registered Participant Overview” in the field “P Fee Eligible” or via the 
• C7 Report CA770 Account Maintenance in the field “feeTrdOrigQual”.
  o   A new value “D” for Disclosed Client will be introduced for those accounts where the affected P-/M-Account transactions are charged with an A-Account fee. 

Transaction data related to P-Account fee:

To support enhanced transparency in fee originator identification for transactions booked on P- or M-Accounts, a new valid value “DC” (Disclosed Client) has been introduced in the field “acctTypGrpX” across the following reports:

CB165 – Eurex Fee Statement
CB167 – Late Closing Fees
CB169 – LP Rebates
CB187 – Monthly Rebates Overview
CB192 – Monthly Fee Statement 
CB196 – Daily Overall Fee Summary
CB199 – Eurex BTRF Monthly Fee Summary.

This enhancement enables participants to identify cases where the transaction is booked on a P- or M- Account, but the client is subject to the A-Account fee. The new value supports clients who do not utilize the Fee Identification Code. 

Please note:

• The value “DC” in the reports listed above is represented by value “A” in report CB001 for field “acctTypGrpX”.
• Within the Report Reference Manual, the fields “acctTypGrp” and “acctTypGrpX” are sharing one combined list of valid values. Those valid values are only documented under the field “acctTypGrp”. The newly introduced valid value “DC” exclusively applies to the field “acctTypGrpX” and solely within the reports listed above.
• The combination of fields “acctTypGrpX” and “acctTyp36Grp” could be used to distinguish between the fee-relevant account and the booked account. 
• The value “DC” for field “acctTypGrpX” in the reports listed above does not indicate a new account name. 
• No changes are introduced to the FIXML messaging specifications for Party Role 38 (RootPartyID); “DC” is not a valid position account value in FIXML.

B. Uniform application of FX alternative fee

Currently and by default, Eurex calculates and charges transaction fees for FX Futures, Options on FX Futures, and Rolling Spot Futures in US dollar (USD), which serves as the standard fee currency. For eligible FX Derivatives, participants have the option to select an alternative fee currency per product, typically aligned with the product currency (e.g. GBP for EUR/GBP).

Effective 1 December 2025, Eurex Clearing will implement a uniform “all-or-none” approach to the application of alternative fee currencies per Trading Participant. This means that either the standard fee currency or the alternative fee currency will be applied per Trading Participant across all eligible FX Derivatives, rather than on a product-by-product basis.

If you wish to make use of the alternative fee currency for eligible FX Derivatives, please complete the form in Attachment 2 and submit it to your Key Account Manager by 31 October 2025.

• This applies even if you have previously submitted a form specifying individual products.
• Participants who do not submit the updated form will be charged in USD from 1 December 2025.
• No action is required if you prefer to continue using USD as the fee currency.

The alternative fee set-up is reflected in the Fee Identification Code. For further details on the current and future situation, please see the “Fee Identification Code – User Guide” mentioned above and the “Eurex Clearing C7 12.0 Release Notes”, section 2.1.2. The documents are available on the C7 Release 12.0 initiative page under the link: Support > Initiatives & Releases > C7 Releases > C7 Release 12.0 > Overview & Functionality.

To support clients identifying the correct fee currency on a respective account, Eurex Clearing provides the following features: 

• C7 GUI window “Registered Participant Overview” in the field “Alternative Fee Applicable” and via the
• C7 Report TA711 All Active/Inactive Series Report in the field “altFeeEligible” (value “Y” indicates that the alternative fee currency applies; otherwise value “N” means that the fee currency is US dollar).

C. Amendments to the legal framework of Eurex Clearing

To reflect the decision to introduce aforementioned measures in the legal framework of Eurex Clearing AG, the following provisions will be amended as outlined in Attachment 1: 

• Numbers 3, 3.2.2.1 of the Price List of Eurex Clearing AG

As of the effective date, the full version of the amended Price List will be available for download on the Eurex Clearing website under the following link:

Rules & Regs > Eurex Clearing Rules & Regulations > 3. Price List

The amendments to the legal framework of Eurex Clearing AG published by this circular are deemed accepted by each affected contractual party of Eurex Clearing AG, unless the respective contractual party objects by written notice to Eurex Clearing AG prior to the relevant effective date(s) as stipulated in this circular. In case of an objection by the respective contractual party pursuant the preceding sentence, Eurex Clearing AG is entitled to terminate the respective contract (including a Clearing Agreement, if applicable). Instead of submitting an objection, the respective contractual party may submit in writing to Eurex Clearing AG comments to any amendments of the legal framework of Eurex Clearing AG within the first 10 Business Days after the publication of the amendments. Eurex Clearing AG shall assess whether these comments prevent the published amendments from becoming effective taking into account the interests of Eurex Clearing AG and all contractual parties. 

Unless the context requires otherwise, terms used and not otherwise defined in this circular shall have the meaning ascribed to them in the Clearing Conditions or FCM Clearing Conditions of Eurex Clearing AG, as applicable.

Attachment: 

• 1 – Amended sections of the Price List of Eurex Clearing AG
• 2 – Amended form: Choice of Fee Currencies for FX Products

Further information