CSA cuts trading fee cap on U.S. inter-listed securities to $0.0017 under final NI 23-101 amendments

The cap moved from the proposed $0.0010 to $0.0017 after pushback from BMO, TD, and others

CSA cuts trading fee cap on U.S. inter-listed securities to $0.0017 under final NI 23-101 amendments

Canadian regulators are cutting the trading fee cap on cross-border stocks from $0.0030 to $0.0017, reshaping costs for dealers and wealth firms. 

On April 23, 2026, the Canadian Securities Administrators published final amendments to National Instrument 23-101 Trading Rules, bringing down the maximum active trading fee for U.S. Inter-listed Securities - stocks that trade on both a Canadian recognized exchange and a U.S. registered national securities exchange - from CAD $0.0030 per share to CAD $0.0017. The change applies to securities priced at CAD $1.00 or more, and once in effect, every equity above that threshold will sit under the same fee cap, regardless of whether it is inter-listed or not. 

The new rules are scheduled to take effect on November 2, 2026, the same day the U.S. Securities and Exchange Commission rolls out its own Tick Size Rule and Trading Fee Rule. Those SEC rules were initially set for November 3, 2025, but litigation put them on hold. 

The CSA did not land where it started. Back in January 2025, the regulator proposed matching the SEC's cap at CAD $0.0010 per share, without adjusting for the exchange rate. That drew 10 comment letters from some of the biggest names in Canadian capital markets - BMO Capital Markets, TD Securities, Scotiabank, National Bank Financial Inc., TMX Group Limited, Nasdaq Canada, Tradelogiq Markets Inc., Virtu Financial, the Investment Industry Association of Canada, and Canadian Independent Finance and Innovation Counsel Inc. 

The feedback was far from unanimous. Five respondents backed the original $0.0010 proposal. One preferred $0.0025. Another wanted to keep the existing $0.0030 cap, though they said they could live with $0.0017 if pressed. Two called for scrapping fee caps altogether in favour of letting the market sort it out. And one argued for dropping the distinction between inter-listed and non-inter-listed securities entirely, which would effectively mean a $0.0017 cap across the board. 

A particular concern for two respondents was the prospect of order flow heading south. They cautioned that lower Canadian fee caps could push investors and traders toward U.S. venues, where marketplaces can offer higher rebates. That, they said, could lead to decreased order flow in Canada - not exactly the outcome regulators were hoping for. 

Three commenters argued that having a harmonized fee cap for all securities in Canada would reduce marketplace fee complexity, though they disagreed on the appropriate level - some supporting CAD $0.0010 for all securities, while others backed CAD $0.0017 for all securities. 

In the end, the CSA settled on $0.0017, reasoning that it still represents a meaningful reduction from $0.0030 while better reflecting the Canadian dollar equivalent of the SEC's USD $0.0010 cap - roughly CAD $0.0014 at current exchange rates. The slightly higher number also gives Canadian marketplaces more room to compete on fees without running afoul of the cap. 

The amendments tidy up a few other loose ends. Section 6.6.2, which dealt with transition periods when a security stopped being inter-listed, is gone. With a single fee cap now covering all equities above $1.00, there is no longer a need for it. The related guidance in the companion policy has also been removed. 

On the question of whether fee caps should extend to passive orders on inverted markets - where the usual maker-taker model is flipped - the CSA said no. The cap is meant for orders that participants may have to interact with under order protection rules, and nobody is forced to post a passive order on an inverted venue. 

The regulator also considered whether Canada should follow the SEC's lead in requiring that all fees and rebates be determinable at the time of execution. For now, no changes there either. The CSA noted that Canadian marketplaces run different volume discount programs than their U.S. counterparts, which means routing conflicts are less of an issue on this side of the border. 

Separately, the Canadian Investment Regulatory Organization has moved to align Canadian trading increments for certain U.S. Inter-listed Securities with the equivalent minimum pricing increment in the U.S., amending subsection 6.1(1) of the Universal Market Integrity Rules. 

The CSA has said it will keep watching how the fee cap changes play out and will revisit the numbers if needed. Any future adjustments would go through public consultation. 

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