The Derivatives Service Bureau postponed an immediate overhaul of its user fee structure after industry feedback, opting instead for a broader review of how costs for maintaining the global OTC derivatives identifier system should be shared. The move follows the DSB's revelation that roughly three quarters of organizations using its data currently do so free of charge. The decision raises questions over the long-term sustainability and fairness of its cost recovery model, as the organization is required to operate on a cost recovery basis while maintaining open access as a founding principle.
The conclusions are contained in the DSB's 2026 Final Report relating to its 2027 OTC ISIN, UPI and CFI service provisions, published following the annual industry consultation. Rather than introducing significant pricing changes for next year, the organization will spend the coming months conducting a discovery-led review of how firms consume, redistribute and commercialize its data before proposing a more comprehensive redesign of the user model.
75% Of Organizations Access DSB Data Without Payment
The DSB said approximately 75% of organizations currently consume DSB data without contributing to the cost of operating the service. While open access remains one of the bureau's founding principles, it is also required to operate on a cost recovery basis, prompting an ongoing debate over whether the existing fee model fairly reflects the value different users derive from the data.
Earlier proposals considered introducing a new Full File Download user category while restricting certain free data downloads. However, feedback from market participants was mixed, with respondents warning that the changes could create operational complexity, disadvantage smaller firms and have unintended consequences for distributors and technology providers. Respondents unanimously supported undertaking a broader review of the entire user model before implementing individual changes.
DSB Confirms Tiered Distributor Fee Model Development
Although broader pricing reforms have been delayed, the DSB confirmed that work will continue on redesigning fees for distributors that redistribute DSB data to downstream users.
A Distributor user type was introduced in January 2026 with flat annual fees of €20,000 for the UPI service and €15,000 for the OTC ISIN service. The latest consultation found broad support for evolving that model into a tiered structure based primarily on the number of downstream users served by each distributor.
The DSB also plans to broaden the definition of Distributor to include firms providing derived data, validation services and display functionality, while improving quarterly reporting requirements to better understand how DSB data flows through the market. The organization said additional industry engagement will take place before any tiered pricing model is finalized.
DSB Abandons Financial Penalty Proposal For Technical Improvements
The report confirms that the DSB has abandoned an earlier proposal to introduce financial penalties for firms repeatedly breaching its Acceptable Usage Policy.
Instead, respondents overwhelmingly supported a package of technical improvements aimed at reducing accidental breaches. These include clearer error messages, encouraging firms to validate data before submission and changing how certain invalid messages are counted within usage limits. Implementation is planned for 2027 at a one-off cost of €63,000, split between the UPI and OTC ISIN services.
Respondents also urged the DSB to reserve any future financial penalties for deliberate or persistent misuse rather than genuine data-quality errors.
Alternative Identifier Usage Drops 50% With €506,000 Annual Costs
The DSB revealed that use of its Alternative Identifier functionality has fallen by more than 50% year over year, with only 21 organizations actively using it during 2025 despite annual third-party data costs of roughly €506,000.
The Alternative Identifier functionality allows users to reference instruments using identifiers such as CUSIP, FIGI and SEDOL alongside ISINs. Respondents broadly agreed that the DSB should review whether those costs should continue to be shared across all UPI users or instead be borne by the relatively small group of firms that actually use the functionality.
DSB Enters Discovery-Led Review Phase For Fee Structure
The DSB said it is entering a discovery-led phase of engagement, with plans to conduct bilateral discussions with firms across different regions, business models and user types before bringing forward future proposals. The organization believes a deeper understanding of downstream workflows, redistribution models and commercial usage patterns will enable it to design a simpler and fairer cost recovery framework.
The consultation marks an important shift for the DSB. Following the successful implementation of the Unique Product Identifier and the launch of its Classification of Financial Instruments service, the organization said its focus is moving away from building new infrastructure and towards understanding how market participants use the data throughout the derivatives ecosystem.
FAQ
What did the DSB decide regarding its fee structure overhaul?
The Derivatives Service Bureau postponed an immediate overhaul of its user fee structure after industry feedback, opting instead for a broader review of how costs for maintaining the global OTC derivatives identifier system should be shared. The conclusions are contained in the DSB's 2026 Final Report relating to its 2027 OTC ISIN, UPI and CFI service provisions.
How many organizations use DSB data without paying fees?
The DSB said approximately 75% of organizations currently consume DSB data without contributing to the cost of operating the service. While open access remains one of the bureau's founding principles, it is also required to operate on a cost recovery basis.
What changes did the DSB make to distributor fees?
A Distributor user type was introduced in January 2026 with flat annual fees of €20,000 for the UPI service and €15,000 for the OTC ISIN service. The latest consultation found broad support for evolving that model into a tiered structure based primarily on the number of downstream users served by each distributor.
