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Friday, August 15, 2025

Data News #2025 - 6
Nasdaq Updates the Nasdaq Global Data Agreement

Markets Impacted:

  • All Markets

Agreement Update:

  • Nasdaq Global Data Agreement (GDA)

Contact Information:

References:

What you need to know:

• Nasdaq is restructuring the Global Data Agreement to enhance clarity and usability for you.

• Nasdaq has also enhanced the Affiliate ordering process, enabling direct ordering and billing for affiliates.

• These changes are made in accordance with applicable regulations and align with the Nasdaq Rulebook.

• These updates apply to all Distributors and do not require recipients of Nasdaq Market Information to sign a new GDA.

• These updates do not impact any other market data agreements, including the Canada Data Agreement (“CDA”).

• The updated GDA (version 5.0) will be effective November 13, 2025.

What is changing?

Nasdaq is proposing certain amendments and clarifications to the current version of the Global Data Agreement (GDA) to simplify and streamline the agreement structure and data product ordering process. These updates will be effective 90 days following the date of this Alert. The following are the key material changes to the agreement:

GDA Format Updates

  • Nasdaq has consolidated the GDA Summary and GDA Terms and Conditions to create a unified agreement.
  • Nasdaq has restructured the order of provisions to make it easier for Distributors to locate applicable rights and obligations.
  • Nasdaq has moved all MiFID II/MiFIR specific requirements and terms to a new appendix.

Ordering Improvements

  • Nasdaq has implemented a streamlined ordering process for Nasdaq Market Information.
  • Nasdaq has improved the Affiliate ordering process allowing Affiliates to order Information and be invoiced directly from Nasdaq.
  • Nasdaq has included terms on which Distributors may access Information on a trial basis.

Simplification of Terms

  • Nasdaq has added, revised, and/or removed certain definitions to streamline the GDA and align with the current ordering process and Nasdaq Rulebook. Examples include new or modified versions of “Agreement”, “Affiliate”, “Data Feed”, “Distributor’s Data”, “European Markets”, “Information”, “Nasdaq Markets”, “Recipient””, “Redistributor”, and “Service Order” definitions.
  • Nasdaq has migrated the audit and compliance process from the GDA to a revised, streamlined Compliance Policy.
  • Nasdaq has simplified the governing law and dispute resolution clauses to mitigate costs by reducing the number of locations for dispute resolution and mandating consolidation of related proceedings.

Other Changes

  • Nasdaq has updated the definition of Affiliate(s) to align with industry standard definitions.
  • Nasdaq has enhanced the connection between Third Party Information Provider terms that may apply to Information and the GDA.

The updated GDA (version 5.0) can be accessed here. Service Orders will incorporate the terms and conditions as a hyperlink, accessible here. A summary table detailing the changes is available upon request. Please email Nasdaq Data Operations for a copy.

Why has a Data News Alert been issued?

This Data News Alert serves as notification to clients of a number of improvements to our GDA and the ordering process. Nasdaq is proposing amending the terms of the GDA in accordance with Section 22 of the current Agreement. Pursuant to the Agreement, the means of notifying Distributors may include, but not be limited to, posting on Nasdaq Trader. Except as otherwise detailed in current Agreement, use of the Services provided under the Agreement by Distributor ninety (90) days from the date of this Alert shall be deemed acceptance of the amended terms. If there are specific use cases not covered below or if you have additional questions, please reach out to your Sales Representative. We have also updated the definition of Affiliate and made it easier for Affiliates to order from and be billed directly by Nasdaq.

Does my firm need to sign a new agreement?

No. Distributors are not required to execute the updated version of the Nasdaq Global Data Agreement if a previous version has been executed.

Are there any policy updates related to these changes?

Yes. The compliance review process terms can now be found in the Compliance Policy. The material differences in the Compliance Policy include:

  • Replacing “audit” terminology with “compliance review”.
  • Clarifying Distributor’s limitations of liability for financial non-compliance based on the type of data.
  • Updating the Review Process, including addition of a review agenda as an appendix to the Policy, to detail Nasdaq’s and Distributor’s responsibilities in the process.
  • Added provisions for Post-Review Periods and Self-Reported non-compliance.

Who should I contact for additional information?

  • Refer to the Market Data Knowledge Center page on the Nasdaq Data Link website.
  • Contact Nasdaq Investment Intelligence at + 1 301 978 5307 or + 45 33 93 66.

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