Tuesday, June 2, 2026

Data News #2026 - 4
Nasdaq Updates the Nasdaq Global Data Agreement and related Policies

What is changing?

Nasdaq is proposing certain amendments and clarifications to the current version of the Global Data Agreement (GDA) to align with European regulations and simplify the ordering and invoicing process. These updates will be effective September 1, 2026. Terms used and not defined herein shall have the meaning set forth in the GDA. The following are the key material changes to the agreement:

European Regulations

• Nasdaq has revised the GDA’s Appendix 3 to align definitions for European Market Information to European Commission Delegated Regulation (EU) 2025/1156 of June 12, 2025 (the “RTS on RCB,” which designates regulatory technical standards and requires a reasonable commercial basis (RCB) for certain behaviors of trading venues and market trading providers), which supplements Regulation (EU) No 600/2014 (the Markets in Financial Instruments Regulation, or MiFIR), which will apply throughout the GDA and all policies to European Market Information.

Contracting Entity Restructuring

• To accommodate regulatory changes and streamline operations, going forward the Nasdaq contracting entity for the GDA will be based on the type of information being provided. Appendix 1 now details the identification of contracting entity and includes all Nasdaq Markets, including Nasdaq European Markets, that may license Market Information.
• Invoicing process has been clarified to specify that the invoice will identify the appropriate currency, and payments may be made to the applicable Nasdaq affiliate.
• Nasdaq has simplified the Agreement mechanics to continue to provide additional Market Information Products without execution of a Service Order to Distributors with an Active Agreement (as defined in the GDA), unless a Distributor expressly requests execution of a Service Order.

Simplification of Terms

• Nasdaq has clarified the classifications of data licensed under the GDA to align with the updated ordering process and Nasdaq Rulebook and added new or modified defined terms for “European Market Information,” “Information,” “Market Information,” and “Nasdaq European Market Information”.
• Nasdaq has revised certain definitions for clarity, including modified versions of “Data Feed,” “Nasdaq Markets,” “Nasdaq System,” and “Redistributor” definitions.
• Nasdaq has enhanced the termination provisions in the GDA to clarify the parties’ responsibilities with respect to Information post-termination.

Assignment and Assumption

• Effective September 1, 2026, the rights and obligations of Nasdaq, Inc. under the GDA for European Market Information shall be assigned to Nasdaq Nordic Ltd., a corporation domiciled in Finland and a wholly owned subsidiary of Nasdaq, Inc.
• Effective September 1, 2026, the rights and obligations of Nasdaq, Inc. under the GDA for all other Nasdaq Information shall be assigned to Nasdaq Information Services, LLC, a Delaware limited liability company and wholly owned subsidiary of Nasdaq, Inc.
• A Distributor’s continued use of Information following such date will constitute acceptance of the assignment pursuant to Section 26.2 of the GDA.

Other Changes

• Updated defined terms to enhance compliance with sanctions trade control laws for all parties to the GDA.

The updated GDA (version 5.1) can be accessed here. Service Orders will incorporate the terms and conditions as a hyperlink. 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 policies. Nasdaq is proposing amending the terms of the GDA in accordance with Section 26 of the current Agreement. Pursuant to the Agreement, the means of notifying Distributors may include, but not be limited to, posting on Nasdaq Trader. For avoidance of doubt, clerical updates such as section references, definitions, and reorganization of the document, are non-material changes to the Agreement. Except as otherwise detailed in current Agreement, use of the Information 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.

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. Updated policies are accessible here. Several policies will be updated to clarify terms and incorporate the above-mentioned changes, including:

• Compliance Policy
  • Notes that compliance reviews will be conducted in accordance with applicable law, including the RTS on RCB, where appropriate;
  • Removes the list of pre-review required documents, which will instead be requested in the Engagement Letter; and
  • Updates 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.
• European Markets Data Policies
  • Adopts new terminology mandated by the RTS on RCB;
  • Incorporates new Customer categories in European Data Price List; and
  • References to other applicable market data policy documents.
• Artificial Intelligence Policy
  • Reflects customer feedback on AI usage; and
  • Conforms terminology to GDA and industry standard concepts.
  • This policy clarification is effective as of its publication date.

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