The Derivatives Service Bureau has postponed any immediate overhaul of its user fee structure after industry feedback, opting instead for a broader review of how the costs of maintaining the global OTC derivatives identifier system should be shared. The move comes despite the DSB revealing that roughly three quarters of organisations using its data currently do so free of charge, raising questions over the long-term sustainability and fairness of its cost recovery model. :contentReference[oaicite:0]{index=0}
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 organisation will spend the coming months conducting a discovery-led review of how firms consume, redistribute and commercialise its data before proposing a more comprehensive redesign of the user model. :contentReference[oaicite:1]{index=1}
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 organisation said its focus is moving away from building new infrastructure and towards understanding how market participants use the data throughout the derivatives ecosystem. :contentReference[oaicite:2]{index=2}
75% Of Users Access DSB Data For Free
One of the biggest issues identified by the consultation is the imbalance between paying and non-paying users.
The DSB said approximately 75% of organisations 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. :contentReference[oaicite:3]{index=3} :contentReference[oaicite:4]{index=4}
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. :contentReference[oaicite:5]{index=5} :contentReference[oaicite:6]{index=6}
Instead, respondents unanimously supported undertaking a broader review of the entire user model before implementing individual changes. :contentReference[oaicite:7]{index=7}
Distributor Fees Headed For Tiered Model
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. :contentReference[oaicite:8]{index=8} :contentReference[oaicite:9]{index=9}
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 organisation said additional industry engagement will take place before any tiered pricing model is finalised. :contentReference[oaicite:10]{index=10} :contentReference[oaicite:11]{index=11}
Penalty Plan Scrapped In Favour Of Technical Improvements
The report also 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. :contentReference[oaicite:12]{index=12} :contentReference[oaicite:13]{index=13} :contentReference[oaicite:14]{index=14}
Respondents also urged the DSB to reserve any future financial penalties for deliberate or persistent misuse rather than genuine data-quality errors. :contentReference[oaicite:15]{index=15}
Alternative Identifier Costs Under Review
Another notable finding concerns the DSB’s Alternative Identifier functionality, which allows users to reference instruments using identifiers such as CUSIP, FIGI and SEDOL alongside ISINs.
The DSB revealed that use of the feature has fallen by more than 50% year over year, with only 21 organisations actively using it during 2025 despite annual third-party data costs of roughly €506,000. 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. :contentReference[oaicite:16]{index=16}
Discovery-Led Approach Signals Longer-Term Reform
Perhaps the most significant outcome of this year’s consultation is procedural rather than commercial.
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 organisation 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. :contentReference[oaicite:17]{index=17} :contentReference[oaicite:18]{index=18} :contentReference[oaicite:19]{index=19}
For derivatives infrastructure providers, brokers, exchanges and market data vendors, the report suggests that no immediate pricing shock is coming in 2027. However, the DSB has made clear that broader reforms remain firmly on the agenda, particularly around distributor fees, downstream redistribution and ensuring that firms deriving commercial value from DSB data contribute proportionately to the cost of maintaining the industry’s global identifier infrastructure. :contentReference[oaicite:20]{index=20} :contentReference[oaicite:21]{index=21}