Contact the Nasdaq Floor Surveillance team regarding market condition exemption questions for all Nasdaq options exchanges at 215.496.5295 or email NasdaqUSoptions.Exchangeofficials@nasdaq.com.

Member firms may submit a market condition exemption request here.  

Complaints with respect to regulatory issues may be filed at regulationquestions@nasdaq.com. 

The rules relating to Nasdaq options exchanges' quoting obligations are Phlx, NOM, NTX Options, ISE, GEMX and MRX Rules Options 2, Section 5.

Contact the Nasdaq Options Review Team regarding quoting obligation questions for all Nasdaq options exchanges via email at DL-PostTradeSurv@nasdaq.com.

Nasdaq generates daily Report HQ surveillance reports as a courtesy to supplement a firm’s surveillance of its market maker compliance. Report HQ surveillance reports do not obviate the firm’s obligation to implement its own reasonably designed supervisory system to monitor for compliance.  Exceptions contained in a Report HQ surveillance report may indicate a violation.  Firms will be notified of a potential violation in formal correspondence from Nasdaq Regulation (e.g., an inquiry letter).

Many Report HQ surveillance reports generate daily regardless of whether an exception exists.  A blank spreadsheet does not necessarily mean that the Firm is complying with its market maker obligations.  A Firm must still implement its own reasonably designed supervisory system to monitor for compliance.

Contact the Post-trade Surveillance team via email at DL-PostTradeSurv@nasdaq.com.

Contact the Post-trade Surveillance team via email at DL-PostTradeSurv@nasdaq.com.

Report HQ may provide reports such as:

Specialist Opening Quote-PMM – This report identifies when an assigned Specialist fails to submit valid opening quotes within the maximum allowed time after the primary market for the underlying has opened.

Excessive Order – This report identifies when a participant is sending an extremely rapid stream of orders in an option series or group of series, either in a short period of time or over a longer period of time.

Excessive Quoting – This report identifies when a participant is sending an extremely rapid stream of quotes in an option series or group of series, either in a short period of time or over a longer period of time.

Continuous Quoting – This report identifies instances when a market maker’s quoting falls below the applicable quoting obligation.

Post Opening Quote Spread – This report includes options series in which the Market Maker quoted with a wider-than-legal quote width on a given day.

Nasdaq Member Firms should complete the Report HQ request form referenced in NasdaqTrader Options Regulatory Alert #2019-24.

The firm should first confirm that it has signed up to view surveillance reports on Report HQ, following the directions listed in Options Regulatory Alert #2019-24. Additionally, the firm should confirm that its Report HQ email subscription is active for the requested reports. Where available, the firm should use on-demand Report HQ file downloads. If the issue persists, the matter may be escalated to DL-PostTradeSurv@nasdaq.com.

Please note that Nasdaq generates daily Report HQ surveillance reports as a courtesy to supplement a firm’s surveillance of its market maker compliance. Report HQ surveillance reports do not obviate the firm’s obligation to implement its own reasonably designed supervisory system to monitor for compliance.

Beginning April 24, 2026, NTX reports include data that previously appeared as NBO. Reports can be accessed under the updated NTX name, while older reports issued before April 24, 2026, remain under the NBO name.

See the screenshot below containing the updated NTX names:

No. Nasdaq does not offer any Continuous Quoting reports beyond what is accessible on the Report HQ portal. The only Continuous Quoting data available to firms is provided through the existing reports on Report HQ.

No. Nasdaq does not provide quoting-by-symbol summary reports. The available Continuous Quoting reports are those found on the Report HQ portal.

Please note that Nasdaq generates daily Report HQ surveillance reports as a courtesy to supplement a firm’s surveillance of its market maker compliance. Report HQ surveillance reports do not obviate the firm’s obligation to implement its own reasonably designed supervisory system to monitor for compliance. In Report HQ, a firm will receive reports containing data when the firm is not meeting its Continuous Quoting obligations. Nasdaq provides blank reports for days on which the firm appears to have met its applicable continuous quoting obligations. However, receiving a blank report does not necessarily mean that the firm was in compliance on those dates. The firm must still perform its own surveillance to monitor for compliance with exchange rules.

Please see PHLX/ISE/MRX/GEMX/NOM/NTX Options 1 Section 1 for definitions of each Market Maker category.

Continuous Quoting obligations are calculated by dividing the total number of seconds the firm disseminates quotes in each assigned options series — Actual Quoting Time — by the total number of seconds each assigned options series is open for trading that day—Eligible Quoting Time.

For example, assume Firm ABC has only two Market Maker badges (i.e., Badges 1 and 2), each badge is only assigned to the same single options series; the Eligible Quoting Time in the assigned series is 100 seconds; and during this Eligible Quoting Time, Badge 1 submitted legal quotes for 60 seconds; and Badge 2 submitted legal quotes for 10 seconds that overlapped in time completely with the Badge 1 quote.  

In this example, Firm ABC’s Market Maker quoting percentage would be 60% (60/100). Since Badge 1 submitted quotes for 60 seconds, and Badge 2 submitted quotes for 10 overlapping seconds, Firm ABC’s Market Maker Actual Quoting Time would be 60 seconds. As stated above, the Eligible Quoting Time is 100 seconds. If the quotes submitted by Badge 1 and Badge 2 did not overlap, the quoting percentage would be 70% (70/100) in this example.

Please see NOM/NTX/ISE/MRX/GEMX/PHLX Options 2 Sections 4 and 5 for more details.

This answer applies to Competitive Market Makers on ISE, GEMX, and MRX; SQT/RSQTs on PHLX; and Market Makers on NOM and NTX Options.

Market Makers, associated with the same member, are collectively required to provide two-sided quotations in 60% of the cumulative number of seconds, or such higher percentage as the exchange may announce in advance, for which that member’s assigned options class is open for trading.  Market Makers are not required to make two-sided markets in any Quarterly Options Series, any Adjusted Options Series, and any options series with an expiration of nine months or greater for options on equities and exchange-traded funds or with an expiration of twelve months or greater for index options. Market Makers may choose to quote such series in addition to regular series in the options class, but such quotations will not be considered when determining whether a Market Maker has met the obligation contained in this paragraph.

Please see NOM/NTX/ISE/MRX/GEMX/PHLX Options 2 Sections 4 and 5 for more details.

This answer applies to Primary Market Makers on ISE, GEMX, and MRX and Lead Market Makers on PHLX and NTX Options.

Lead/Primary Market Makers, associated with the same member, are collectively required to provide two-sided quotations in 90% of the cumulative number of seconds, or such higher percentage as the exchange may announce in advance, for which that member's assigned options class is open for trading. Lead/Primary Market Makers on PHLX, ISE, GEMX, and MRX shall be required to make two-sided markets in any Quarterly Options Series, any Adjusted Options Series, and any option series with an expiration of nine months or greater for options on equities and ETFs or with an expiration of twelve months or greater for index options. Lead/Primary Market Makers on NTX Options shall not be required to make two-sided markets in any Quarterly Option Series, any Adjusted Option Series, and any option series with an expiration of nine months or greater for options on equities and exchange-traded funds or with an expiration of twelve months or greater for index options. However, a Lead/Primary Market Maker may still receive a participation entitlement in such series if it elects to quote in such series and otherwise satisfies the requirements of Options 3, Section 10.

Please see NTX/ISE/MRX/GEMX/PHLX Options 2 Sections 4 and 5 for more details.

Directed/Preferred Market Makers, associated with the same member, are collectively required to provide two-sided quotations in 90% of the cumulative number of seconds, or such higher percentage as the exchange may announce in advance, among all options series in which the Directed/Preferred Market Maker has executed a Directed/Preferred Order on a daily basis, except that a Directed/Preferred Market Maker shall not be required to make two-sided markets in any Quarterly Options Series, any Adjusted Options Series, and any options series with an expiration of nine months or greater for options on equities and ETFs or with an expiration of twelve months or greater for index options. A Directed/Preferred Market Maker has the ongoing quoting obligation from the time a Directed/Preferred Market Maker executes its first Directed/Preferred Order in the options series in which the Directed/Preferred Market Maker is assigned until a Directed/Preferred Market Maker notifies the exchange that the Directed/Preferred Market Maker is no longer directed.

For example, all non-directed/non-preferred Market Maker badges are aggregated for the 60% obligation. When the firm is assigned an options series as a Market Maker and receives and executes a Directed/Preferred order, the firm is directed/preferred in that options series. In this case, the 60% quoting obligation no longer applies in that options series. Instead, all options series in which the firm is directed/preferred will be subject to a heightened 90% quoting obligation and aggregated in the Directed/Preferred Market Maker bucket until the firm notifies the exchange that it is no longer directed/preferred. For options series where the firm has not received or executed a directed/preferred order and therefore is not directed/preferred, the firm remains subject to the 60% quoting obligation, and these options series are aggregated in the Market Maker bucket.

Quoting time for a directed/preferred symbol is measured starting at the time the Firm received and executed a directed/preferred order in that symbol, and not at the beginning of the trading day on which the Firm became preferenced in that symbol.

This applies to Preferred Competitive Market Makers on ISE, GEMX, and MRX and Directed SQT/RSQTs on PHLX.

Please note that Market Maker and directed/preferred Market Maker quoting obligations are calculated separately per Options Regulatory Alert #2021-36. Additionally, quoting obligations are calculated separately for series in which a Firm is designated a Directed SQT/RSQT or Preferred Competitive Market Maker versus a Directed Lead Market Maker or Preferred Primary Market Maker.

Please see ISE/MRX/GEMX/PHLX Options 2 Section 5 for more details.

Directed/Preferred Lead/Primary Market Makers, associated with the same member, are collectively required to provide two-sided quotations in 90% of the cumulative number of seconds, or such higher percentage as the exchange may announce in advance, among all options series in which the Directed/Preferred Lead/Primary Market Maker has executed a Directed/Preferred Order on a daily basis, except that a Directed/Preferred Lead/Primary Market Maker shall be required to make two-sided markets in any Quarterly Options Series, any Adjusted Options Series, and any options series with an expiration of nine months or greater for options on equities and ETFs or with an expiration of twelve months or greater for index options. A Directed/Preferred Lead/Primary Market Maker has the ongoing quoting obligation from the time a Directed/Preferred Lead/Primary Market Maker executes its first Directed/Preferred Order in the options in which the Directed/Preferred Lead/Primary Market Maker is assigned until a Directed/Preferred Lead/Primary Market Maker notifies the exchange that the Directed/Preferred Lead/Primary Market Maker is no longer directed.

For questions about whether you received and executed a Directed/Preferred order, contact Nasdaq Market Operations at OptionsHelpdesk@Nasdaq.com. For questions about whether you opted in or out of receiving Directed/Preferred orders, or to change your prior election, contact Membership at membership@nasdaq.com.

For example, all non-directed/preferred Lead/Primary Market Maker badges are aggregated for the 90% obligation. When the Firm is assigned an options series as a Lead/Primary Market Maker and receives and executes a directed/preferred order, the firm is directed/preferred in that options series and remains subject to the 90% quoting obligation. These series will be aggregated in the Directed/Preferred Lead/Primary Market Maker bucket until the firm notifies the exchange that it is no longer directed/preferred. Where the firm has not received or executed a directed/preferred order and is therefore not directed/preferred, the firm is still held to the 90% quoting obligation, but these series are aggregated in the Lead/Primary Market Maker bucket.

Quoting time for a directed/preferred symbol is measured starting at the time the firm received and executed a directed/preferred order in that symbol, and not at the beginning of the trading day on which the firm became preferenced in that symbol.

This applies to Preferred Primary Market Makers on ISE, GEMX, and MRX and Directed Lead Market Makers on PHLX.

Please note that Lead Market Maker/Primary Market Maker and Directed Lead Market Maker/Preferred Primary Market Maker quoting obligations are calculated separately per Options Regulatory Alert #2021-36. Additionally, quoting obligations are calculated separately for symbols in which a Firm is designated a  Directed SQT/RSQT or Preferred Competitive Market Maker versus a Directed Lead Market Maker or Preferred Primary Market Maker.

Please see ISE/MRX/GEMX/PHLX Options 2 Section 5 for more details.

Continuous quoting obligations are calculated collectively at the firm level for badges within the same category (e.g., on ISE/GEMX/MRX: Competitive Market Maker (CMM), Primary Market Maker (PMM), Preferred CMM, Preferred PMM. On PHLX: SQT/RSQT, Lead Market Maker (LMM), Directed SQT/RSQT, Directed LMM. For NTX Options: Market Maker and LMM. On NOM: Market Maker).

For example, all non-directed/non-preferred Market Maker badges are aggregated for the 60% obligation, and all non-directed/non-preferred PMM or LMM badges are aggregated for the 90% obligation. When the firm is assigned an options series as a Market Maker and receives and executes a preferred order, the firm is preferred in that options series. In this case, the 60% quoting obligation no longer applies. Instead, all options series in which the firm is preferred will be subject to a heightened 90% quoting obligation and aggregated in the preferred Market Maker bucket until the firm notifies the exchange that they are no longer preferred. For options series where the firm has not received or executed a preferred order and therefore is not preferred, the firm remains subject to the 60% quoting obligation, and these options series are aggregated in the Market Maker bucket.

Similarly, when the firm is assigned an options series as a PMM and receives and executes a preferred order, the firm is preferred in that options series and remains subject to the 90% quoting obligation. These series will be aggregated in the Preferred PMM bucket until the firm notifies the exchange that they are no longer preferred. For PMM-assigned options series where the firm has not received or executed a preferred order and is therefore not preferred, the firm is still held to the 90% quoting obligation, but these series are aggregated in the PMM bucket.

For example, assume Firm ABC has only two CMM badges (i.e., Badges 1 and 2), each badge is only assigned to the same single options series; the Eligible Quoting Time in the assigned series is 100 seconds; and during this Eligible Quoting Time, Badge 1 submitted legal quotes for 40 seconds; and Badge 2 submitted legal quotes for 20 seconds that never overlapped in time with the Badge 1 quote.  

In this example, Firm ABC’s CMM quoting percentage would be 60% (60/100). Since Badge 1 submitted legal quotes for 40 seconds, and Badge 2 submitted legal quotes for 20 non-overlapping seconds, Firm ABC’s CMM quoting time would be 60 seconds. As stated above, the Eligible Quoting Time is 100 seconds.

Please note that Market Maker and Lead Market Maker quoting obligations are calculated separately per Options Regulatory Alert #2021-36. Additionally, quoting obligations are calculated separately for symbols in which a Firm is designated a Directed SQT/RSQT or Preferred Competitive Market Maker versus a Directed Lead Market Maker or Preferred Primary Market Maker.

Please see NOM/NTX/ISE/MRX/GEMX/PHLX Options 2 Sections 4 and 5 for more details.

No. The number of Market Maker badges assigned to an options series does not change the Eligible Quoting Time.

Please see NOM/NTX/ISE/MRX/GEMX/PHLX Options 2 Sections 4 and 5 for more details.

No. Each market maker category’s quoting obligations are calculated separately, as described in Options Regulatory Alert #2021-36. A badge assigned to one obligation category cannot be used to satisfy a separate obligation category.

Please see NTX/ISE/MRX/GEMX/PHLX Options 2 Sections 4 and 5 for more details.

When a firm is assigned an options series as a Market Maker and receives and executes a Preferred/Directed Order, the firm is preferred/directed in that series at that time. The 60% Market Maker obligation no longer applies to those series. Instead, the series are subject to a 90% directed/preferred obligation and are aggregated in the applicable Preferred/Directed Market Maker bucket until the firm notifies the exchange that it is no longer preferred.

 For questions about whether you received and executed a Directed/Preferred order, contact Nasdaq Market Operations at OptionsHelpdesk@Nasdaq.com. For questions about whether you opted in or out of receiving Directed/Preferred orders, or to change your prior election, contact Membership at membership@nasdaq.com.

Please see ISE/MRX/GEMX/PHLX Options 2 Section 5 for more details.

Yes. When a firm is assigned an options series as a Lead/Primary Market Maker and receives and executes a Preferred or Directed Order, those series are aggregated in the applicable Preferred/Directed Lead/Primary Market Maker bucket until the firm notifies the exchange that it is no longer preferenced or directed.

Lead/Primary Market Maker-assigned series in which the firm has not received or executed a Preferred or Directed Order remain subject to the non-directed 90% Lead/Primary Market Maker obligation and are aggregated in the Lead/Primary Market Maker bucket.

Please see ISE/MRX/GEMX/PHLX Options 2 Section 5 for more details

Symbols may be missing from a Market Maker or Lead/Primary Market Maker Continuous Quoting report if those symbols are captured under a directed/preferred obligation instead. For example, if a firm becomes directed in a symbol after receiving and executing a Directed/Preferred Order, that symbol may appear under the applicable Directed/Preferred Market Maker or Directed/Preferred Lead/Primary Market Maker category rather than the non-directed Lead/Primary Market Maker category.

Please see ISE/MRX/GEMX/PHLX Options 2 Section 5 for more details.

Yes, provided the quotes comply with applicable legal width and size requirements.

Please see NOM/NTX/ISE/MRX/GEMX/PHLX Options 2 Sections 4 and 5 for more details.

 However, in rare circumstances reports may be available later than T+1.

No. Floor Market Makers are not obligated to quote electronically in any designated percentage of series.

Please see PHLX Options 8 Section 27 for more details.

No. Intra-day adds are excluded from the Continuous Quoting calculation on the day they are added.

Please see NOM/NTX/ISE/MRX/GEMX/PHLX Options 2 Sections 4 and 5 for more details.

Yes. Nasdaq treats newly added same-day series as intra-day adds. If a series is newly listed and did not trade on the prior trading day, it is treated as an intra-day add and excluded from the Continuous Quoting report for that trading day. This can include series listed after the prior day’s close or before the current day’s open if the series first begins trading on the current day.

Please see NOM/NTX/ISE/MRX/GEMX/PHLX Options 2 Sections 4 and 5 for more details.

Please see NOM/NTX/ISE/MRX/GEMX/PHLX Options 2 Sections 4 and 5 for more details.

No. When the series is excluded for the applicable obligation category, it is excluded from both Actual Quoting Time and Eligible Quoting Time. Quoting an excluded series does not add that series back into either side of the calculation for that obligation category.

Please see NOM/NTX/ISE/MRX/GEMX/PHLX Options 2 Sections 4 and 5 for more details.

Market Makers that want to either begin receiving Preferred/Directed Orders or cease receiving Preferred/Directed Orders should contact Membership at membership@nasdaq.com.

Please review Options Regulatory Alert #2024-41 for more information.

Once the firm is assigned in an options series, the firm’s continuous quoting obligations begin when its assigned option series are open for trading.

Please see NOM/NTX/ISE/MRX/GEMX/PHLX Options 2 Sections 4 and 5 for more details.

Yes. The prior preferred/directed obligation would resume. The only way to end the firm’s preferred/directed classification is for the firm to notify the exchange that it no longer wishes to be preferred/directed.

Market Makers that want to cease receiving Preferred/Directed Orders should contact Membership at membership@nasdaq.com.

Please see ISE/MRX/GEMX/PHLX Options 2 Section 5 and Options Regulatory Alert #2024-41 for more information.

Lead Market Makers (LMMs) and Primary Market Makers (PMMs) on Phlx, ISE, GEMX and MRX must enter a Valid Width Quote in at least 90% of their assigned series no later than one minute following the dissemination of a quote or trade by the market for the underlying security. For index options, the one-minute window starts following the receipt of the opening price in the underlying index.

The remainder of the assigned series must be opened "promptly". PMMs and LMMS are required to open all of their assigned series each trading day and following any trading halts for an assigned symbol on Phlx, ISE, GEMX and MRX.

Please see PHLX/ISE/MRX/GEMX Options 3, Section 8 for more details.

Only LMMs and PMMs are obligated to submit a Valid Width Quote to open a series on Phlx, ISE, GEMX and MRX during the Opening Process.  The Valid Width Quote of a Market Maker may open an option series, however Market Makers are not obligated to submit Valid Width Quotes during an Opening Process on Phlx, ISE, GEMX and MRX.

Please see PHLX/ISE/GEMX/MRX Options 3, Section 8 for more details.

PHLX, ISE, GEMX, and MRX require quoting during the Opening Process by Lead/Primary Market Makers. NTX Options and NOM utilize an automated opening cross auction instead of this market-maker-driven opening process and do not require any market maker to quote.

Please see PHLX/ISE/GEMX/MRX Options 3, Section 8 and NTX/NOM Options 3 Section 8 for more details.

Please see the PHLX/ISE/GEMX/MRX Valid Opening Quote Differentials Tables for more details.

Quote relief is communicated through the NasdaqTrader Options Regulatory Alerts.

During the electronic opening cross, market makers are required to adhere to specific maximum bid/ask spreads that scale based on the option's premium price. A full, detailed table of these valid width quote requirements is available in Options Regulatory Alert #2026-18.