
DSB operates on a cost recovery basis where annual user fees recover the UPI Forecast Total DSB Cost. Annual user fees are derived using a fee model calculation which comprises the variables UPI Forecast Total DSB Cost, Number of Infrequent Users, Standard Users, Search Only API Users, UAT-only Users, Power Users and Distributors (as an estimate for 2026), fixed no later than the end of the first Working Day in December each year, as per the DSB Charges Policy. The new fee-paying ‘Distributor’ user type has been introduced following feedback to the 2025 Industry Consultation to contribute to the principle of fair allocation of cost recovery across the user base.
Following user feedback in 2020, the fee model determination period is undertaken in October to better align with users’ budgetary processes.
2026 UPI Fee Model Variables
Based on the implementation of UPI mandates in eight jurisdictions, with a further two before the end of 2025, the DSB currently provides access to UPI data to more than 2,100 organisations, across 80 jurisdictions of which 80% consume the data free of charge. Fee paying user numbers reflect a small increase in all user types since the October 2024 estimated numbers, with 433 fee paying users and eight estimated Distributor Users as of 3 October 2025.
The below UPI Fee Model Variables table will be updated quarterly:
Fee Variable | Values as at 7 Oct 2025 |
UPI Forecast Total DSB Cost | €16.41m |
Number of Infrequent Users | 199 |
Number of Standard Users | 69 |
Number of Search Only API Users | 54 |
Number of Power Users | 100 |
Number of UAT Only Users | 1 |
Estimated Number of Distributor Users | 8 |
2026 UPI Forecast Total DSB Cost
Annual user fees recover the DSB overhead costs which include a 20% margin for financial sustainability, up to the value of six months of working capital. The 2026 UPI Forecast Total DSB Cost includes the UPI Build Costs for the period 2020-2023, Forecast Time-Limited Costs (amortisation of Capex, 2022-2023 Opex and Financing costs) and the Forecast Annualised Operating Expenditure.
In accordance with the DSB Charges Policy, Excess Fee Income resulting from additional contracts, as well as operating cost efficiencies, go to defraying the UPI Forecast Total DSB Cost for the contract year following the audited statutory accounts. Conversely, where the UPI Actual Total DSB Cost exceeds the UPI Forecast Total DSB Cost, creating a shortfall in cost recovery, this will be incorporated into the UPI Forecast Total DSB Cost for the year following the audited financial accounts.
The DSB’s continued focus on cost-efficiency has resulted in operating expenditure of €232K below the 2024 budget. As a result of revenue falling below the initial estimation and to avoid the potential impact of excessive year on year fluctuations, as well as ensure overall cost stability, the 2024 cost base was reprofiled by starting the amortisation of capex a year later in 2025 and by spreading the collection of the financial sustainability margin. This has resulted in an Excess Fee Income reduction of €1,467K against the 2026 UPI Forecast Total DSB Cost.
In relation to the UPI Forecast Total DSB Cost increase, the DSB committed to review the cost allocation between the UPI and OTC ISIN Services within two years of the launch of the UPI Service. The cost allocation review was undertaken in the 2025 Industry Consultation for the 2026 OTC ISIN and UPI Service Provision. As a result of stakeholder feedback, the DSB has implemented the revised cost allocation policy for shared costs effective 1 January 2026 with a split of 67% allocated to the UPI Service and 33% allocated to the OTC ISIN Service. Full details can be found in the Final Report on the annual consultation, related to the 2026 service provision.
The tables below show the breakdown of the 2026 UPI Forecast Total DSB Cost upon which the 2026 UPI annual user fees have been calculated and includes the financial sustainability margin.
Category (Recurring) | Description | Amount |
Technology & Operations | Operation of the UPI Service through the DSB platform including technical and asset class support | €9,910K |
Management | Senior management team including MD and Managed Service Provider management team | €875K |
Administration | Administrative costs and overheads such as office space, and administrative support functions | €1,940K |
External consultants | External oversight, legal, professional & communication | €372K |
Third-party data | Provision of third-party reference data | €670K |
Previous Year Operating Expenditure Adjustment | Excess Fee Income reduction based on the DSB Statutory Accounts 2024 | -€1,467K |
Total | €12,300K |
Forecast Time-Limited Costs (amortisation of Capex, 2022-2023 Opex and Financing costs):
Category (Time-Limited) | Amount |
Amortised 2022-23 Opex | €664K |
Forecast Capex Amortisation | €2,742K |
Financing Costs | €705K |
Total | €4,110K |
Amortisation Analysis
1. Capex Amortisation
DSB Build Costs / Capital Expenditure (Capex) are usually amortized over four years, starting from the year after the service/functionality goes live (i.e. 2024-2027), as approved via industry consultation.
Due to the number of users subscribing to the UPI Service being below initial estimates (in both user numbers and user types subscribed), the four year amortisation of the 2020-2023 build costs started in 2025 rather than 2024. This approach was taken to ensure a fair distribution of costs across the broadest user base and provide overall cost stability.
Build Costs are based on the known evolution of the service which is driven by industry consultation. Therefore, additional Build Costs / Capex for 2027 onwards will be provided when details are known.
2. Amortised 2022-23 Opex
The operational expenditure (Opex) incurred up to 31 December 2023 is amortized over four complete years from 2024-2027. This is to ensure a fair distribution of costs across the broadest user base, and to not disadvantage early adopters.
3. Financing Costs Amortisation Analysis
This is the cost of financing the Capex (Build Costs), initially to be repaid over four years (2024 –2027). Annualised interest represents the total interest from the start of the build phase to the date these costs are fully repaid. Like the capex amortisation, the repayment of this finance cost has been re-profiled over five years (2024-2028) to ensure overall cost stability.
Amortisation Analysis Summary
The below table provides an overview of the amortisation for the period 2026-2028:
Amortisation Analysis | Forecast 2026 | Forecast 2027 | Forecast 2028 |
Amortisation of Forecast Capex, 22-23 Opex and Financing Costs | €4,110K | €4,044K | €3,304K |
2025 UPI Fee Model Variables
As regulatory mandates are still coming into effect during the last quarter of 2024 and throughout 2025, user numbers have been estimated to allow for additional new users who will contribute to the 2025 cost recovery.
The below UPI Fee Model Variables table will be updated quarterly:
2025 UPI Forecast Total DSB Cost
Fee Variable | User numbers as at 7 Oct 2024 | User numbers as at 31 Dec 2024 | User numbers as at 31 Mar 2025 | User numbers as at 30 June 2025 |
2025 UPI Forecast Total DSB Cost | €12.00m | €12.00m | €12.00m | €12.00m |
Number of Infrequent Users | 200 | 210 | 217 | 198 |
Number of Standard Users | 64 | 73 | 74 | 73 |
Number of Search Only API Users | 53 | 54 | 55 | 53 |
Number of Power Users | 104 | 109 | 112 | 109 |
Number of UAT Only Users | 0 | 1 | 1 | 1 |
Annual user fees recover the DSB overhead costs which include a 20% margin for financial sustainability, up to the value of six months of working capital. The 2025 UPI Forecast Total DSB Cost includes the UPI Build Costs for the period 2020-2023, Forecast Time-Limited Costs (amortisation of Capex, 2022-2023 Opex and Financing costs) and the Forecast Annualised Operating Expenditure.
In accordance with the DSB Charges Policy, Excess Fee Income resulting from additional contracts, as well as operating cost efficiencies, go to defraying the UPI Forecast Total DSB Cost for the contract year following the audited statutory accounts. Conversely, where the UPI Actual Total DSB Cost exceeds the UPI Forecast Total DSB Cost, creating a shortfall in cost recovery, this will be incorporated into the UPI Forecast Total DSB Cost for the year following the audited financial accounts.
Most fees have increased by 3.5% due to inflation of 4.1% as well as the DSB Board approval of incremental activities which were supported during the annual industry consultation process and to support additional governance related activities. The annual fee values have also been impacted by the different mix in user subscriptions compared to the forecasted mix in October 2023.
The tables below show the breakdown of the 2025 UPI Forecast Total DSB Cost upon which the 2025 UPI annual user fees have been calculated and includes the 20% margin for financial sustainability.
Category (Recurring) | Description | Amount |
Technology & Operations | Operation of the UPI Service through the DSB platform including technical and asset class support | €5,746K |
Management | Senior management team including MD and Managed Service Provider management team | €522K |
Administration | Administrative costs and overheads such as office space, and administrative support functions | €1,129K |
External consultants | External oversight, legal, professional & communication | €334K |
Third-party data | Provision of third-party reference data | €599K |
Previous Year Operating Expenditure Adjustment | Excess Fee Income reduction based on the DSB Statutory Accounts from prior period (N/A given the 2023 launch of the UPI Service) | N/A |
Total | €8,329K |
Forecast Time-Limited Costs (amortisation of Capex, 2022-2023 Opex and Financing costs):
Category (Time-Limited) | Amount |
Amortised 2022-23 Opex | €666K |
Forecast Capex Amortisation | €2,719K |
Financing Costs | €287K |
Total | €3,672K |
Amortisation Analysis
1. Capex Amortisation
DSB Build Costs / Capital Expenditure (Capex) are usually amortized over four years, starting from the year after the service/functionality goes live (i.e. 2024-2027), as approved via industry consultation. Due to the number of users subscribing to the UPI Service being below initial estimates (in both user numbers and user types subscribed), the four year amortisation of 2020-2023 build costs will start in 2025 rather than 2024. This approach is being taken as the DSB has an obligation to avoid the potential impact of excessive year on year fluctuations and ensure overall cost stability.
Build Costs are funded by the DSB’s financial sustainability margin with 25% of the cost incorporated into the cost basis for the four years following build of the service/functionality. Build Costs are based on the known evolution of the service which is driven by industry consultation. Therefore, additional Build Costs / Capex for 2026 onwards will be provided when details are known.
2. Amortised 2022-23 Opex
The operational expenditure (Opex) incurred up to 31 December 2023 is amortized over four complete years from 2024-2027. This is to ensure a fair distribution of costs across the broadest user base, and to not disadvantage early adopters.
3. Financing Costs Amortisation Analysis
This is the cost of financing the Capex (Build Costs), initially to be repaid over four years (2024 –2027). Annualised interest represents the total interest from the start of the build phase to the date these costs are fully repaid. Like the capex amortisation, the repayment of this finance cost has been re-profiled over five years (2024-2028) to ensure overall cost stability.
Amortisation Analysis Summary
The below table provides an overview of the amortisation for the period 2025-2028:
Amortisation Analysis | Forecast 2025 | Forecast 2026 | Forecast 2027 | Forecast 2028 |
Amortisation of Forecast Capex, 22-23 Opex and Financing Costs | €3,672K | €4,122K | €3,597K | €3,262K |
2023-2024 UPI Fee Model Variables
Given the UPI Service launch in Production on 16 October 2023, the DSB estimated the Number of Users per User Type for the 2023 and 2024 invoicing periods based on a market sizing exercise and stakeholder outreach. Further details can be found in the UPI Fee Model Variables and Annual User Fee Update, published September 2023.
Additionally, as a result of the UPI Service launching in 2023, the actual costs that would normally have been incurred in the 2024 calendar year were spread over five quarters, resulting in the 2024 UPI Forecast Total DSB Cost representing 4/5th of the 2024 cost base.
The below annualised UPI Fee Model Variables table will be updated quarterly:
2024 UPI Forecast Total DSB Cost (1 Jan 2024 – 31 Dec 2024)
Fee Variable | Estimated user numbers as at 4 Sep 2023 | Values as at 31 Dec 2023 | Values as at 31 Mar 2024 | Values as at 30 Jun 2024 |
2024 UPI Forecast Total DSB Cost (representing 4/5th of the 2024 cost base) | €9.29m | €9.29m | €9.29m | €9.29m |
Number of Infrequent Users | 102 | 22 | 84 | 151 |
Number of Standard Users | 60 | 17 | 42 | 59 |
Number of Search Only API Users | 15 | 16 | 38 | 51 |
Number of Power Users | 120 | 53 | 87 | 103 |
Annual user fees recover the DSB overhead costs which include a 20% margin for financial sustainability. The 2023 UPI Forecast Total DSB Cost includes the UPI Build Costs for the period 2020-2023, Forecast Time-Limited Costs (amortisation of Capex, 2022-2023 Opex and Financing costs) and the recurring Forecast Annualised Operating Expenditure for 300 users.
In accordance with the DSB Charges Policy, Excess Fee Income resulting from additional contracts as well as operating cost efficiencies, go to defraying the UPI Forecast Total DSB Cost for the contract year following the audited statutory accounts. Conversely, where the UPI Actual Total DSB Cost exceeds the UPI Forecast Total DSB Cost, creating a shortfall in cost recovery, this will be incorporated into the UPI Forecast Total DSB Cost for the year following the audited financial accounts.
The tables below show the breakdown of the 2024 UPI Forecast Total DSB Cost upon which the 2023-2024 UPI annual user fees have been calculated and includes the 20% margin for financial sustainability. Two columns are provided, the first relating to the annualised billing period 1 Jan 2024 – 31 Dec 2024, and the second for the five quarter billing period 16 Oct 2023 – 31 Dec 2024 (from the date of the UPI Service launch in Production).
Recurring Forecast Annualised Operating Expenditure (Opex) for 300 users:
Category (Recurring) | Description | 1 Jan – 31 Dec 2024 | 16 Oct 2023 – 31 Dec 2024 |
Technology & Operations | Operation of the UPI Service through the DSB platform including technical and asset class support | €3,500K | €4,374K |
Management | Senior management team including MD, Managed Service Provider management team and CFO | €403K | €504K |
Administration | Administrative costs and overheads such as office space, and administrative support functions | €419K | €524K |
External consultants | External oversight, legal, professional & communication | €230K | €288K |
Third-party data | Provision of third-party reference data | €659K | €823K |
Contingency | Contingency to cover unplanned costs to support the service once rolled out | €385K | €481K |
Previous Year Operating Expenditure Adjustment | Excess Fee Income reduction based on the DSB Statutory Accounts from prior period (N/A given the 2023 launch of the UPI Service) | N/A | N/A |
Total | €5,595K | €6,993K |
Forecast Time-Limited Costs (amortisation of Capex, 2022-2023 Opex and Financing costs):
Category (Time-Limited) | 1 Jan – 31 Dec 2024 | 16 Oct 2023 – 31 Dec 2024 |
Amortised 2022-23 Opex | €694K | €867K |
Forecast Capex Amortisation | €2,350K | €2,937K |
Financing Costs | €654K | €818K |
Total | €3,698K | €4,622K |
Amortisation Analysis
1. Forecast Capex Amortisation
DSB Build Costs / Capital Expenditure (Capex) are amortized over 4 years, starting from the year after the service/functionality goes live (i.e. 2024-2027), as approved via industry consultation. On this basis, Build Costs are funded by the DSB’s financial sustainability margin with 25% of the cost incorporated into the cost basis for the four years following build of the service/functionality. Build Costs are based on the known evolution of the service which is driven by industry consultation. Therefore, Build Costs / Capex for 2024 onwards will be provided when details are known.
2. Amortised 2022-23 Opex
The operational expenditure (Opex) incurred up to 31 December 2023 is also amortized over 4 complete years from 2024-2027. This is to ensure a fair distribution of costs across the broadest user base, and to not disadvantage early adopters.
3. Financing Costs Amortisation Analysis
This is the cost of financing the Capex (Build Costs), to be repaid over 4 years (2024 –2027). Annualised interest represents the total interest from the start of the build phase to the date these costs are fully repaid (2027). The total has been split over 4 years, as per DSB amortisation policy.
Amortisation Analysis Summary
The below table provides an overview of the amortisation for the period 2023-2027:
Amortisation Analysis | Estimate 2023 16 Oct 2023 – 31 Dec 2024 | Forecast 2024 Annualised | Forecast 2025 Annualised | Forecast 2026 Annualised | Forecast 2027 Annualised |
Amortisation of Forecast Capex, 22-23 Opex and Financing Costs | €4,622K | €3,698K | €3,886K | €3,698K | €3,698K |
*The DSB is committed to maintaining the financial reserves up to the value of 6 months of operating costs. The increase in the amortisation amount in 2025 versus the annualised amount in 2024 is due to collecting the financial sustainability margin required to reach this limit. No financial sustainability margin is applied from 2026 onwards, on the assumption that no further build-up of reserves will be required.
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