To clarify the report requirements and transitional arrangements for program trading at the Zhengzhou Commodity Exchange (“ZCE”), strengthen the oversight of program trading, regulate program trading activities, and maintain an orderly and fair futures market, the following announcement is hereby given in accordance with the Program Trading Rules of Zhengzhou Commodity Exchange (“Program Trading Rules”).
I. Program Trading Report
(I) Who Needs to Submit a Report
A trader at the ZCE who meets one or more of the following criteria is required to submit a report:
1. Placing and canceling 10 or more orders within 1 second on 10 or more occasions in a single trading day. For the purpose of this rule, accounts linked by actual control relationship are treated as a single client account;
2. Letting a computer to automatically determine all the critical elements of a trading order such as contract code, buy/sell direction, order size, and order price as well as the timing of such order;
3. Using a self-developed or customized program trading software; or
4. Any other circumstance need to report recognized by the ZCE.
(II) What Information to Report
1. Basic account information, including the trader’s name, trading code, product manager, the carrying Futures brokerage Member (“FB Member”) or overseas broker,etc.;
2. Trading and software information, including the method of trading order execution, the name, basic functions, and developer of the trading software, etc.; and
3. Any other information required by the ZCE.
A program trader shall submit the change report within thirty(30) trading days after any significant change to the previously reported information.
A program trader shall ensure the reported information is true, accurate, and complete. The FB Member or overseas broker shall verify the reported information. Upon verification with no discrepancies, the FB Member shall report to the ZCE within five (5) trading days, and the overseas broker shall report to the ZCE through its carrying FB Member within five (5) trading days. Additionally, an FB Member or overseas broker shall verify the information reported by its program trading clients semiannually or as required by the ZCE. Where a client fails to report information as required, the FB Member or overseas broker shall urge the client to make corrections. Where the client fails to make corrections after being urged, the FB Member or overseas broker shall, in accordance with the Program Trading Entrustment Agreement, refuse to accept any further orders to open positions from the client.
(III) How to Submit a Report
A program trading client shall submit the report in accordance with the requirements of the Program Trading Rules. The FB Member and overseas broker shall report the clients’ program trading information to the ZCE through CFMMC’s program trading report system in accordance with the Notice on the Launch of China Futures Market Monitoring Center’s Program Trading Report System.
A non-FB Member shall report relevant information to the ZCE through the ZCE’s member service system before engaging in program trading.
Reporting requirements for high-frequency traders will be announced by the ZCE separately.
II. Transitional Arrangements
The following arrangements apply to FB Members, overseas brokers, and traders that have been engaged in program trading activities before October 9, 2025.
1. Before April 8, 2026, a FB Member shall enter into a Program Trading Entrustment Agreement with the client to stipulate the rights and obligations of both parties and clarify the requirements for reporting, risk management, and other matters. An overseas broker accepting a client’s entrustment for program trading shall be subject to the requirements of the preceding requirements.
2. A trader shall report program trading information through the designated channels truthfully, accurately, and completely . Starting from April 9, 2026, traders who fail to report program trading through the designated channels will not be allowed to engage in program trading.
3. For high-frequency traders and clients frequently involved in abnormal behaviors such as erroneous orders, the ZCE may require its carrying FB Member to test the technical system they use for program trading. Such system shall be tested by the FB Member either directly or through a third-party testing organization.
III. Supervisory Requirements
Any program trader that violates applicable rules may be ordered to make corrections and be subject to such measures taken by the ZCE as an alert, requiring a written explanation, arranging for a regulatory meeting, and restricting the opening of new positions.Any FB Member or overseas broker that violates applicable rules may be ordered to make corrections and be subject to such measures taken by the ZCE as an alert, arranging for a regulatory meeting, issuing a written warning, and issuing a supervisory opinion letter.Any serious violation will be handled in accordance with the Rules of Zhengzhou Commodity Exchange on Violations.
Attachment: 1. Report Form for Futures Market Program Trading Clients
2.Instructions for the Report Form for Futures Market Program Trading Clients
