Market StructureIntermediate

Payment for Order FlowPFOF

Payment for order flow is when a broker is paid by a market maker for sending it customers’ orders. It helps fund commission-free trading but raises conflict-of-interest questions; US brokers must disclose it in routing reports, and some jurisdictions restrict or prohibit it.

Payment for order flow is when a broker is paid by a market maker or wholesaler for sending it clients' orders. It helps fund commission-free trading but creates a conflict of interest. US brokers must disclose it, and some jurisdictions restrict or ban it.

Category
Market Structure
Reading time
3 min
Also called
Order flow payments
Updated

PFOF in plain words

Payment for order flow (PFOF) is money a broker earns for sending retail customers' orders to a wholesaler — a market maker — that takes the other side.1

European regulators see a clear conflict of interest: the broker is tempted to route to whoever pays most, rather than wherever clients get the best result.2

Rules vary: in the EU, regulators consider PFOF largely incompatible with MiFID II.2

How PFOF works

  1. You place an order

    A retail order goes to a commission-free broker.

  2. Broker routes

    The broker routes the order to a wholesaler and receives a payment for it.1

  3. Wholesaler fills

    The wholesaler takes the other side, often from inventory.

  4. Best execution applies

    In the US, these payments must never get in the way of the broker's duty of best execution.3

  5. Conflict

    Be aware of the conflict: the broker may favour whoever pays most over the best result for you.2

  6. Disclosure

    Check your broker's routing reports.

Worked examples

Example 1 — Broker revenue

4,000 a day

Hypothetical: 0.002 per share on 2,000,000 shares a day.

Example 1 — Broker revenue — calculation
Daily PFOF4,000

The broker earned a payment for sending the order to the wholesaler.1

Example 2 — Hidden cost

Net −2.00

A hypothetical client saves a 1.00 commission but fills 0.01 worse on 300 shares.

Example 2 — Hidden cost — calculation
Commission saved1.00
Price cost3.00

This is exactly the conflict regulators worry about: routing for the payment, not for the client.2

Example 3 — EU client

Restricted

A hypothetical EU broker considers PFOF.

Example 3 — EU client — calculation
Regulatory viewUnlikely compatible

In the EU, regulators consider receiving PFOF unlikely to fit with MiFID II in most cases.2

PFOF broker vs commission broker

AspectPFOF modelCommission model
Client feeOften zeroPer trade
Broker incomeWholesaler paymentsCommissions
ConflictHigherLower
RoutingOften to wholesalersOften to exchanges

Where PFOF matters

Advantages and disadvantages

Advantages

  • Funds zero-commission trading.
  • Retail orders often get small price improvement.
  • Fast fills.

Disadvantages

  • Conflict of interest.
  • Costs are less visible.
  • Restricted or banned in some jurisdictions.
  • Hard for clients to compare.

Going deeper

Read as far as you need. Each level builds on the one before it.

Definition

Beginner

PFOF means a broker is paid by a third party for sending client orders to it for execution.2

US approach

Intermediate

In the US it is allowed with disclosure, but it must not undermine best execution.3

EU approach

Advanced

European regulators take a much stricter line and see it as largely incompatible with MiFID II.2 Rules differ by jurisdiction.

Common mistakes

  1. Thinking zero commission is free

    Spread is a cost.

  2. Ignoring routing reports

    Read them.

  3. Assuming PFOF is legal everywhere

    Rules differ.

  4. Using market orders carelessly

    Prefer limit prices.

Check your understanding

Test yourself before moving on. Each answer comes with an explanation.

Q1PFOF is paid…
Q20.001 per share on 500,000 shares =

Key points to remember

  1. PFOF pays brokers for routing orders.
  2. It funds commission-free trading.
  3. It creates a conflict of interest.
  4. Best execution still applies.
  5. Rules differ by jurisdiction.

Frequently asked questions

Is PFOF legal?

In the US yes, with disclosure; some jurisdictions restrict or ban it.

Does PFOF hurt me?

Not always, but it can cost on price.

How do I check?

Read your broker's order-routing disclosures.

Further learning

Sources

This article is written in our own words. The sources below support the specific facts, rules and figures marked with a number in the text. Links open the original publisher’s page.

  1. Congressional Research Service. Payment for Order Flow (PFOF) and Broker-Dealer Regulation (opens in a new tab) Checked .
  2. ESMA. ESMA warns firms and investors about risks arising from payment for order flow (opens in a new tab) Checked .
  3. FINRA. Regulatory Notice 15-46: Guidance on Best Execution Obligations (opens in a new tab) Checked .

Educational content, not financial advice. Examples use hypothetical prices and simplified costs; actual fees, margin rules and regulations vary by broker, market and country. We are not affiliated with any publisher linked above. Last reviewed . Report an error or request a source credit.