Pursuant to the notification requirements set forth in the e-OSCAR Terms of Use, OLDE announces upcoming updates to both the e-OSCAR Terms of Use and the e-OSCAR API License Agreement, effective November 5, 2026.

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These updates modernize our language around automation and AI-driven tools, add new protections for Registrants going through corporate resolution processes, and bring more clarity and structure to how the API Services are governed. Nothing about your day-to-day use of e-OSCAR changes on Day 1 — but a few of these updates are worth your attention, especially if your organization uses any automated tools or bots to interact with the System.

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Below is a plain-language summary of what's changing. The full, updated documents are linked below, and we encourage you to review them in detail.

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What's Changing in the Terms of Use

• New rules for automation tools and bots. We've broadened the definition of “Registrant Automation Tool” to explicitly cover bots, intelligent agents, RPA, AI-driven agents, and similar non-human tools. Going forward, use of any such tool against the e-OSCAR System requires written authorization from OLDE in advance — a shift from the prior standard, which only required notifying OLDE before use.

  • If you're already using an automation tool you previously disclosed to OLDE, you have a 180-day grace period from the effective date of our new Terms to obtain written authorization to continue using it.

  • Use of OLDE's official API Services under our published API documentation is not affected by this change — that's still the supported, sanctioned path for automation.

  • Unauthorized automation tools may result in immediate suspension of the associated Operator ID, without advance notice.

• New protections for Registrants in resolution planning. We've added a new framework for Registrants subject to Dodd-Frank resolution planning requirements, ensuring continuity of e-OSCAR access during a resolution proceeding (so long as fees continue to be paid and the Registrant remains in compliance), along with a defined path for a resolution transferee to assume a Registrant's e-OSCAR rights and obligations.

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What's Changing in the API License Agreement

• Clearer term and termination rights. The Agreement now spells out its term explicitly, and gives Licensees the ability to terminate with 30 days' written notice (email is acceptable). We've also clarified that ending your API Agreement does not affect your underlying e-OSCAR registration under the Terms of Use.

• More detail on rate limiting and throttling. OLDE's existing right to manage API traffic has been clarified and expanded — including the ability to throttle or restrict call volume for an individual Registrant (without affecting others) if usage patterns risk harming System stability, with OLDE's determination on that point being conclusive. 

• New Monitoring and API Changes provisions. We've added explicit language confirming that OLDE monitors API usage (call volume, error rates, patterns, etc.) for security and enforcement purposes, and that OLDE may update or version the API over time — with advance notice and up to six months of backward compatibility where feasible for changes that would require you to update your integration.

• New Data Security and Compliance section. Licensees are responsible for securing their own systems, credentials, and connections, and must notify OLDE within 24 hours of any actual or suspected unauthorized access to their User ID or credentials.

• New limitation of liability. The Agreement now includes a defined cap on OLDE's liability and excludes indirect and consequential damages — bringing the API Agreement in line with standard industry practice and the underlying Terms of Use.

• Pricing tier notice. OLDE will now provide at least 30 days' advance notice ahead of any change to your API Pricing Tier resulting from an annual or interim review.

 

What You Need to Do

For most Registrants, no action is required — continued use of the e-OSCAR System or API Services on or after November 5, 2026 constitutes acceptance of the updated terms, consistent with how changes have always been communicated under Section 1.3 of the Terms of Use.

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If your organization currently uses any bots, scripts, RPA, or AI-driven tools to interact with e-OSCAR, we'd encourage you to reach out to Joel Strickland or Christy Macdonald to discuss your options.

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