ADR fees: the small charge most investors never notice

An ADR is not free to maintain. The depositary bank that holds the foreign shares, pays the dividends, and keeps the register charges for that work, and it collects the money from you. The amounts are small, often a few cents per ADR per year, and they are usually deducted before a dividend lands in your account. Small is not the same as irrelevant, though, especially if you hold a lot of low-priced ADRs.

The depositary service fee

The main recurring charge goes by several names: depositary services fee, custody fee, or, on many brokerage statements, "ADR pass-through fee." The SEC describes it as covering the bank's costs of holding the shares, handling registration and compliance, paying dividends, and communicating with holders.

How much it typically costs

The fee is set program by program in the deposit agreement, so there is no single rate. A few verified reference points:

• The SEC's investor bulletin gives the example of 1,000 ADRs being charged $20 to $50, which works out to two to five cents per ADR.
• Charles Schwab tells clients the average pass-through fee is one to three cents per share, with amounts and timing varying by issuer.
• Many deposit agreements cap the annual service fee at $0.05 per ADR. A September 2026 DTC notice for one JPMorgan-administered program, for instance, announced an annual fee of $0.03 per ADR.

Taken together, about one to five cents per ADR per year is a fair description of the usual range as of 2026. Some programs charge it once a year; others split it across dividend payments.

How the fee is collected

There are two routes, and which one you see depends on the ADR.

1. Netted from dividends. This is the usual method. The depositary announces a gross dividend rate and a net rate after its fee. It pays the net amount to the Depository Trust Company (DTC), which distributes it to brokers. You receive the net figure, and the fee may never appear as a separate line on your statement.
2. Billed through DTC. For ADRs that pay no dividend, or when the depositary decides to collect separately, the depositary instructs DTC to collect the fee from the brokers holding the ADR as of a fee record date. The broker then debits customer accounts. This is the charge that surprises people: a small debit labeled "ADR fee" on a stock that paid nothing.

For how the fee interacts with currency conversion and foreign withholding on a dividend, see ADR dividends and currency.

Why the fee bites on low-priced ADRs

The fee is charged per ADR, not as a percentage of what the ADR is worth. A $0.03 fee is trivial on an ADR priced at $150 and noticeable on one priced at $3.

This is also why a ratio change matters. If the depositary changes the ratio so that each ADR represents more shares, you hold fewer ADRs and pay less in per-ADR fees for the same economic exposure. See ADR ratios and pricing.

Other charges in the deposit agreement

The annual fee is not the only one. A typical deposit agreement lists:

• Issuance and cancellation fees. Charged when ADRs are created or surrendered for the underlying shares. One recent agreement on EDGAR sets each at up to $5.00 per 100 ADRs, or five cents per ADR. In its 2024 termination notice for one program, Deutsche Bank listed a cancellation fee of up to $0.05 per ADR plus a $15 cable fee. These mainly matter if you convert ADRs into ordinary shares, or when a program terminates.
• Cash distribution fees. Some agreements allow a separate per-ADR charge on each dividend, again often capped at a few cents.
• Currency conversion. The depositary converts dividends into dollars at a rate it sets. Agreements commonly disclose that the bank may earn a spread between the rate it gives holders and the rate it obtains, and that the rate is not guaranteed to be the best available. This cost is embedded in your dividend rather than listed as a fee.
• Taxes and pass-through expenses. Local taxes, registration charges, and some corporate-action costs can be passed through.

Separately, some countries tax trades in their companies' ADRs. Schwab notes that France, Italy, and Spain impose financial transaction taxes that can apply to ADR purchases. That is a government tax, not a depositary fee, but it shows up on the same statements.

Where to find a specific ADR's fee

1. The depositary bank's program page. BNY, Citi, JPMorgan (adr.com), and Deutsche Bank each maintain directories of the programs they run, with ratios, CUSIPs, and in many cases fee details and dividend history showing gross and net rates.
2. The Form F-6 and deposit agreement on EDGAR. Every ADR is registered on Form F-6. The SEC points investors to the section titled "Description of American Depositary Shares" (or Receipts) for fee terms. The deposit agreement filed as an exhibit lists the maximum charges.
3. The company's Form 20-F. Exchange-listed ADR issuers disclose fees payable by ADR holders in Item 12 of the annual report.
4. DTC notices and your broker. Depositaries announce fee collections through DTC, and your broker can tell you what was charged and when.

Putting fees in context

For most holders of exchange-listed, reasonably priced ADRs, the fee is a rounding error next to foreign withholding tax and currency swings. It deserves more attention when you hold large share counts of low-priced ADRs, or when you are choosing between an ADR and the company's ordinary shares. Our comparisons of ADRs vs. foreign ordinary shares and ADRs vs. international ETFs weigh these costs side by side.

Educational content only, not investment, tax or legal advice. The Stateside Report does not recommend buying or selling any security. Tax rules depend on your situation; confirm with a qualified tax professional. Full disclosures.