If your goal is to reduce the maximum frequency of order inserts/cancels, it makes more sense to directly charge based on frequency.
Several exchanges (the Hong Kong Stock Exchange, for one) rate-limit each connection to the exchange, charging fees based on the number of transactions per second allowed on the connection.
Several exchanges (the Hong Kong Stock Exchange, for one) rate-limit each connection to the exchange, charging fees based on the number of transactions per second allowed on the connection.