Four
prediction market platforms received regulatory relief from the Commodity
Futures Trading Commission (CFTC) on Thursday, freeing them from swap data
reporting obligations that typically apply to derivatives traders.
The CFTC's
Division of Market Oversight and Division of Clearing and Risk issued no-action
letters to Polymarket US, LedgerX (operating as MIAX Derivatives Exchange),
PredictIt operator Aristotle Exchange, and Gemini's newly launched Gemini Titan
platform.
The letters
exempt these registered entities from requirements to report binary option
transactions to swap data repositories, citing the limited applicability of
traditional swap reporting rules to exchange
Exchange
An exchange is known as a marketplace that supports the trading of derivatives, commodities, securities, and other financial instruments.Generally, an exchange is accessible through a digital platform or sometimes at a tangible address where investors organize to perform trading. Among the chief responsibilities of an exchange would be to uphold honest and fair-trading practices. These are instrumental in making sure that the distribution of supported security rates on that exchange are effectiv
An exchange is known as a marketplace that supports the trading of derivatives, commodities, securities, and other financial instruments.Generally, an exchange is accessible through a digital platform or sometimes at a tangible address where investors organize to perform trading. Among the chief responsibilities of an exchange would be to uphold honest and fair-trading practices. These are instrumental in making sure that the distribution of supported security rates on that exchange are effectiv
Read this Term-traded event contracts.
CFTC Requires Full Collateralization
The relief
comes with strings attached. Each platform must ensure that all event contracts
remain fully collateralized, meaning traders deposit enough funds upfront to
cover their maximum possible loss on any position. This requirement puts
prediction markets closer to exchange-traded futures than over-the-counter
swaps, which typically involve bilateral credit arrangements.
Platforms
must also publish time and sales data for all transactions promptly after
execution, including trade timestamps, contract details, quantities, and
prices. While this transparency measure falls short of real-time swap data
repository reporting, it gives market participants and regulators visibility
into trading activity.
.@CFTC Staff Issues No-Action Letters Regarding Event Contracts: https://t.co/oelx60JIap
— CFTC (@CFTC) December 11, 2025
The CFTC's
letters don't change underlying law or address whether these contracts comply
with other statutory requirements. The staff emphasized that the exemptions
apply only to specific reporting regulations and don't excuse compliance with
broader Commodity Exchange Act provisions.
Removing Intermediation
Barriers
Two of the
letters – those issued to Polymarket US and LedgerX – specifically remove
earlier restrictions that prohibited futures commission merchants from
intermediating trades. The December 11 modifications allow registered brokers
to clear event contracts on behalf of customers, expanding market access beyond
direct platform users.
The CFTC
granted these amendments after both platforms amended their operating rules to
permit FCM participation. The change brings Polymarket US and LedgerX in line
with no-action relief previously granted to other prediction market operators,
which didn't include intermediation restrictions.
The latest
reporting relief comes shortly after the CFTC
CFTC
The 1974 Commodity Exchange Act (CEA) in the United States created the Commodity Futures Trading Commission (CFTC). The Commission protects and regulates market activities against manipulation, fraud, and abuse trade practices and promotes fairness in futures contracts. The CEA also included the Sad-Johnson Agreement, which defined the authority and responsibilities for the monitoring of financial contracts between the Commodity Futures Trading Commission and the Securities and Exchange Commiss
The 1974 Commodity Exchange Act (CEA) in the United States created the Commodity Futures Trading Commission (CFTC). The Commission protects and regulates market activities against manipulation, fraud, and abuse trade practices and promotes fairness in futures contracts. The CEA also included the Sad-Johnson Agreement, which defined the authority and responsibilities for the monitoring of financial contracts between the Commodity Futures Trading Commission and the Securities and Exchange Commiss
Read this Term unveiled a new CEO-level advisory
body bringing
together major prediction markets and digital asset firms, underscoring how
event contracts and crypto infrastructure are now central to the agency’s
modernization agenda. The group included, among others, the CEO of Polymarket
and Gemini.
Industry Growth Drives
Regulatory Attention
The
regulatory accommodations arrive as prediction markets experience explosive
growth. Kalshi and Polymarket combined for roughly $7.4 billion in trading
volume during October 2025, with Kalshi
alone processing $4.4 billion in transactions. Those figures surpass
Polymarket's cumulative volume from its first four years of operation.
Gemini's
entry into the sector through its Titan platform adds another regulated
competitor to a market previously dominated by Kalshi and Polymarket. The
exchange secured CFTC approval to operate as a designated contract market
earlier this month, allowing U.S. customers to trade event contracts using
existing dollar balances.
Prediction
markets let users bet on real-world outcomes ranging from election results
to economic data releases. The contracts function as binary options, paying out
to holders of winning positions while leaving counterparties with nothing.
Why Kalshi and Robinhood
Are Not in This Round
Kalshi
currently operates under a different regulatory pathway and has previously
received its own
CFTC approvals around event contracts, while Robinhood’s core brokerage and
trading offerings fall under a mix of securities and derivatives oversight that
is separate from the swap-reporting issues addressed here.
The absence
of their names in these letters does not imply any change in their status. It
simply reflects that this batch of no-action relief was targeted at a specific
group of registered entities that approached the CFTC staff with swap data
reporting concerns for particular event-style swaps.
Despite
their classification as swaps under the Commodity Exchange Act, the platforms
argued these products share more characteristics with exchange-traded
derivatives than over-the-counter instruments.
The CFTC
noted its no-action positions mirror similar exemptions granted to other
prediction market operators since 2017. Staff retain authority to modify,
suspend or terminate the relief at their discretion.
Four
prediction market platforms received regulatory relief from the Commodity
Futures Trading Commission (CFTC) on Thursday, freeing them from swap data
reporting obligations that typically apply to derivatives traders.
The CFTC's
Division of Market Oversight and Division of Clearing and Risk issued no-action
letters to Polymarket US, LedgerX (operating as MIAX Derivatives Exchange),
PredictIt operator Aristotle Exchange, and Gemini's newly launched Gemini Titan
platform.
The letters
exempt these registered entities from requirements to report binary option
transactions to swap data repositories, citing the limited applicability of
traditional swap reporting rules to exchange
Exchange
An exchange is known as a marketplace that supports the trading of derivatives, commodities, securities, and other financial instruments.Generally, an exchange is accessible through a digital platform or sometimes at a tangible address where investors organize to perform trading. Among the chief responsibilities of an exchange would be to uphold honest and fair-trading practices. These are instrumental in making sure that the distribution of supported security rates on that exchange are effectiv
An exchange is known as a marketplace that supports the trading of derivatives, commodities, securities, and other financial instruments.Generally, an exchange is accessible through a digital platform or sometimes at a tangible address where investors organize to perform trading. Among the chief responsibilities of an exchange would be to uphold honest and fair-trading practices. These are instrumental in making sure that the distribution of supported security rates on that exchange are effectiv
Read this Term-traded event contracts.
CFTC Requires Full Collateralization
The relief
comes with strings attached. Each platform must ensure that all event contracts
remain fully collateralized, meaning traders deposit enough funds upfront to
cover their maximum possible loss on any position. This requirement puts
prediction markets closer to exchange-traded futures than over-the-counter
swaps, which typically involve bilateral credit arrangements.
Platforms
must also publish time and sales data for all transactions promptly after
execution, including trade timestamps, contract details, quantities, and
prices. While this transparency measure falls short of real-time swap data
repository reporting, it gives market participants and regulators visibility
into trading activity.
.@CFTC Staff Issues No-Action Letters Regarding Event Contracts: https://t.co/oelx60JIap
— CFTC (@CFTC) December 11, 2025
The CFTC's
letters don't change underlying law or address whether these contracts comply
with other statutory requirements. The staff emphasized that the exemptions
apply only to specific reporting regulations and don't excuse compliance with
broader Commodity Exchange Act provisions.
Removing Intermediation
Barriers
Two of the
letters – those issued to Polymarket US and LedgerX – specifically remove
earlier restrictions that prohibited futures commission merchants from
intermediating trades. The December 11 modifications allow registered brokers
to clear event contracts on behalf of customers, expanding market access beyond
direct platform users.
The CFTC
granted these amendments after both platforms amended their operating rules to
permit FCM participation. The change brings Polymarket US and LedgerX in line
with no-action relief previously granted to other prediction market operators,
which didn't include intermediation restrictions.
The latest
reporting relief comes shortly after the CFTC
CFTC
The 1974 Commodity Exchange Act (CEA) in the United States created the Commodity Futures Trading Commission (CFTC). The Commission protects and regulates market activities against manipulation, fraud, and abuse trade practices and promotes fairness in futures contracts. The CEA also included the Sad-Johnson Agreement, which defined the authority and responsibilities for the monitoring of financial contracts between the Commodity Futures Trading Commission and the Securities and Exchange Commiss
The 1974 Commodity Exchange Act (CEA) in the United States created the Commodity Futures Trading Commission (CFTC). The Commission protects and regulates market activities against manipulation, fraud, and abuse trade practices and promotes fairness in futures contracts. The CEA also included the Sad-Johnson Agreement, which defined the authority and responsibilities for the monitoring of financial contracts between the Commodity Futures Trading Commission and the Securities and Exchange Commiss
Read this Term unveiled a new CEO-level advisory
body bringing
together major prediction markets and digital asset firms, underscoring how
event contracts and crypto infrastructure are now central to the agency’s
modernization agenda. The group included, among others, the CEO of Polymarket
and Gemini.
Industry Growth Drives
Regulatory Attention
The
regulatory accommodations arrive as prediction markets experience explosive
growth. Kalshi and Polymarket combined for roughly $7.4 billion in trading
volume during October 2025, with Kalshi
alone processing $4.4 billion in transactions. Those figures surpass
Polymarket's cumulative volume from its first four years of operation.
Gemini's
entry into the sector through its Titan platform adds another regulated
competitor to a market previously dominated by Kalshi and Polymarket. The
exchange secured CFTC approval to operate as a designated contract market
earlier this month, allowing U.S. customers to trade event contracts using
existing dollar balances.
Prediction
markets let users bet on real-world outcomes ranging from election results
to economic data releases. The contracts function as binary options, paying out
to holders of winning positions while leaving counterparties with nothing.
Why Kalshi and Robinhood
Are Not in This Round
Kalshi
currently operates under a different regulatory pathway and has previously
received its own
CFTC approvals around event contracts, while Robinhood’s core brokerage and
trading offerings fall under a mix of securities and derivatives oversight that
is separate from the swap-reporting issues addressed here.
The absence
of their names in these letters does not imply any change in their status. It
simply reflects that this batch of no-action relief was targeted at a specific
group of registered entities that approached the CFTC staff with swap data
reporting concerns for particular event-style swaps.
Despite
their classification as swaps under the Commodity Exchange Act, the platforms
argued these products share more characteristics with exchange-traded
derivatives than over-the-counter instruments.
The CFTC
noted its no-action positions mirror similar exemptions granted to other
prediction market operators since 2017. Staff retain authority to modify,
suspend or terminate the relief at their discretion.