The CFTC, Prediction Markets and Event Contracts

Dec. 11, 2025

CFTC Staff Letter 25-47: DMO and DCR provide no-action relief from the SDR Regulations to Aristotle Exchange DCM, Inc. and Aristotle Exchange DCO, Inc. for fully-collateralized binary option and variable payout event contracts. Conditions include that no participant clears through a third-party clearing member.

Dec. 11, 2025

CFTC Staff Letter 25-45: DMO and DCR amend relief previously granted to MIAXdx, removing the prior non-intermediation condition.

CFTC Staff Letter 25-48: DMO and DCR amend relief previously granted to QCX LLC d/b/a Polymarket US (DCM) and QC Clearing LLC d/b/a Polymarket Clearing, removing the prior non-intermediation condition. CFTC staff publishes request for comment regarding potential issues related to DCOs that, either in part or in whole, provide for the clearing of derivatives to retail participants on a direct (non-intermediated) basis. CFTC Staff Letter 26-01: DMO and DCR provide no-action relief from the SDR Regulations to Bitnomial Exchange, LLC (DCM) and Bitnomial Clearinghouse, LLC (DCO) for fully-collateralized “binary and bounded swaps referencing digital assets, economic indicators, and

Dec. 11, 2025

Dec. 18, 2025

Jan. 8, 2026

financial outcomes” traded on and cleared by Bitnomial.

Feb. 4, 2026

91 Fed. Reg. 5386: CFTC withdraws proposed rulemaking on “Event Contracts” published on June 10, 2024 that, among other things, would have further specified the types of event contracts that involve “gaming” and are contrary to the public interest. CFTC Staff Letter 26-04: CFTC withdraws CFTC Staff Advisory 25-36, which warned industry participants of the risk of state regulatory action and litigation arising from the listing or facilitation of trading and clearing of sports-related event contracts. The advisory also reminded registered entities to make any necessary disclosures and adopt appropriate risk management policies to account for such risk, and noted that they should be prepared to identify such disclosures and policies to the CFTC in connection with routine registration, oversight and examination activities of the CFTC and applicable self-regulatory organizations.

Feb. 4, 2026

Feb. 17, 2026

CFTC files an amicus brief to the Ninth Circuit reaffirming its exclusive jurisdiction over prediction markets.

Feb. 25, 2026

DOE issues an advisory regarding two instances of insider trading and fraud that occurred on Kalshi in which it emphasizes its willingness to investigate and

March 2026 / Page 3

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