RISKSMART INTELLIGENCE — RFL/01
Vol IV · Paper 02 · Rev. C Updated May 22, 2026 LIVE
A RiskSmart Intelligence Brief · 29 Jurisdictions

The Global Regulation of Prediction & Event Markets

$44 billion in 2025 global volume. $29.8 billion in April 2026 alone. Zero bespoke regulatory frameworks anywhere on Earth. This is the map.

GLOBAL REG MAP · v2026.05
Click any node · Drag to rotate
Accessible Uncertain Banned Nascent Unregulated
Jurisdiction Detail
United States
Uncertain
The federal-state collision. CFTC Chair Selig has signaled the most permissive federal posture in history. State attorneys general and Congress are pushing the opposite direction. 19 federal lawsuits, three Congressional bills, federal prosecutors in SDNY. The Supreme Court will likely have to resolve it.
Population
335M
Posture
Federal–State Split
→ Click a node to inspect
Executive Summary

A four-fold-per-year industry growing into a regulatory vacuum that is now filling with litigation, legislation, and federal prosecutors.

The prediction market industry crossed $44 billion in global volume in 2025 and hit $29.8 billion in April 2026 alone. The regulatory landscape is not keeping pace. It is fragmenting.

In the United States, a new CFTC chairman has signaled the most permissive federal stance in history — while 19 federal lawsuits, 38 state attorneys general, three Congressional bills, and federal prosecutors push in the opposite direction. In Europe, country-by-country bans are accumulating faster than any framework. Globally, no jurisdiction has built a bespoke prediction market regime.

The Iran strikes insider trading scandal — a $515,000 winning bet placed seventy-one minutes before the news broke — has elevated the debate from gambling-versus-derivatives to national security. And yet on March 10, CFTC Chairman Selig called prediction markets "truth machines" while Kalshi's CEO sat alongside the heads of CME, Nasdaq, and Deutsche Börse as an equal.

$44B
2025 Global Volume
$29.8B
Apr 2026 Volume
19+
Federal Lawsuits
38
State AGs Filed
3
Bills in Congress
0
Bespoke Frameworks
"Truth machines. They create accountability, transparency, and information." CFTC Chair Michael Selig · FIA Boca · March 10, 2026
The Core Question

Derivative, bet, or something altogether new?

Every lawsuit, every state rule, every Congressional bill traces back to a single classification problem. Three answers are on the table. None of them quite fit.

Derivative

Kalshi · Coinbase · CFTC · Coalition

Event contracts are binary derivatives. The Commodity Exchange Act grants the CFTC exclusive jurisdiction. A 2024 D.C. court confirmed this for election contracts. Federal preemption resolves the ambiguity.

Gambling

38 State AGs · AGA · Tribes · Courts

Sports contracts are functionally identical to wagers. States have regulated gambling since before the Constitution. Ninety percent of Kalshi's volume is sports. The label "derivative" is regulatory arbitrage.

Something New

Academics · Regulators · EU

It doesn't fit either box. Binary event contracts share features of both insurance and gaming. A bespoke framework is the analytically honest answer. None exists today, anywhere on Earth.

Twenty Months of Regulatory Action

Every consequential event from September 2024 through Kalshi's $22 billion Series F.

A real event timeline, not a particle field. Each marker is a named event positioned by date. Green is pro-market. Red is restrictive. The labels mark the five inflection points that actually moved the field.

Pro-market Restrictive Ambiguous Sep 2024 → May 2026
United States · Section 01

Two governments, one industry.

The U.S. picture is defined by a single unresolved tension. The federal government and the states disagree on what prediction markets are. Both cannot be right. The Supreme Court will likely have to say so.

1.1 — The Federal Pivot

On January 29, 2026, CFTC Chairman Michael Selig withdrew the Biden-era proposed ban on political and sports contracts, vacated a 2025 staff advisory, directed new "clear standards" rulemaking, and signaled the CFTC may intervene in state litigation. He called the prior administration's posture "a frolic into merit regulation."

1.2 — The State Revolt

Kalshi now faces nineteen federal lawsuits. Maryland ruled sports contracts "indistinguishable" from wagering. Massachusetts ordered geofencing in January. Thirty-eight states filed amicus support for the Maryland position. The legal community now openly forecasts a Supreme Court hearing within twelve to twenty-four months.

1.3 — The Congressional Front

Three bills are now in Congress. The Merkley–Klobuchar "End Prediction Market Corruption Act" would bar government officials from trading event contracts. The bipartisan Moore–Carbajal "Event Contract Enforcement Act" would force the CFTC to prohibit contracts on terrorism, assassination, war, gaming, or illegal activity. The Torres bill would bar federal employees from the same. Meanwhile, former OMB director Mick Mulvaney launched a 501(c)(4) called "Gambling Is Not Investing" pushing for state regulation. And on March 9, SDNY's Jay Clayton said publicly: "My prosecutors are looking at what laws we can use."

"My prosecutors are looking at what laws we can use." Jay Clayton · U.S. Attorney for SDNY · March 9, 2026

The Litigation Tracker

Nineteen federal lawsuits, sorted by trajectory. The 9th Circuit ruling in Blue Lake v. Kalshi is the pivotal near-term marker.

Kalshi v. CFTC
D.C. Circuit · 2024
Won
Election contracts are not "gaming." CFTC dropped its appeal in May 2025. The foundational federal precedent.
Blue Lake v. Kalshi
9th Circuit · 2025
On Appeal
Won at district court on federal preemption. The 9th Circuit appeal is the pivotal near-term ruling.
Kalshi v. Nevada
2025
Reversed
Reversed November 2025. The court held the state may enforce gaming laws against Kalshi-style contracts.
Maryland v. Kalshi
State Court · 2025
State Won
Sports event contracts ruled "indistinguishable" from wagering. Triggered 38-state amicus brief.
Massachusetts v. Kalshi
2025–2026
Injunction
Geofencing ordered. Kalshi's stay request denied. Polymarket filed a counter-suit on preemption February 10.
Polymarket v. Massachusetts
2026
Filed
Filed February 10, 2026. Claims federal preemption under the CEA. First Polymarket-led preemption suit.
Coinbase v. MI / IL / CT
2025
Pending
Three concurrent state actions. Coinbase argues the CFTC is the sole proper regulator for these contracts.
Class Actions (4+)
2025–2026
Pending
SDNY filing characterizes Kalshi as an "illegal unlicensed sports book." Investor and bettor classes both moving.
Tribal Challenges
2025–2026
Active
Multiple tribal nations asserting exclusive Class III gaming compacts preempt prediction market sports contracts.
Trajectory
A circuit split is forming. The 9th Circuit's Blue Lake ruling will likely set up Supreme Court review within twelve to twenty-four months. CFTC rulemaking is expected in Q2 2026. The race is now between federal rulemaking and federal jurisprudence — whichever resolves first sets the line.

The State Map · Enforcement Status

Click any state to inspect the regulatory posture and the active case if there is one. Red states have active enforcement or injunctions against Kalshi or Polymarket. Amber states are uncertain — gaming commissions reviewing or preliminary actions. Green states are accessible without state-level restriction. Grey states have no formal posture yet.

U.S. STATE MAP · Click to inspect
State Detail
Maryland
Maryland v. Kalshi
State Won. Maryland state court ruled sports contracts "indistinguishable" from wagering. The ruling triggered a 38-state amicus brief supporting Maryland's position. This is the strongest pro-state-power ruling in the field.
Active lawsuit / injunction Uncertain / reviewing Accessible No formal posture
Europe & Rest of World · Section 02

Death by a thousand national bans.

There is no unified European prediction market framework. There is a unified European pattern: national gaming authorities, one by one, geofencing Polymarket out of their jurisdictions.

France, Belgium, Poland, Portugal, Hungary, Romania, and Ukraine have all banned or restricted Polymarket. Germany and Spain remain accessible — for now. The MiCA grandfathering window closes in July 2026, and every crypto platform in the EU without a CASP license faces enforcement after that date. MiCA does not regulate prediction markets directly. It constrains the crypto rails they ride on, which is the same thing by another name.

Eurex is reported to be weighing entry. If that happens it would be the first major European exchange in the space, and the first jurisdictional move toward treating event contracts as derivatives rather than gambling. Watch this one.

Rest of World

No jurisdiction outside the United States has created a dedicated prediction market regime. The United Kingdom classifies event contracts under existing gambling law. Singapore, Australia, China, and South Korea have banned or restricted access. Brazil is the most-discussed expansion market, with a draft framework circulating but no firm timeline.

The Underlying Curve

Monthly volume, Sep 2024 through May 2026.

Sector-wide monthly notional, with the Kalshi/Polymarket split shown for the months that ran the records. The shape of the growth is the case.

Kalshi Polymarket Other tracked platforms USD Notional, Billions · Source: Dune Analytics / DeFi Rate

April set the sector record at $29.8 billion in combined notional volume. The week of March 2–8 set a single-week record of $5.35 billion across Kalshi and Polymarket. CME's event contracts independently hit $100 million in their first eight weeks. The Federal Reserve published a paper on February 12 finding prediction market prices forecast Fed rate moves on par with — or better than — Bloomberg consensus, the New York Fed survey, and fed funds futures. When the Federal Reserve's own research staff validates your data quality, the gambling-versus-derivatives debate is no longer the argument that matters.

Who Is Building What

The competitive landscape has transformed beyond recognition.

Yesterday at FIA Boca, Kalshi's CEO sat as an equal on a headline panel with the heads of CME, Nasdaq, Deutsche Börse, and SGX. That image is the most accurate single representation of where this industry now sits.

PartyRecent MoveDateVector
Kalshi Closed $22B Series F May 7 (Coatue-led, with Sequoia, a16z, IVP, Paradigm, Morgan Stanley). CEO Mansour on FIA Boca panel alongside CME, Nasdaq, Deutsche Börse, SGX. 200 internal investigations opened, two insider trading referrals. Mar–May Exchange
Polymarket Reportedly raising at $15B valuation. Palantir partnership for sports betting surveillance. Preemption suit filed against Massachusetts February 10. Iran strikes insider trade scandal triggered the $515K winning bet probe. Mar 2026 Exchange
Rothera Robinhood + Susquehanna + MIAX joint venture (45/45/10). Renamed from LedgerX/MIAXdx January 20. Self-certified baseball, weekly jobless claims, and core PCE contracts May 14. Target list date on or after May 20. May 14 New Venue
CME Group Event contracts crossed 100 million in eight weeks. Treating prediction markets as a recurring product line rather than an experimental sleeve. Q1 2026 Incumbent
Cboe Announced patent-pending three-outcome event contract framework. First incumbent to attempt structural innovation rather than format mimicry. Mar 9 Incumbent
Nasdaq Filed with the SEC for binary options on the Nasdaq-100. A direct positioning play against Kalshi's macro contracts. Mar 2 Incumbent
CFTC Chair Selig withdrew the Biden-era proposed ban, vacated the 2025 staff advisory, signaled potential intervention in state litigation, called prediction markets "truth machines." Jan–Mar Regulator
SDNY (Clayton) U.S. Attorney publicly stated his prosecutors are reviewing the Iran strikes scandal for chargeable conduct. The first federal prosecutorial signal. Mar 9 Enforcement
Federal Reserve Published "Kalshi and the Rise of Macro Markets" finding prediction market quality on par with or better than the NY Fed survey, Bloomberg consensus, and fed funds futures. Feb 12 Validator
Congress Three bills active: Merkley–Klobuchar (officials), Moore–Carbajal (substance ban), Torres (federal employees). Mulvaney 501(c)(4) "Gambling Is Not Investing" launched. Q1 2026 Restrictive
Marex Group Issued the first "prediction market bond" — $10M structured note paying 7% coupon if Nvidia stays #1 by market cap in a year, principal protected, sold to a Swiss client, hedged via Kalshi positions. Marex Solutions CEO Jethwa on record building a PM structured-products line. Apr 2 Structured
Susquehanna (SIG) First official market maker on Kalshi (reduced fees, elevated limits in exchange for two-sided quoting). Standing up "Information Finance" desks. Hiring PM quants in Philadelphia HQ and Dublin sports unit. Also a 45% owner of Rothera. Q1 2026 Liquidity
DRW Dedicated "Information Finance" trading desk standing up alongside SIG's. Treats event probability with the same quant rigor as HFT equity trading. Q1 2026 Liquidity
ICE Committed $2B to the prediction market sector, of which $600M went directly into Polymarket. First NYSE-parent material backing of a prediction venue. Oct 2025 Infrastructure
Goldman Sachs CEO Solomon confirmed on the latest earnings call the bank is exploring opportunities in the space. Research desk has already used Polymarket pricing as an input to model Strait of Hormuz closure odds and the second-order oil impact. Q1 2026 Exploring
Saba Capital Boaz Weinstein publicly frames event contracts as a portfolio-level hedging tool — a probability shorthand for offsetting specific outcomes and sizing into other positions with more confidence. Q1 2026 Asset Mgr
DriveWealth API partnership with Kalshi to embed event contracts inside fintech-partner brokerages alongside equities and ETFs. REST/WebSocket/FIX 4.4 — the same connectivity protocols already in use at most professional desks. Feb 2026 Distribution
Citadel / IMC / HRT Publicly confirmed they are not active in prediction markets. Cite the absence of a mechanical hedge against a spot underlying. That is now the explicit institutional divide. Apr 2026 Sitting Out
The Five Fault Lines

Where this fractures next.

Five unresolved questions sit underneath every lawsuit, every state action, every Congressional bill.

5.1

Federal preemption vs. state power

Does the Commodity Exchange Act preempt state gambling laws? Circuit courts are now splitting. The Supreme Court will likely have to resolve it. This is the single most consequential question in the field.

5.2

Sports vs. non-sports

Ninety percent of Kalshi's volume is sports. The regulatory heat is almost entirely on sports contracts. Economic and political contracts face far less opposition. A bifurcated regime is not the worst-case outcome — it may be the most likely one.

5.3

Insider trading and national security

The Iran strikes scandal changed the frame. A $515,000 winning bet placed seventy-one minutes before public news broke means prediction markets are no longer just a gambling debate. They are now discussed in the same sentence as classified-information vector risk.

5.4

The MiCA squeeze

By July 2026, every crypto platform in the EU without a CASP license faces enforcement. MiCA does not regulate prediction markets directly. It constrains their crypto infrastructure. Same outcome by another name.

5.5

The Fed's validation

On February 12, the Federal Reserve published "Kalshi and the Rise of Macro Markets" — finding that prediction markets perform on par with or better than Bloomberg consensus, NY Fed surveys, and fed funds futures. They correctly identified the most likely Fed rate outcome on the eve of every FOMC meeting since 2022. The Federal Reserve's own research staff validating prediction market data quality carries enormous weight. Every restrictive argument now has to contend with the question: if the data is this good, what exactly are we banning?

Bottom Line

The industry is growing at four-times-per-year into a framework built for neither its scale nor its ambiguity. The CFTC's January pivot is being countered by three bills, a new anti-PM lobbying group, and federal prosecutors. The Iran betting scandal has shifted the debate from gambling to national security. This is no longer about gambling versus derivatives. It is about whether prediction markets can exist without becoming a vector for profiting from classified information. That question will define 2026.

Addendum · Updated May 22, 2026

Two months on: Kalshi pulled ahead, Rothera filed, and June is the heaviest catalyst month of the year.

The March paper closed at $5.35B weekly. Two months later the picture has shifted in three structural ways: the volume race is no longer close, the third major venue is in CFTC-self-certified pre-launch, and the calendar in front of us is denser than anything we have seen in this asset class.

Monthly Volume — Sector-Wide

Dune Analytics, all tracked platforms. Kalshi and Polymarket together hold roughly 98% of sector open interest.

Jan 2026
$26.75B
All-time monthly peak
Sector record
Feb 2026
$23.24B
Kalshi: $9.93B
Polymarket: $7.94B
Mar 2026
$25.70B
Kalshi: $13.07B
Polymarket: $10.57B
Apr 2026
$29.80B
Kalshi: $14.81B (record)
Polymarket: $10.30B (−9%)
May MTD
~$22B
Kalshi on pace to top April
Polymarket likely below April

Two structural shifts since the March paper closed. First, the volume race is no longer close. Kalshi held 72% of combined notional volume in the week ending May 4, up from near parity in late February. The sports-and-Exotics mix is sustaining volume through quieter calendar windows where Polymarket's politics-heavy book softens. Polymarket's April drop was its first monthly decline in eight months. Second, the capital flowed in. Kalshi closed a $22 billion Series F on May 7 — Coatue-led with Sequoia, a16z, IVP, Paradigm, and Morgan Stanley participating. Polymarket is reportedly raising at $15 billion. Combined lifetime volume crossed $150 billion in April. Kalshi's April run-rate annualizes to roughly $178 billion; combined Kalshi+Polymarket trailing twelve-month volume sits closer to $200 billion.

Rothera: The Third Venue Files

On May 14, Robinhood and Susquehanna's joint-venture exchange — formerly LedgerX/MIAXdx, renamed Rothera on January 20 — self-certified its first three contracts with the CFTC: baseball games, weekly initial jobless claims, and the core PCE price index. The filings target a list date on or after May 20, with the full Rothera launch by June 30. Robinhood holds 45%, Susquehanna 45%, MIAX 10%.

The contract selection is deliberate. Robinhood already routes its prediction market flow primarily to Kalshi (with a smaller share to ForecastEx), and by Q1 had pushed 8.8 billion event contracts through that pipe. Rothera is the venue grab — own the exchange, own the volume and the fees. Picking jobless claims and core PCE puts the launch squarely in macro territory where Kalshi is strong but not unassailable. Baseball is the toe in the water on sports without going head-to-head against the NBA Finals or the NFL preseason.

Institutional Structuring: Wall Street Stops Watching

The story has quietly shifted from "will the institutions show up" to "which institutions, in which roles." The last sixty days produced more institutional-grade activity than the prior two years combined. Three patterns matter.

First, the structured-product wrap. On April 2, Marex Group issued what it called the first "prediction market bond" — a $10 million structured note paying a 7% coupon if Nvidia remains the world's largest company by market capitalization on the one-year anniversary, principal-protected if it isn't. The note was sold to a Swiss client, hedged via positions on Kalshi, and Marex Solutions CEO Nilesh Jethwa was on record that the firm intends to build out a prediction-market structured-product line and use exchanges like Kalshi to replicate them. The mechanics matter. Marex takes the binary outcome that retail trades on Polymarket — Nvidia stays #1 or it doesn't — and turns it into capital-protected institutional credit paper. The prediction market becomes the pricing benchmark and the hedge venue. The structured note becomes the consumable product. That is the bridge.

Second, the market-maker arrival. Susquehanna International Group became the first official market maker on Kalshi, taking reduced fees and elevated position limits in exchange for two-sided quoting obligations. The arrangement is the standard liquidity-provider template from listed derivatives, applied to event contracts for the first time. DRW stood up an "Information Finance" desk in parallel. Susquehanna is hiring prediction-market quants out of its Philadelphia headquarters and its Dublin sports-trading unit. Flow Traders, Kirin, Anti Capital, and Sfermion are expanding event-driven activity. Boaz Weinstein's Saba Capital has gone on record framing event contracts as a portfolio hedging tool — a probability shorthand that lets PMs offset specific outcomes and take larger positions elsewhere with more confidence. Citadel, IMC, and HRT confirmed they are not active in the space, citing the absence of a mechanical hedge against a spot underlying. That is now the explicit institutional divide.

Third, the infrastructure capital. Intercontinental Exchange committed $2 billion to the sector and put $600 million directly into Polymarket in October — the first time an NYSE-parent has materially backed a prediction venue. DriveWealth announced an API partnership with Kalshi in February to embed event contracts inside fintech-partner brokerages alongside equities and ETFs. Goldman Sachs CEO David Solomon confirmed the bank is exploring opportunities in the space on the most recent earnings call — Goldman's research desk has already used Polymarket pricing as an input to model the odds of an Iranian closure of the Strait of Hormuz and the second-order impact on oil. Swiss-based G-20 Advisors is hiring quantitative engineers to build probability models for event contracts on the structured-product side.

The Marex note is the cleanest expression of what comes next. A binary event contract, on its own, is not a product an institutional allocator can hold. Wrapped as a coupon-bearing, principal-protected structured note with credit risk against a regulated dealer, it is. The structuring desks are now treating prediction market prices the same way they treat any other observable input — pricing inputs to package into a sellable wrapper, hedged on the underlying exchange. Expect every major structured-products desk in Europe to be inside this space by year-end, and expect the U.S. private-bank structured-product channels to follow as the CFTC rulemaking clears.

June Catalysts

The June calendar is the densest single month of the year by event-contract relevance.

Jun 16–17

FOMC + Dot Plot

Kalshi pricing 96% no-change, 3% cut, 2% hike. Combined Kalshi+Polymarket OI on June rate decision exceeds $42M. Watch dot plot dispersion — April was the most-dissented meeting since 1992.

By Jun 30

Rothera Goes Live

Third major regulated venue opens with macro-heavy contract mix. The retail migration question gets its first read. If even a third of Robinhood's flow moves, Kalshi's volume pace decelerates noticeably in June.

Jun 3–19

NBA Finals

Game 1 June 3, Game 7 if needed June 19. Kalshi's championship contract is already the largest open interest on the platform. The single biggest sports volume event between now and the World Cup final.

Jun 11

FIFA World Cup Opens

$344.5M aggregated volume in the winner contract alone. France favored at 17.9%, Spain 16.8%, England 11.2%. This is where Polymarket can claw back ground — international tournaments are their lane.

Q2 close

CFTC Rulemaking

Selig's promised Q2 rulemaking lands or it doesn't. Either resolves the federal-vs-state collision on preemption — or hands the 9th Circuit's Blue Lake ruling the vacuum to fill.

Top Ten Contracts for Capital Markets

Filtered for what would matter to a CRO, head of risk, or trading technologist — macro signal value, capital-markets-adjacent settlement, or institutional-grade liquidity.

#ContractVenueWhy it matters
01Fed Decision · June 17Kalshi / PolyNo-change pricing at 89–96%. The Fed's own February paper validated these markets against the NY Fed survey, Bloomberg consensus, and fed funds futures. The cleanest macro signal you do not have to pay a terminal for.
02Core PCE · Monthly PrintRothera ⊕CFTC self-certified May 14, target list on or after May 20. The "Fed's favorite measure" of inflation, packaged as a binary event contract. First Robinhood/SIG/MIAX product. Settlement-grade macro print.
03Initial Jobless Claims · WeeklyRothera ⊕Self-certified alongside core PCE. Weekly cadence makes this the closest analog to a high-frequency macro indicator in event-contract form. Natural overlay against front-end rates positioning.
04CPI · Monthly Headline / CoreKalshi / PolyOne of the most liquid economic markets on either platform. Print-day pricing routinely matches or beats survey consensus on direction and magnitude.
05Fed Funds Above 3.25% / 3.50% After JuneKalshiPricing 99% and 98% respectively. Useful as a low-cost hedge expression against tail rate scenarios. Cleaner than equivalent SOFR options strikes for binary-event positioning.
06Recession in 2026KalshiThe macro-tail contract. Deep liquidity, multi-month resolution. Useful as a duration overlay signal and as a sentiment check against credit spreads and 2s10s.
07BTC > $X by Quarter-EndPolymarketBinary structure complements perpetual futures positioning — same conviction, defined risk profile, no funding-rate drift. Useful as a vol surface comparison against Deribit option skew.
08FOMC Dissent Count · June 17RobinhoodThe forward read on policy path uncertainty. April set a 1992 dissent record; June dispersion will move 2027 cut pricing. Most useful Fed-watcher contract of the cycle.
09US–Iran Peace DealPolymarketTop political market by volume on Polymarket. Geopolitical tail risk priced more cleanly than CDS or option skew on regional ETFs.
102026 House Control / Midterm Seat CountKalshiThe earliest tradeable read on the 119th Congress lame-duck dynamic and 2027 fiscal posture. Capital markets payoff sits in tax and spending legislation, not headline politics.
⊕ Note on Rothera contracts Contracts #2 and #3 are self-certified, not yet listed. CFTC publication confirms the contract subjects (core PCE price index, weekly initial jobless claims) and the on-or-after May 20 target list date. Specific terms — strike convention, tenor, settlement source language, tick size — sit in the filing rulebook appendices on the CFTC industry filings portal under Rothera Exchange and Clearing LLC. If institutional uptake matters, the SIG market-making desk is the path to the term sheet faster than the public docket.