CFTC regulated prediction markets

US prediction markets — regulated landscape

CFTC-regulated DCM exchanges, DCO clearinghouses, FCM and IB intermediaries, and the front-end brands routing through them — plus the emerging SEC-regulated securities-based event contracts track. Current as of May 2026.

DCM = Exchange DCO = Clearinghouse FCM = Intermediary (holds funds) IB = Introducing Broker Front-end brand SEC-regulated alt track

Exchange and clearinghouse structure: where trading actually happens

Each platform routes through a CFTC-registered Designated Contract Market (DCM). The Derivatives Clearing Organization (DCO) clears the trades. A Futures Commission Merchant (FCM) intermediates customer access (where applicable).

KalshiEX LLC

DCM — designated 2020 · self-clears via affiliate Kalshi Klear (DCO, Aug 2024)

Kalshi Klear LLC DCO · affiliate clearinghouse

Front-ends routing through KalshiEX:

Kalshi (direct)

Webull

Robinhood

PrizePicks Predict

Coinbase Predict

Sleeper

Splash Sports

Sleeper

Moomoo

Crypto.com | Derivatives North America (CDNA)

DCM + DCO (formerly Nadex) · DCM amended Sep 2025 for margined products · full FCM/DCM/DCO stack

CDNA (in-house DCO) Same legal entity — North American Derivatives Exchange, Inc.

Foris DAX FCM LLC d/b/a OG Broker FCM · NFA registered, Sep 2025

Front-ends routing through CDNA:

Crypto.com (direct)

Underdog

Fanatics

DraftKings Predict (multi-DCM)

OG (Crypto.com subsidiary)

Robinhood (multi-DCM)

FanDuel

BitMart US (Plaee)

ROLR (High Roller Technologies)

Prospect Markets

QCX LLC d/b/a Polymarket US

DCM — designated Jul 2025 · DCO affiliate QC Clearing · acquired by Polymarket for $112M

QC Clearing LLC DCO · d/b/a Polymarket Clearing

Front-ends routing through QCX:

Polymarket US (direct)

Other live DCMs hosting prediction-market contracts

Each is its own DCM; clearing arrangement noted per row

ForecastEx LLC DCM + DCO · IBKR affiliate · routes: IBKR, Robinhood

Rothera (fka MIAXdx, LedgerX) DCM + DCO · Miami Intl Holdings · 90% owned by Robinhood & SIG

CME Group DCM + DCO · CME Clearing · routes: FanDuel Predicts, DraftKings Predict

Aristotle Exchange d/b/a UDX DCM + DCO · owned by Underdog

Gemini Predictions Gemini Titan (DCM) + Gemini Olympus (DCO)

Railbird Exchange d/b/a DKeX DraftKings-owned DCM; clears via QC Clearing (Polymarket) or Bitnomial

Small Exchange DCM (no in-house DCO) · Kraken-owned since Oct 2025 · clears via OCC (Options Clearing Corporation, SIFMU); third-party FCMs

Electron Exchange d/b/a ElectronX DCM + DCO · electricity prices

ProphetX DCM + DCO · Approved Jun 2026 · not launched yet

Ludlow Exchange, LLC (Novig) DCM approved Jun 2026 · not operating yet

Operating under CFTC no-action letter

Not DCMs — historical exemptions from intermediation/registration requirements

Iowa Electronic Markets University of Iowa · academic research

PredictIt Prediction Market Research Consortium · academic research

SEC-regulated prediction markets (securities-based event contracts)

Listed on SEC-registered national securities exchanges, not CFTC DCMs · structured as options on securities or securities indices · rely on the CEA § 2(a)(1)(C)(i)(I) swap-securities exclusion to sit outside CFTC jurisdiction · cleared by OCC (dual SEC/CFTC-registered SIFMU)

Cboe Predicts SEC-registered national securities exchange · launched Mini-SPX prediction contract Jun 2026 · partial-payout “payout zone” structure (proprietary, patent-pending) · cleared by OCC

Nasdaq Signaled interest in event-based products; SEC-registered exchange operator likely to pursue securities-based path rather than CFTC DCM registration

Why this matters: The prediction-market landscape is bifurcating into two regulatory tracks — CFTC-regulated event contracts (Kalshi, Polymarket, Crypto.com, et al., facing state-gambling-law preemption litigation) and SEC-regulated securities-based event contracts (Cboe, prospectively Nasdaq). The SEC path uses a slower Section 19(b) rule-change process but rests on more settled securities-law preemption.

Pending or announced

Upcoming prediction markets via CFTC DCM designation

Pursuing own DCM / DCO

Bitnomial

RSBIX

Sporttrade

Eventive (Rush Street Interactive)

Smarkets

PMEX Markets (Pluto)

Optex Markets

Juice Exchange

Water Street Labs (Cantor Fitzgerald)

PredictCraft (DimeTrades)

365Prediction, LLC

Matchbook

Metavesco

Limitless

Backpack

ICE Prediction Market

Optex Markets LLC

Front-ends planning to route via existing DCMs

Truth Predict via Crypto.com / CDNA

Hollywood.com via Crypto.com / CDNA

MyPrize via Crypto.com

Betr via Polymarket / QCX

Front-end intermediation status: how customers actually reach the market

Three legal pathways have emerged for prediction-market front-ends: full FCM registration (holds customer funds), IB registration (solicits orders, routes funds to an FCM), or unregistered “technology partner” arrangements (the DCM is the registered party). The IB route is the fastest-growing on-ramp for sports-betting and DFS operators.

Registered FCMs intermediating prediction-market contracts

Hold customer funds, accept orders, route to one or more DCMs · NFA members · subject to CFTC 17 CFR Part 1 rules

Robinhood Derivatives, LLC NFA ID 0424278 · routes to Kalshi, ForecastEx, Rothera

Performance Predictions II d/b/a PrizePicks Predict · approved Sep 2025 · routes to Kalshi, Polymarket

FanDuel Predicts (JV) CME 51% / FanDuel 49% · Routes to CME & Crypto.com; FanDuel standalone FCM filing pending

Sleeper Markets LLC approved Jan 2026 after CFTC litigation · routes to Kalshi

Foris DAX FCM LLC Crypto.com FCM · approved Sep 2025 · intermediates CDNA contracts

UDM LLC (Underdog) approved Jan 2026 · was tech partner; now FCM routing to CDNA, plus Aristotle DCM/DCO acquired Mar 2026

Morton St Trading Investments LLC Fanatics Markets FCM · approved Mar 2026 · routes to CDNA

Webull Financial LLC FCM · partnership announced Feb 2025 · routes to Kalshi (confirmed via Kalshi Help Center); pending Kalshi clearing membership

Coinbase Financial Markets FCM · routes Coinbase Predict orders to Kalshi · customer funds segregated under CFTC Rule 1.20 / Part 190

Kinetic Markets Kalshi-affiliated FCM · NFA registered Mar 24, 2026 · positions Kalshi for partially-collateralized (margin) trading once CFTC rule changes clear

Moomoo Financial Inc. FCM and swap firm · NFA-approved May 1, 2026 · routes to Kalshi · majority-controlled by Futu

Plus500US Financial Services LLC fka Cunningham Commodities · routes Plus500 US prediction-market orders to Kalshi (launched Feb 2026)

NinjaTrader Clearing, LLC fka TransAct Futures · acquired by Kraken in 2025

Clear Street LLC formerly an IB · routes prediction-market orders to Kalshi

Wedbush routes to CME · cleared 1B contacts Dec 2025-Jun 2026 · supports 24/7 crypto trading

GUS III LLC d/b/a DraftKings Predictions Approved Jul 2026 · NFA ID: 0571907

Pending FCM applications: FanDuel (standalone New Ventures III entity), ICE Derivatives Execution Services LLC.

Adjacent in-flight: Coinbase agreed to acquire The Clearing Company in Dec 2025 (CFTC DCO application pending); once approved, Coinbase will hold an FCM plus its own DCO, materially reducing Kalshi-dependence.

Registered Introducing Brokers intermediating prediction-market contracts

Solicit orders and route them through an FCM for execution and clearing on a DCM · do not hold customer funds · NFA members · bound by NFA Compliance Rule 2-29 advertising restrictions

Gus III LLC d/b/a DraftKings Predictions · approved Dec 2025 · routes to Railbird, CDNA, CME

Paragon Global Markets d/b/a Fanatics Markets IB · acquired by Fanatics Jul 2025 · routes to CDNA

Splash Market LLC (d/b/a Splash Sports) Betterpool, LLC · routes event-contract orders to Kalshi

Greenlight Commodities Houston-based IB · institutional/OTC · structured first prediction-market block trade on Kalshi (Apr 2026)

Ascent Capital Management Inc d/b/a ACM Futures · purchased by Betr Predictions LLC May 2026

Onyx Predictions LLC Onyx Odds sweepstakes platform · (May 2026)

Rails Markets, Inc d/b/a Rails · perpetual trading platform

High Roller Technologies d/b/a ROLR · (Jun 2026)

Pending IB applications: DAZN (Sports Marketing 1 LLC, filed Apr 2026, partnered with Polymarket / ADI Predictstreet) · Predictor LLC (Galactic — powers SI Predict and TIME prediction markets; IB + swap firm application filed Nov 2025) · Gains.com (sweepstakes platform) · Taild Sports Inc (affiliated with Chalkboard) · RealTime Fantasy Sports Inc · Starr Futures · Gains Predictions · Chronos Markets & Trading · Ratus AI · eToro USA Futures LLC.

Pattern: The IB route has emerged as the preferred on-ramp for sports-betting, DFS, and content-brand operators that want to plug into someone else’s DCM without the years-long DCM/DCO build or the higher capital and segregated-funds burden of full FCM status.

Technology partners (no NFA registration)

White-label arrangement — customer is the DCM’s customer; front-end provides only the app/UX layer. No customer funds held by the front-end · no NFA membership · DCM bears all CFTC obligations · not directly bound by NFA Rule 2-29 (though the DCM/FCM that “directly benefits” from the promotion is)

Truth Predict, Hollywood.com, MyPrize, High Roller, BitMart US, Prospect Markets tech partners to CDNA

Recently transitioned out of this category: Underdog (now FCM, Jan 2026), DraftKings Predictions (now IB via Gus III LLC, Dec 2025), Fanatics Markets (now IB via Paragon and FCM via Morton St). The unregistered tech-partner pathway is increasingly viewed as transitional — operators serious about scale are moving to FCM or IB registration.

Direct DCM brands (the exchange itself)

Customer-facing app operated by the DCM under its own registration · the brand the customer sees is the same legal entity that holds the DCM license · no intermediary in the stack

Kalshi (KalshiEX)

Crypto.com (CDNA)

Polymarket US (QCX)

IBKR ForecastTrader (ForecastEx)

Gemini Predictions (Gemini Titan)

ICE Prediction Market (ICE Futures U.S.)

Novig (Ludlow Exchange, LLC)

Operator-owned DCMs fronted by a separate consumer brand

DCM license owned by an operator that markets to customers under a different brand and routes order flow through a separate FCM or IB entity · the DCM itself has no live consumer-facing app under its own name

Railbird Exchange d/b/a DKeX DCM owned by DraftKings; customer-facing brand is DraftKings Predictions (Gus III LLC, IB) · pre-launch

Rothera DCM/DCO owned 90% by Robinhood & SIG; customer-facing brand is Robinhood (Robinhood Derivatives, FCM)

Aristotle Exchange d/b/a UDX DCM/DCO owned by Underdog; customer-facing brand is Underdog (Underdog FCM)

CME Group DCM/DCO; consumer-facing prediction-market brands are FanDuel Predicts and DraftKings Predict

Small Exchange DCM owned by Kraken (Payward Inc.) since Oct 2025 for $100M ($32.5M cash + $67.5M Payward stock); customer-facing brand is Kraken · no in-house DCO (clears via OCC) · IG Group retained as distribution partner

Water Street Labs, LLC DCO is CX Clearing fka Cantor Clearinghouse · Connected to BGC Group, which split off from Cantor Fitzgerald in 2004 · Waterstreetlabs.com redirects to CX Markets

The IB vs FCM vs tech-partner choice

FCMs hold customer funds and execute trades; IBs do not hold funds but solicit orders and route them to an FCM that holds the account. Both are NFA members bound by NFA Compliance Rule 2-29’s advertising and promotional-material restrictions. Tech partners hold no funds, take no orders, and are not NFA members — the DCM is the CFTC-overseen party that bears the regulatory obligations. The current regulatory trajectory — DraftKings, Fanatics, and Underdog all upgrading from tech-partner to IB or FCM status within the past year — suggests the tech-partner pathway is now treated as a starter chassis, not a permanent home.