Kalshi self-certifies two-year deposit and trading rewards programme worth up to $5,000

KalshiEX LLC filed a self-certification with the Commodity Futures Trading Commission that establishes a Deposit and Trading Reward Programme running for two years from no earlier than 28 September 2026. The exchange will pay Promotional Bonus Credits to individual customers through deposit matches and trading matches, with per-promotion caps of $2,500 and a programme cap of $5,000 per customer. The filing is dated 15 September and appears on the CFTC portal with an official receipt date of 25 September and a status of "10 Day Review".

What Kalshi filed with the CFTC and when

Kalshi submitted the rule under Kalshi Rule 3.13(f), which authorises programmes "that provide incentives to Participants that encourage trading." The self-certification says the programme will start on or after 28 September 2026 and run through 28 September 2028 unless otherwise modified. A version of the filing on the CFTC portal carries a 25 September receipt date and retains the 28 September start date. The exchange describes the programme's purpose as to "drive both deposit and trading activity, and strengthen liquidity and price discovery."

The filing names who may participate: Kalshi "Self-Clearing Members who are natural persons" in good standing who have passed identity verification and are not under compliance investigation. There is no numerical cap on participants.

Mechanics of the Deposit and Trading Reward Programme

Time-Limited Promotions run between three and 90 days. Promotions can be configured in two broad ways:

• deposit rewards earned when a single deposit at or above a specified minimum is made; or

• trading rewards earned when collateral committed to eligible contracts reaches a designated minimum, counting only fills priced between $0.03 and $0.97.

Kalshi may offer either a percentage match or a fixed reward. A participant can earn at most one percentage match and one fixed reward per promotion. The rules set these hard caps:

• up to $2,500 per individual promotion; and

• up to $5,000 in total across the two-year programme.

A fixed reward cannot exceed three times the qualifying minimum; therefore, to reach a $2,500 fixed reward the minimum must be at least $833. Where no minimum is set, the fixed reward cannot exceed $25. A percentage match may reach a full 100% match, but it is capped at $2,500.

Rewards are issued as "Promotional Bonus Credits" either in a lump sum or in instalments over three to ten days. Credits expire one to 30 days after issue and may only be withdrawn after the participant "has traded an amount equal to the Bonus Credit." Eligible contracts for a given promotion can be the whole exchange or be limited to a category such as sports, a single sport or league, crypto, economics, financials, politics, weather and climate, or culture and entertainment. Kalshi will announce eligible contract categories at least 24 hours before each promotion.

Targeting, safeguards and confidentiality

Promotions can be targeted by criteria listed in the filing and Appendix B: inactivity lookback, account age, funded or unfunded account status, prior deposit or trading activity, prior activity or inactivity in one or more contract categories, geographic location, or account status. The specific match rates, minimum deposit thresholds and reward values are in Appendix B, which Kalshi has asked the CFTC to keep confidential.

The modified filing adds anti-abuse safeguards. It excludes trades linked to self-matching, wash trading or pre-arranged trading, prevents incentives stacking on a single trade, and trims payments that would leave a trade with net-negative fees. The exchange represents it "is not aware of any substantive opposing views."

How this sits against CFTC guidance and recent case law

The filing arrives after the CFTC's Division of Market Oversight issued Staff Letter 26-23 on 12 August 2026, warning it had seen incentive filings for event contracts that were "procedurally or substantively deficient." The staff letter cautioned that threshold bonuses can encourage trading "solely to reach volume targets" and said rewards should not be "gamified, casino-style." It also stated that a substantive change to a pending filing requires a new submission and a new ten-business-day review.

Separately, two federal appeals courts have recently moved the treatment of Kalshi's sports contracts into state gambling law territory. The Sixth Circuit ruled three days before the programme's 28 September start date that Ohio and Tennessee may enforce their gambling statutes against Kalshi's sports contracts, a decision that bears on sportsbook-style promotions aimed at sports contracts.

Sports contracts, Premier League sanctions and related event contracts

On 28 September Kalshi self-certified event-class contracts that address whether the English Premier League will impose a sanction on Manchester City, and a class covering any Premier League club. Possible sanctions listed in the filings include title stripping, a points deduction, a fine of at least £500,000 or a registration ban, and the first official announcement counts even if reduced on appeal. The certification followed media reports that an independent commission had found Manchester City guilty on 114 of 115 charges; no official sanction had been announced and the Premier League had not published a ruling at the time of the filing.

Kalshi also certified a contract covering the number of regular-season Major League Baseball games played in 2027; payouts scale with how far the total lands from a strike. MLB's collective bargaining agreement with players expires on 1 December 2026, according to ESPN.

Railbird Exchange, trading as DKeX and launched by DraftKings in June, certified on 25 September swaps on whether Nikola Jokić wins the 2026-27 NBA MVP and whether Jalen Brunson scores the first points for the Philadelphia 76ers against the New York Knicks on 20 October. Those contracts resemble sportsbook props but were filed as swaps.

Regulatory and market implications for operators and regulators

The programme's structure — deposit matches up to 100%, short credit expiry windows, targeting of inactive customers and league-specific promotions — mirrors standard sportsbook welcome and reload offers. The filing contains caps and anti-abuse language but includes no affordability or responsible-gambling measures. Kalshi accounts are open from age 18; in Ohio and Tennessee sportsbook customers must be 21.

Because the detailed economics live in a confidential appendix, state regulators and customers cannot compare Kalshi's bonus terms against those of licensed sportsbooks. The CFTC advisory on incentive filings and the timing of the portal receipt raise a procedural question: if the 25 September portal entry is treated as a new submission, the ten-business-day clock would run to 9 October rather than the 28 September start date the filing still cites.

"The programme is designed to drive both deposit and trading activity, and strengthen liquidity and price discovery," Kalshi wrote in its self-certification.

The CFTC Division of Market Oversight warned that some incentive filings had been "procedurally or substantively deficient," in Staff Letter 26-23 dated 12 August 2026.

For market operators and compliance teams, the filing is a reminder that incentive mechanics used by sportsbooks can be translated to exchange-listed event contracts, but they land in a different regulatory mix when courts allow states to treat those contracts as gambling. The confidentiality around Appendix B means the practical customer-facing economics will remain visible only to regulators and not to the public.