Kalshi sign-up codes offering randomized rewards of $10, $25, $50, $100 or $2,000 remained promoted in early October, weeks after CFTC staff warned designated contract markets that chance-based incentives likely conflict with impartial-access rules. Gambling Insider reported on October 7 that at least four such codes were still circulating.
What did the CFTC say about randomized exchange rewards?
The warning came in CFTC Staff Advisory Letter No. 26-23, issued August 12, 2026, by the Commodity Futures Trading Commission’s Division of Market Oversight. The advisory, signed by acting DMO director Duncan Hennes, addressed incentive programs self-certified by designated contract markets under Commission Rules 40.5 and 40.6.
The letter did not create a new binding rule. It set out DMO staff’s current view of incentive-program structures that can raise compliance concerns under the Commodity Exchange Act and CFTC regulations. Its language on randomized rewards was unusually direct for a staff advisory.
“Sweepstakes-like or randomized rewards programs or prizes based, in whole or in part, on pure chance, rather than pre-defined performance metrics, likely run afoul of Core Principle 2 because they introduce unequal and non-objective benefits that treat market participants within the same category differently,” the advisory stated.
A footnote added that rewards should not be offered through “gamified, casino-style, or other chance-based mechanisms,” including spin-the-wheel promotions or offers where the availability, amount or value of a reward is determined through randomized or game-like features.
Core Principle 2 is the Commodity Exchange Act’s impartial-access requirement for designated contract markets, codified in Section 5(d)(2) and implemented in CFTC regulations at 17 C.F.R. 38.150 through 38.160. The advisory also flagged risk-free trade language, unlimited rebates and steep volume-tier rewards as incentive structures that can create regulatory concerns, including wash-trading risks and possible conflicts with Rule 1.56’s limits on guarantees.
The advisory gave exchanges a specific review marker. In footnote 15, DMO staff recommended that all designated contract markets with previously submitted incentive programs under Rule 40.6(a) review those programs and submit any amendments by September 14, 2026.
Which Kalshi codes were still being promoted?
Gambling Insider reported on October 7 that at least four Kalshi codes promoted in early October used the randomized bonus structure: AMNY, GOAL2000, MILE and RAD2000. The outlet reported that the possible reward amounts were $10, $25, $50, $100 and $2,000, and that current odds for receiving each tier were not disclosed.
Affiliate pages continued to advertise Kalshi sign-up offers with a $2,000 maximum after the CFTC staff advisory. A Crossing Broad page for the RAD2000 code, published September 28, described a $10 minimum first deposit, $25 in cumulative qualifying trades and a bonus of up to $2,000. Mile High Sports and SailGP’s prediction-markets section also advertised Kalshi offers with a $2,000 ceiling.
Dustin Gouker, writing in his Straight to the Point newsletter, summarized the disclosure issue this way: “no one is being very transparent about your odds of getting the $2,000 bonus.” That is also the regulatory pressure point in the CFTC staff advisory. The advisory’s concern is not the size of a reward by itself, but whether the amount or value is determined by chance and whether participants who meet the same criteria receive unequal treatment.
Kalshi’s randomized bonus structure had drawn attention before the October report. InGame reported on August 13 that Kalshi was promoting bonuses of up to $500 where the size was left to chance. The affiliate pages cited in early October advertised a maximum of $2,000, increasing the visibility of the issue after the CFTC staff warning.
What did Kalshi file after the CFTC staff deadline?
Gambling Insider reported that CFTC records showed Kalshi filed a “Deposit and Trading Reward Incentive Program” on September 15, one day after the advisory’s recommended amendment date. The outlet also reported that another filing with the same name appeared on September 25. The public filing descriptions do not show from their titles alone whether those submissions covered the randomized $2,000 offers reviewed in the report.
Gouker also noted a September 28 Kalshi filing terminating a separate volume-incentive program early. Under CFTC Rule 40.6, self-certified rules and rule amendments generally become effective after a 10-business-day review period unless the Commission stays certification. The August advisory reminded exchanges that when a submission may be inconsistent with the Act or CFTC regulations, the Commission may request more information, seek modification or stay the program’s effectiveness.
As of October 7, the CFTC had not announced a public stay tied to the September Kalshi incentive filings discussed in the Gambling Insider report. Kalshi had not publicly commented on that report by publication time.
Is the CFTC preparing a broader review of prediction-market incentives?
Front Office Sports reported on September 29 that the CFTC, under Chairman Michael Selig, was preparing a sweep of incentive programs offered by prediction-market platforms, naming Kalshi, Polymarket and Novig. As of October 7, the Commission had not announced examinations or enforcement actions arising from that reported review.
The Front Office Sports report said the agency was examining promotions involving promised deposit amounts on signup, risk-free trades, unlimited rebates and guaranteed-profit language. Those categories overlap with the incentive-program concerns described in the August DMO advisory, although the advisory itself applies to designated contract markets and their incentive programs, not to one named company.
The affiliate channel matters because the advisory extends exchange obligations to incentives offered or delivered through third-party affiliates or intermediaries. DMO staff said exchanges should maintain sufficient oversight and safeguards over those arrangements. That framing puts responsibility on the exchange rather than only on the publisher or affiliate page carrying the code.
Gambling Insider also noted that Kalshi promotional codes were being distributed through media-affiliate channels while Kalshi market data was appearing in news and sports contexts. The regulatory issue is narrower than the media-business question: whether a designated contract market can continue using or distributing a chance-based sign-up reward after staff said such structures likely conflict with impartial-access obligations.
Why does a sign-up bonus matter to a derivatives regulator?
The CFTC question turns on exchange regulation. Kalshi operates as a federally regulated designated contract market, and its legal position in disputes over event contracts has relied on the federal commodities-law framework governing its markets. A randomized customer-acquisition reward creates a different compliance issue: it can make an exchange incentive look less like an objective access program and more like a game of chance.
For state regulators and attorneys general scrutinizing prediction markets, that comparison is politically useful. For the CFTC, the immediate question is more technical: whether a reward whose value is determined by chance gives similarly situated participants unequal, non-objective benefits in a way that conflicts with Core Principle 2.
The next public marker is whether the CFTC takes visible action on incentive programs after the September 29 Front Office Sports report and the August 12 staff advisory. As of October 7, the Commission had not announced related enforcement actions, while the AMNY, GOAL2000, MILE and RAD2000 promotions remained described on affiliate pages reviewed by Gambling Insider.
