SEC
Securities and Exchange Commission (US)
SEC notice: KalshiEX immediately effective rule filing to add Chapter 14 for Perpetual Security Futures Products
Published
Sep 18, 2026
Effective
Sep 18, 2026
Topics
Security futures products, Exchange rulebook, Product listing standards, Margin requirements, Position limits, Market surveillance, Trading halts, Corporate actions
Executive Summary
The SEC has published KalshiEX LLC’s immediately effective proposed rule change to adopt Rulebook Chapter 14 for “Perpetual Security Futures Products” or Perpetual SFPs. The proposal would let Kalshi list cash-settled, indefinite-duration security futures referencing eligible equity securities, with daily funding payments intended to align the product price with the underlying security. The filing was made with the SEC on September 18, 2026 and submitted to the CFTC for approval on the same date; the SEC notice states that the CFTC had not yet approved it. Chapter 14 sets detailed product eligibility, delisting, margin, settlement, position limit, corporate action, market surveillance, sales practice and broker-member standards. The most immediate business impact is for Kalshi, Kalshi Klear, Kalshi Prime, FCMs and broker-dealers that may intermediate or trade these products, and firms monitoring equity-derivatives market structure. Controls will be needed for underlying-security eligibility checks, margin configuration, funding calculations, trading halts, position limits and customer risk disclosures before any launch.
What Changed
Previous
Kalshi’s rulebook did not contain a Chapter 14 framework for Perpetual Security Futures Products.
New
Chapter 14 would define Perpetual SFPs and establish listing, trading, settlement, margin, position limit, surveillance, corporate action and membership rules.
Previous
No Kalshi Perpetual SFP eligibility framework existed.
New
Initial listing includes, among other tests, ADTV of at least $450 million over six months, or $1 billion over the prior month for shorter-listed securities; market capitalization of at least $100 billion; and estimated deliverable supply above 20 million shares. Maintenance includes quarterly review, a 90-calendar-day cure period for maintenance failures, and immediate delisting events.
Previous
No Kalshi rule existed for Perpetual SFP funding-rate computation.
New
Funding uses 60-second computation intervals during the U.S. equity regular trading session, excludes block trades, applies a deadband threshold of 0.002% and maximum funding magnitude of 2.00%, and settles through Kalshi Klear at the daily settlement time.
Previous
The joint SEC/CFTC customer margin rules establish a 15% minimum initial and maintenance margin requirement for security futures positions.
New
FCM SFP Broker Members must collect and maintain margin of at least 15.50% of current market value for each customer Perpetual SFP position, with no lower margin for offsetting positions and no separate initial or maintenance rate.
Previous
No Perpetual SFP-specific trading, position or surveillance framework existed in Kalshi’s rules.
New
Perpetual SFPs would trade from 6:00 PM ET Sunday to 5:00 PM ET Friday with a daily 5:00 PM–6:00 PM ET maintenance window; the standard contract unit is 100 shares; the minimum price fluctuation is $0.005 per share; and baseline position limits include 50,000 standard contract equivalents generally and 25,000 during the last three trading days before final settlement.
Business Impact
Who is affected
Directly affected
KalshiEX, Kalshi Klear, Kalshi Prime, Kalshi members, FCM SFP Broker Members, broker-dealers or FCMs seeking to intermediate Perpetual SFP transactions, and participants trading or carrying Perpetual SFP positions.
Indirectly affected
equity market surveillance teams, clearing and collateral teams, compliance teams monitoring security futures, technology vendors supporting derivatives reference data, and issuers of potential underlying securities.
Jurisdictions
United States
Business processes
New product approval and product governance, Underlying-security eligibility and ongoing quarterly maintenance review, Customer onboarding, account approval and security futures risk disclosure delivery, Margin calculation, collateral eligibility and margin-call processing, Daily mark price, funding-rate and settlement calculation, Position limit, aggregation, exemption and accountability monitoring, Trading halt, corporate action, delisting and accelerated final settlement workflows, Market surveillance, audit-trail retention and intermarket information sharing
Estimated effort
High
Compliance risk
High
Affected Reports
| Field | Validation rule |
|---|---|
| Underlying Security eligibility status | Rules 14.3 and 14.4 require eligibility checks for security type, registration, NMS status, public float, holders, ADTV, price, market capitalization, estimated deliverable supply, reporting status and categorical exclusions. |
| Maintenance review result and cure-period status | Rule 14.6 requires quarterly maintenance review and a 90-calendar-day cure period for maintenance failures, subject to immediate delisting events. |
| Contract Unit | Rule 14.9(a) sets one Perpetual SFP contract unit at 100 shares of the underlying security. |
| Minimum price fluctuation | Rule 14.9(c) sets the minimum price fluctuation for Perpetual SFPs at $0.005 per share. |
| Funding Rate | Rule 14.10 calculates the funding rate from observed premiums during 60-second computation intervals, subject to a 0.002% deadband threshold and 2.00% maximum funding magnitude. |
| Mark Price and Daily Settlement Price | Rule 14.12 establishes a tiered methodology using trade VWAP, sampled midpoint average, prior mark plus underlying index change, or an alternative methodology when needed. |
| Perpetual SFP Margin Ratio | Rule 14.16 requires FCM SFP Broker Members to collect and maintain customer margin of at least 15.50% of current market value. |
| Position limit or accountability level | Rules 14.23 and 14.24 establish position limits, liquidity-tiered limits, a 200,000 standard contract equivalent cap and accountability levels where permitted. |
| Trading halt status | Rule 14.13 requires trading halts in a Perpetual SFP during a regulatory halt affecting the underlying security and prohibits block trades during the halt. |
| Corporate action adjustment or accelerated settlement status | Rules 14.26 through 14.30 govern adjustments, accelerated final settlement and related notice timing for corporate actions affecting the underlying security. |
Recommended Actions
- 1AI generatedStep 1 of 7
Treat this as a conditional launch-readiness item because the SEC notice states immediate effectiveness, but also states the CFTC had not yet approved the proposed rule change.
- 2AI generatedStep 2 of 7
Build a Perpetual SFP product-control matrix covering initial listing tests, categorical exclusions, quarterly maintenance standards, cure-period monitoring and immediate delisting triggers.
- 3AI generatedStep 3 of 7
Configure margin and collateral systems for a 15.50% Perpetual SFP margin ratio with no offset relief unless later rules or notices expressly permit a different treatment.
- 4AI generatedStep 4 of 7
Validate pricing engines against the proposed mark-price, funding-rate, deadband, cap, block-trade exclusion and daily settlement mechanics before allowing customer trading.
- 5AI generatedStep 5 of 7
Update customer onboarding for SFP Broker Members to include security futures account approval, required risk disclosure delivery and written acknowledgement capture.
- 6AI generatedStep 6 of 7
Implement surveillance alerts for regulatory halts, insider-trading restrictions, position limits, position accountability levels, wash trades, self-matching and manipulation of the underlying security or Perpetual SFP.
- 7AI generatedStep 7 of 7
Monitor SEC, CFTC, Kalshi and Federal Register publications for CFTC approval, product certifications, contract specifications, Exchange Notices and any comment or approval developments.
Timeline
other
Sep 5, 2001
SEC staff issued Staff Legal Bulletin No. 15 on listing standards for trading security futures products, which Kalshi cites as a benchmark for its proposed listing standards.
other
Nov 19, 2009
SEC and CFTC issued a joint order modifying security futures listing-standard requirements for ETF shares and trust-issued receipts, which Kalshi says its proposed standards reflect.
other
May 29, 2026
CFTC approved Kalshi’s BTCPERP futures contract, cited by Kalshi as precedent for perpetual futures over a non-security underlier.
other
Jul 7, 2026
Federal Register published CME’s security futures rule filing, cited by Kalshi for certain more stringent listing standards.
effective date
Sep 18, 2026
Kalshi filed SR-KALSHIEX-2026-02 with the SEC, and the SEC notice states the proposed rule change was filed with immediate effectiveness.
other
Sep 18, 2026
Kalshi submitted the proposed rule change to the CFTC for approval under Commodity Exchange Act Section 5c(c); the SEC notice states the CFTC had not yet approved it.
Sources
AI-generated analysis is based on the following primary sources. Always verify against the official publication.
- SRO notice / proposed rule changeU.S. Securities and Exchange CommissionSep 18, 2026Self-Regulatory Organizations; KalshiEX LLC; Notice of Filing and Immediate Effectiveness of a Proposed Rule Change Relating to Listing Standards for Security Futures Products ↗
https://www.sec.gov/files/rules/sro/kalshiex/2026/34-106422.pdf
- Staff legal bulletinU.S. Securities and Exchange CommissionSep 5, 2001Staff Legal Bulletin No. 15: Listing Standards for Trading Security Futures Products ↗
https://www.sec.gov/interps/legal/mrslb15.htm
- Joint orderFederal Register / SEC and CFTCNov 24, 2009Joint Order Modifying the Listing Standards Requirements under Section 6(h) of the Securities Exchange Act of 1934 and the Criteria under Section 2(a)(1) of the Commodity Exchange Act ↗
https://www.federalregister.gov/documents/2009/11/24/E9-28040/joint-order-modifying-the-listing-standards-requirements-under-section-6h-of-the-securities
- RegulationElectronic Code of Federal RegulationsDate not specified17 CFR Part 41 - Security Futures Products ↗
https://www.ecfr.gov/current/title-17/chapter-I/part-41
- SRO noticeFederal RegisterJul 7, 2026Self-Regulatory Organizations; Chicago Mercantile Exchange Inc.; Notice of Filing and Immediate Effectiveness of a Proposed Rule Change Relating to Security Futures Product Listing Standards ↗
https://www.federalregister.gov/documents/2026/07/07/2026-13712/self-regulatory-organizations-chicago-mercantile-exchange-inc-notice-of-filing-and-immediate
Related Evidence
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