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SEC

SEC

Securities and Exchange Commission (US)

High Impact

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

newPerpetual SFP product framework

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.

newUnderlying-security eligibility and delisting standards

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.

newDaily funding and mark-price methodology

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.

newHigher customer margin requirement

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.

newTrading, position and surveillance controls

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

Approved Securities Table for eligible underlying securitiesNew Product Committee written approval memorandum and product determination recordsExchange Notices for delisting, accelerated final settlement, trading halts and safeguard changesCustomer security futures risk disclosure acknowledgement recordsPosition limit, position accountability and hedging-exemption monitoring controls
FieldValidation rule
Underlying Security eligibility statusRules 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 statusRule 14.6 requires quarterly maintenance review and a 90-calendar-day cure period for maintenance failures, subject to immediate delisting events.
Contract UnitRule 14.9(a) sets one Perpetual SFP contract unit at 100 shares of the underlying security.
Minimum price fluctuationRule 14.9(c) sets the minimum price fluctuation for Perpetual SFPs at $0.005 per share.
Funding RateRule 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 PriceRule 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 RatioRule 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 levelRules 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 statusRule 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 statusRules 14.26 through 14.30 govern adjustments, accelerated final settlement and related notice timing for corporate actions affecting the underlying security.

Recommended Actions

7 suggested next steps· derived from source analysis
  1. 1
    AI 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.

  2. 2
    AI 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.

  3. 3
    AI 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.

  4. 4
    AI 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.

  5. 5
    AI 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.

  6. 6
    AI 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.

  7. 7
    AI 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

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