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CHI Company Investigation · Finance

Kalshi

The Market Is Transparent. The Rules Still Leave Kalshi Holding the Final Word.

CFTC-regulated event-contract exchange · Combos · Perpetual futures via an affiliate
Standard company investigation · No score assigned · Research current through 5 October 2026

Kalshi gives users visible prices, open markets and competitive transaction economics. But when wording-dependent contracts become disputed, the exchange retains substantial control over interpretation and settlement.

On price, exit and the treatment of winning users, the evidence mostly runs in Kalshi’s favour. What survived verification is narrower: who decides a disputed outcome, what a user can do about it, and which sportsbook protections do not reach sports-like contracts.

≈ ParityTaker cost vs FanDuel and DraftKings, liquid NFL singles, Sept–Oct 2026
None foundCases of Kalshi limiting a user for winning
No routeFor a user to start a challenge to a market outcome
18Kalshi’s minimum age; most state sportsbooks require 21
Estimated read 24 min

The trading core Mostly favourable

Published prices, a published fee formula, and an open book to exit on.

Event contracts are fully collateralized, so a user cannot lose more than the cost plus the fee. Kalshi publishes its fee formula, shows resting orders and prints completed trades in a public feed. No case was found of a winning user being limited.S2S3S4S7

Full collateralPublished fee formulaOpen order bookPublic tradesNo winner-limiting found

When a contract is disputed Kalshi decides

Kalshi writes the contract, interprets it and settles it.

Its rules give it sole discretion over interpretation, and only Kalshi can start a formal review of an outcome. The user’s formal route afterwards is arbitration that Kalshi convenes, with a fee of $500 or $1,000.S1

Sole discretionNo user-initiated reviewPost-event rule, April 2026Kalshi-convened arbitration

This distinction is the finding. The everyday trading relationship is mostly transparent and, on several measures, better for users than a sportsbook. The concerns that survived sit where a contract’s wording is contested, and in the protections a sports-like product leaves behind.

01Why we looked

An exchange that sells contracts on almost anything, to everyday users.

Kalshi is a CFTC-designated contract market. Users buy contracts that pay $1 if an event happens and nothing if it does not: a team wins, a rate is cut, a person says a word. Alongside sports, politics and economics it now offers multi-leg “combos” and, through an affiliated broker, leveraged perpetual futures.

The proposition tested was that Kalshi’s structure works against its users: through cost, through how outcomes are decided, through weak recourse, and through protections lost when sports exposure moves from a licensed sportsbook to a federally regulated exchange.

CHI ran two research passes. The first built the case. The second reopened the rulebook, the contracts, the court orders and the regulators’ texts, and moved several findings in Kalshi’s favour. This page reports the second pass, and gives the favourable evidence first.

One distinction runs through the page. A different regulatory form is not hostility, and neither is exchange finality. The question is whether users are worse off than they would reasonably expect, and worse off than at the alternatives.

02What Kalshi does well

The favourable evidence, at full weight.

Several of the first pass’s concerns weakened or failed on verification. These are not caveats; they are part of the result.

Cost

About parity on busy NFL singles

For users taking the displayed price on liquid NFL moneylines and totals in Sept–Oct 2026, the all-in cost was about the same as at FanDuel and DraftKings, sometimes slightly lower.S14

Limit orders

Cheaper if they fill

A resting order that fills pays a far smaller fee, or none. A fill is not guaranteed.S3

Fee display

Fee-inclusive cost before you confirm

Kalshi’s published review screens (c. 2025) show the cost with the fee included and the profit net of it. The itemized fee sits behind an icon.S4

Winning users

No winner-limiting found

No documented case of Kalshi limiting, restricting or closing an account because the user was profitable.S17

Withdrawals

No friction by design

No withdrawal fee, published minimum or bonus lock on a user’s own cash was found. Holds apply to recent deposits, not to winnings.S5

Exit

Sell on an open order book

Users can sell before the event to anyone who will buy. Kalshi does not set the exit price.S4

Visibility

Prices and trades are public

Resting orders are shown, and completed trades appear in a public, unauthenticated feed.S7

Account discipline

Real due process

Written charges, a hearing with witnesses, an appeal and CFTC review. Trading limits need written reasons and allow a 28-day petition.S1

Corrections

Some errors fixed at Kalshi’s cost

Kalshi refunded fees and reimbursed some purchases in the Khamenei market, by its own account; users hit by Super Bowl LX deposit problems were reimbursed.S9S5

Perpetual futures

Walled off from event contracts

A separate affiliated firm, agreement, application, questionnaire, tutorial and balance, with manual transfers only. Offering them is normal market structure.S8

03What weakened under verification

The first pass found more than survived. The difference is the method working.

Single-market costWithdrawn

The first-pass view that liquid singles cost takers more than sportsbooks did not hold. Fee-explicit comparisons show about parity on busy NFL markets; the evidence does not reach other sports or periods.S14

Fee displayNarrowed

Only the itemized fee sits behind an icon; the cost shown already includes it.S4

CombosNarrowed to a watch item

Each combo has its own order book, any member may quote, and completed trades are public.S7

Perpetual futuresReclassified as normal

Robinhood, Coinbase and Webull also offer leveraged futures through an affiliated broker beside other products.S8

RecourseNarrowed

Weak for outcome disputes and small money claims only. Account discipline has full process.S1

Michigan positionsNot established

Kalshi filed a plan to liquidate some Michigan positions; the CFTC stayed it on 14 July 2026. No unwind was verified.S21

MassachusettsNot a current restriction

The state’s preliminary injunction has been stayed since 17 February 2026.S22

Khamenei market factsCorrected in Kalshi’s favour

The death carve-out was printed in the market’s rules; trading halted about seven hours before close; the 54.5 million figure counts contracts, not dollars.S9

Verification also cut the other way. It found a market settled under a rule written after the event, confirmed income-style wording in Kalshi-run ads, found “bet on sports” in today’s Google Play listing, and showed that omitting a gambling helpline is Kalshi’s choice. Those findings are why the result stays at partially supports.

04Finding 1 · Settlement and contract interpretation

When wording decides the payout, Kalshi decides what the wording means.

The narrowed finding

Discretionary settlement of language-dependent contracts without a user challenge route.

Frequency is low. Severity, when it happens, can be high: in a few large 2026 markets the wording, or a rule adopted after the event, decided who was paid.
Interpretation · Rule 6.3(c)

Sole discretion

“Kalshi has sole discretion to interpret a Contract’s Terms and Conditions.”

Committee determinations are “final and not subject to review”.S1

Outcome review · Rule 7.1

Only Kalshi can start it

“Before Settlement, Kalshi may initiate the Market Outcome Review Process, at its sole discretion”

No rule or help article gives a user the right to start it.S1

Emergency powers · Rule 2.8

Rules can change at speed

Kalshi may act “without giving prior notice to, or securing prior approval from the Commission”. It used this power to settle a market in April 2026.S1

Who decides

A committee with public directors

The Outcome Review Committee has three members, at least two of them Public Directors (Rule 2.7).S1

What users can ask for

Review of a trade, not an outcome

A user may request review of an erroneous trade within 15 minutes (Rule 5.11). The decision is final.S1

After disputes

Templates were rewritten

Kalshi rewrote its performer template (2 March 2026) and amended leader-exit (11 May) and mention terms (April–July 2026).S9

Normal for an exchange

  • Final settlement. Futures exchanges such as CME set final settlement prices without a member appeal.
  • Exchange discretion over ambiguous events.
  • Last-price settlement when a sports event is interrupted.

Unusual in combination

  • Mass-retail users
  • Natural-language contracts whose meaning can be argued
  • Outcome-deciding conditions sometimes in the rules text, not the title
  • Discretionary interpretation, and once a rule written after the event
  • No user-initiated or external route to challenge an outcome

Other venues give users a route. In Nevada, sportsbook disputes of at least $500 go to the state Gaming Control Board; Polymarket’s international market lets anyone challenge a result by posting a bond. Each has its own weaknesses; this is not a quality ranking, and sportsbook routes vary by state.S11

The clearest case: the White House Correspondents’ Dinner

25 April 2026

The event is interrupted. The mention market’s written terms said that if the event “fails to qualify under the Payout Criterion, or any other circumstance prevents normal resolution”, the “Event does not qualify” market resolves to Yes. A 14-day postponement clause also applied.

Written terms
28 April 2026

Kalshi files a rule amendment, effective generally from 12 May 2026 but “effective immediately under Kalshi Rule 2.8 with respect to the settlement of markets related to the White House Correspondents’ Dinner”.

Rule after the event
29 April 2026

All 44 outcomes settle at pre-incident prices. “Event does not qualify” settles at $0.01; it had last traded at about $0.66.

Settled
Kalshi’s statement

Kalshi said it “expects to reimburse traders using operational funds as necessary to prevent harm” and that “most market participants appear to support this rule”.

Stated intent
Not established

Whether any reimbursement was paid; what users lost; whether “Event does not qualify” holders were entitled to $1, given the postponement clause.

Open

Source. Kalshi’s rule filing of 28 April 2026 and its public market data.S9 This case does not show that anyone was cheated. It shows that the party deciding the outcome also wrote the deciding rule after the fact, and that users had no route to contest it.

Other 2025–26 disputes, stated precisely

MarketWhat decided the payoutWhat the record shows
Linda Yaccarino and XThe rules, not the titleThe clearest title-versus-terms case. The title asked about her leaving X; the rules required an announced new CEO by 31 December 2025. Settled No.S9
Ali KhameneiA disclosed death clauseThe clause, paying the last price before death, was printed in the market’s rules. Strikes settled at $0.02–$0.51. 54.5 million contracts traded across five strikes. Kalshi refunded fees and reimbursed some purchases, by its own account.S9
Super Bowl LX performerAn undefined termWhether Cardi B’s appearance counted as “perform”. Settled at the last traded price ($0.26 / $0.74) under Rule 6.3(c); the template was rewritten.S9
Brad Pitt attendanceA disclosed testAttendance counted if the person was “reported present at the event by any Source Agency”. Kalshi applied that test and settled Yes; the reports later proved wrong.S9

Disputes are rare by count. They cluster in large, wording-dependent markets.

No reliable dispute rate exists, and CHI does not publish one: the documented cases are only those that reached the press, and Kalshi’s resolved markets are dominated by mechanical sports, crypto and combo contracts.S10

05Finding 2 · Recourse

Narrow for outcomes and small sums. Fuller for account discipline.

Recourse on settlement outcomes and small money claims is narrow and, through the rulebook’s arbitration route, expensive relative to the sums involved. Account discipline carries fuller process, including CFTC review.

Market outcomes

Narrow

No review a user can start; support contact only. A CFTC complaint goes to enforcement staff and yields no individual recovery. The CFTC’s reparations program reaches only registered persons, and its handbook sends settlement complaints to the exchange first.S1S12

Small money claims

Expensive relative to the sums

Arbitration under Chapter 10 of the rulebook, with a panel Kalshi convenes. Fee: $500 under $5,000, $1,000 at $5,000 or more, paid to Kalshi. No small-claims option appears in the documents, and suing before arbitrating is treated as a rule violation (Rule 10.4(a)).S1

Account discipline

Fuller process

Written charges, 15 days to contest, a hearing with witnesses, an Appeals Committee, and CFTC review of exchange discipline. Trading limits need written reasons and allow a 28-day petition (Rule 3.11).S1

Filing fees for a small claim, by route
RouteFeeNote
Kalshi arbitration, claim under $5,000$500Paid to Kalshi; the panel may award it back
Kalshi arbitration, $5,000 or more$1,000Paid to Kalshi; the panel may award it back
FINRA customer arbitration, up to $5,000$50–$175Brokerage comparator; hardship deferral available
NFA arbitration, up to $50,000$250 + $175For customers of futures brokers
CFTC reparations$50–$250Not available against an exchange

There are real mitigations. The panel may award the fee back, fee-shifting runs both ways, and no class-action or jury waiver appears in the exchange documents.S1

How binding is arbitration? Chapter 10 applies “If so elected” (Rule 10.1), while Rule 11.3(d) provides for binding arbitration of actions against Kalshi parties. Whether these terms bind users is contested in a pending federal case in New York, where plaintiffs say they never agreed to them. That is an allegation; no court has ruled on it.S23

06Finding 3 · The sportsbook protection gap

Sports-like contracts, without sportsbook rules. And without some sportsbook problems.

Kalshi’s sports contracts sit under federal derivatives rules, not state gaming law. Some protections state sportsbooks must offer do not apply. Some protections the exchange form provides are ones sportsbooks do not offer.

18Kalshi’s stated minimum age. Most state-licensed sportsbooks require 21.Help center
≈ 31–32States where a person aged 18–20 can buy Kalshi sports contracts but is too young for a legal sportsbook.Approximate · CHI computation
3.14%Share of trading volume from users aged 18–21 in August 2026 (4% in May). Volume, not users.Company figures via CNN
Not establishedThat users aged 18–20 are harmed more. No measurement exists.Open

About the state count. It is CHI’s own approximate computation from secondary lists of sportsbook ages. It changes as court orders restrict Kalshi in particular states, and in about 11 further states there is no licensed sportsbook at any age. Kalshi declined to tell CNN how many users it has aged 18 to 21; the band CNN reported includes 21-year-olds.S15

What sportsbook users may have

Required or offered by state-licensed sportsbooks, depending on the state.S13

  • A minimum age of 21In most states. Wyoming, New Hampshire and D.C. allow 18.
  • State self-exclusion listsNew Jersey, Pennsylvania and Massachusetts require licensed operators to block listed people. Kalshi holds no state gambling licence and, NPR reported, does not take part in state self-exclusion databases.S16
  • Loss, stake and time limitsOffered by DraftKings and FanDuel; some mandated in Pennsylvania. Kalshi documents a monthly deposit cap only.
  • A gambling helplineDraftKings and FanDuel display 1-800-GAMBLER. Kalshi’s help hub lists 988 and Birches Health; no gambling helpline number was found.S6
  • A regulator complaint routeNew Jersey, Pennsylvania and Massachusetts take patron complaints.

What Kalshi users have instead

Protections that come with the exchange form.S1S17

  • No limiting of winning users foundSportsbooks reserve stake limits. In Massachusetts, 0.64% of accounts were limited as of December 2024, an average across operators.
  • Exit on an open order bookSportsbook cash-out is set at the operator’s discretion.
  • Visible prices and a published feeNo sportsbook margin disclosure was found in the house rules read.
  • Reasons for account actionKalshi’s rules require written reasons; DraftKings’ New Jersey terms reserve closure for “any reason or no reason”.
  • A capped lossOn event contracts a user cannot lose more than the cost plus the fee.

The two regimes guard against different risks. State rules protect against loss of control; the exchange form protects against operator discretion over price, limits and exit. Sportsbook protections vary by state.

Self-exclusion and brokers

Kalshi offers its own tools: a monthly deposit cap, trading breaks and self-exclusion, none of which can be lifted early. By its own description, self-exclusion “does not limit a trader’s ability to access Kalshi products via a Futures Commission Merchant”, meaning broker apps such as Robinhood that list Kalshi contracts. Some brokers run exclusion tools of their own. The one cross-platform list, SelfExclude.io, currently covers Kalshi and Novig.S6S16

Much of the gap follows from federal classification. Some of it is Kalshi’s choice.

Peer prediction products sit in the same position, and FanDuel Predicts and DraftKings Predictions also start at 18. But both display a gambling helpline under the same federal framework. A monthly-only cap, no loss, stake or time tools, and no gambling helpline are things Kalshi could change without a state licence.S13

07Mention and attendance markets

Some contracts turn on what one person says, or whether someone shows up.

Insiders can know or control those answers. CFTC staff have said they “may view Mention Markets as presumptively readily susceptible to manipulation” (Staff Letter 26-27). That is a rebuttable staff view, not a Commission rule.S21

The category matters for this page because two of 2026’s disputes, the Correspondents’ Dinner and the Brad Pitt attendance market, fall in it. A CFTC settlement with an individual user over trading in such a market records that the CFTC “appreciates the assistance of KalshiEX”; the order is against the user, not Kalshi. Kalshi amended its mention-market terms between April and July 2026.S21S9

08How Kalshi has marketed itself

In 2025 it advertised “legal sports betting”. In court it argued it is not a sportsbook.

These are dated examples. Much of the most aggressive wording is historical, and Kalshi’s current owned language mostly says “trade” and “markets”. CHI did not comprehensively review current paid advertising, so this section does not say what today’s ads contain.

January 2025

Sponsored Instagram ads from Kalshi’s own account: “Sports Betting Legal in all 50 States on Kalshi”; “The First Nationwide Legal Sports Betting Platform.” Reproduced in a federal appellate dissent.S18

Kalshi ad · historical
September 2025

The latest dated “betting” ad CHI found, as reported; the ad itself was not seen.S18

Reported
Dec 2025 – Jan 2026

Kalshi-run sponsored ads with earnings framing: “that time I made $1000 just for being right about the weather”, and a TikTok ad unit with the on-screen line “I just found a money hack”.S18

Kalshi ad · income-style
Early 2026

A creator clip presented by Media Matters as a Kalshi ad: “2026 side hustle: predict the weather”, “make $35 repeat daily”. The wording is verified; who paid for its placement is not.S18

Creator clip
Kalshi’s response

Kalshi told Media Matters it “no longer works with any of the influencers in the advertisements featured”. Its 2026 brand campaign (“Trade on Anything”) carries no betting or earnings claims.S18

Changed
5 October 2026

Google Play listing: “Kalshi lets you bet on sports through live event contracts”. The Apple description says “It’s like trading stocks”.S4

Current

A Washington state court found, in an amended preliminary injunction of 12 August 2026, that “legal betting” ads “are likely to mislead a reasonable consumer”. That is a preliminary finding, not a final ruling. Federal appellate opinions at the preliminary-injunction stage have quoted the marketing, and the Ninth Circuit separately rejected an advertising claim over “legal in all 50 states”.S19S20

09Combos and perpetual futures

Two products to understand. Neither is a hostility finding.

Watch this · Combos

Parlay-style contracts priced by private quote

A user requests a price; members answer privately; the user sees the best quote for one to three seconds. Quoting firms are not shown, and each combo’s own order book is almost always empty. That is weaker pre-trade transparency than Kalshi’s single markets.S7

Against that: any eligible member may quote, completed trades are public, loss is capped at the price paid, and they are not structurally worse than a sportsbook parlay. They do cost more than single markets.S14

Normal market structure · Perpetual futures

A separate, leveraged product, walled off

Offered through an affiliated broker, Kalshi Prime, with its own agreement, application, experience questionnaire, mandatory tutorial and balance. Money moves only by manual transfer; the two balances “do not share funds and cannot affect each other”.S8

One watch item. The customer agreement says “You will be responsible for any deficiency remaining in your Account after liquidation”; a Kalshi help article says “the clearinghouse’s risk waterfall absorbs it”. The agreement governs. How deficits are handled in practice is not established.S8

11What this means if you use Kalshi

Transparent on price. Final on outcomes. Different from a sportsbook.

Know this

8 items
  1. K1You can lose everything you pay for a contract. On event contracts you cannot lose more than that plus the fee.
  2. K2Kalshi charges a fee when you take a listed price. The formula is published, and Kalshi’s own screenshots show the total cost, fee included, before you confirm. On 163 series, resting orders pay a smaller fee too.
  3. K3“% Chance” is a market price, not a guaranteed probability.
  4. K4You can sell early only if someone will buy at a price you accept. Kalshi does not set a buy-back price.
  5. K5The full rules decide the result, not the market’s title.
  6. K6Your money is held by Kalshi’s clearinghouse, not in a bank account in your name. FDIC insurance is “not guaranteed to you”, and SIPC does not apply.
  7. K7Buying through a broker app changes what applies. Kalshi’s break and exclusion tools do not cover that account, and fees round differently.
  8. K8Kalshi’s minimum age is 18. Most state-licensed sportsbooks require 21; this varies by state.

Watch this

10 items
  1. W1Combos are parlays. Every leg must win, the price is a private quote that lasts seconds, and they cost more than single markets. Your loss is capped at what you pay.
  2. W215-minute and hourly markets allow rapid repeat trading, with a fee each time. The one detailed public harm report involved these contracts.
  3. W3Buying, then selling at market, costs two fees plus the spread: about 9% of your stake at 50¢, about 32% at 5¢ (illustrative).
  4. W4Withdrawals are free, with no published minimum. New deposits can be held briefly; winnings are not. Complaints describe verification holds lasting weeks.
  5. W5A withdrawal can be suspended during an investigation with no stated time limit. Disciplinary action comes with written reasons, a hearing and CFTC review.
  6. W6Caps, breaks and exclusions cannot be lifted early. The cap is monthly only, no loss, stake or time limits are documented, and the helpline listed is 988.
  7. W7Perpetual futures are a different, leveraged product. Under the customer agreement you are responsible for any deficiency, although a Kalshi help article says otherwise. Access needs a separate application, questionnaire and tutorial.
  8. W8Don’t assume Kalshi is cheaper or dearer than a sportsbook. On busy NFL games in autumn 2026 it cost about the same as FanDuel and DraftKings, sometimes slightly less; combos cost more.
  9. W9Sign-up and referral offers appear in app-store listings, including for the leveraged product. Read the terms.
  10. W10What you can trade depends on your state and can change by court order. In Washington several categories are restricted, and existing positions can still be closed.

This is unusual

5 items
  1. U1Kalshi writes the contract, interprets it and settles it, and you cannot start a challenge to the outcome. In a few high-volume 2026 markets the wording, or a rule adopted after the event, decided the payout. Such disputes are rare by count.
  2. U2Disputing an outcome or a small sum means arbitration Kalshi convenes, with a $500 or $1,000 fee payable to Kalshi (the panel may award it back). The CFTC’s reparations program does not cover exchanges.
  3. U3Sportsbook protections do not carry over: age 21, state self-exclusion lists, loss and time limits, a gambling helpline. They vary by state. Kalshi gives other protections sportsbooks do not: no limiting of winning users was found, an open order book, and reasons for account action.
  4. U4Some markets turn on what one person says or whether someone attends. Insiders can know or control the answer, and CFTC staff have said they may treat mention markets as presumptively open to manipulation.
  5. U5In 2025 Kalshi advertised legal sports betting in all 50 states while arguing in court that state gambling law does not apply. Its Google Play listing still says “bet on sports”. Courts have reached different preliminary views; none is final.

12CHI pattern assessment

One pattern partly supported, narrowly. One weakly. Two not at all.

CHI tests every company against four recurring patterns of customer-economic change. Each is graded on its own evidence; none changed level in the second pass.

SP001Unmonetized access

Charging for something users already had.

Does not support

No previously free access was found to have been monetized.

SP002Existing-customer yield

Getting more from the same users.

Partially supportsNarrow

Maker fees now reach 163 series, and a combo maker fee began on 20 August 2026 after a CFTC self-certification. Against it, the headline taker rate is unchanged since 2022 and MLB fees were halved.S3

SP003Legacy deprioritization

Neglecting older products or users.

Weakly supports

The product mix is shifting toward perpetual futures, with margined products proposed. No user-facing retirement of an existing product was found.

SP004Regulated pass-through

Passing outside costs on to users.

Does not support

No pass-through of state taxes or regulatory costs was observed.

13Questions for the CHI taxonomy

Two concepts Kalshi raises. Neither has been adopted.

One company cannot show that a mechanism repeats. These are recorded as findings about Kalshi and as questions for the methodology. No pattern code has been assigned to either.

Candidate mechanism — taxonomy review

Settlement-Definition Asymmetry (restated)

Discretionary settlement of language-dependent contracts without a user challenge route.

The party that writes, interprets and settles a language-dependent contract is the same, and the user has no route to challenge the outcome. It would apply to any operator-settled contract product, not to Kalshi alone.

Candidate mechanism — taxonomy review

Regulatory-Protection Gap

When a product moves from one regulatory form to another, users lose protections the old form required. FanDuel Predicts, DraftKings Predictions, Robinhood and Polymarket US sit in the same position.

Any definition must be two-sided, counting protections gained as well as lost, and must separate what the form removes from what the company chooses to omit.

14Final CHI assessment

Kalshi offers users real advantages over a conventional sportsbook: visible prices, an open market to exit on, competitive costs on liquid single markets, no established limiting of winners and a published fee.

The weaknesses are specific. When a wording-dependent contract is disputed, Kalshi interprets it and settles it, and users cannot start a challenge. The formal route for outcome and small-money disputes is narrow and costly. And sportsbook protections do not reach sports-like contracts, partly by law and partly by Kalshi’s choice.

Why not a stronger finding? Because cost, exit, withdrawals and the treatment of winning users came out in Kalshi’s favour, no harm rate is measured, and every adverse ruling is preliminary. Why not a weaker one? Because the settlement, recourse and protection findings rest on Kalshi’s own rule text, regulator documents and verified cases.

Partially supportsLower end of the band · Bounded weaknesses, not systematic hostility · Standard company investigation · No score assigned · Research current through 5 October 2026

15Methodology and limitations

How this page was built, and how far it can be relied on.

Two passes

A baseline research dossier, then a verification and final adjudication pass that controls wherever the two differ. The second pass corrected the first in a number of places, several in Kalshi’s favour.

What was checked

Kalshi’s rulebook (v1.29), member and clearing agreements, help center and public API; court opinions and orders; CFTC orders, letters and handbook; state sportsbook rules for New Jersey, Pennsylvania, Massachusetts and Ohio; DraftKings and FanDuel terms.

How evidence was weighed

Rule text shows what Kalshi may do, not how often. User complaints were used as leads, not proof. Allegations are not treated as findings. Kalshi did not take part in this research and has not reviewed it.

Limitations

  • No live, logged-in inspection of the Kalshi app. No account was funded and no trade placed.
  • Interface findings rest on Kalshi’s own published screenshots, help-center images and current app-store listings, not on observed live screens.
  • Reddit, X and Discord were not reached in the second pass. No conclusion is drawn from their absence.
  • Cost comparisons rest on a limited set of published comparisons and spot checks of liquid NFL markets in September–October 2026.
  • FanDuel Sportsbook’s dispute terms were not resolved, so no comparison to FanDuel’s recourse is made here.
  • Three first-pass items are held from publication because they were not re-tested: a reported ratio of losing to winning users, Kalshi’s tax-form position, and its outage history.

16Sources

Every claim on this page traces to one of these.

Kalshi — rules, agreements, fees and product
S1

KalshiEX Rulebook v1.29: Rules 2.7, 2.8, 3.11, 5.3, 5.11, 6.3, 6.4, 7.1, 9.2, 9.6, Chapter 10 and 11.3. rulebook (PDF)First-party

S2

Kalshi Member Agreement (1 October 2026) and Kalshi Klear Self-Clearing Member Agreement: age of majority, custody, FDIC wording, liability. member agreement · Klear agreementFirst-party

S3

Fees: help-center fees article, API fee-rounding documentation and API changelog (maker-fee series, combo maker fee from 20 August 2026, MLB multiplier). fees · rounding · changelogFirst-party

S4

Order screens and listings: help-center articles with published screenshots (c. 2025), the order-book article, and the Apple and Google Play listings as read on 5 October 2026. order book · App Store · Google PlayFirst-party

S5

Deposits, withdrawals and custody: Transfers FAQ, card deposits, Klear disclosures; Gaming America on Super Bowl LX reimbursements (10 February 2026). transfers · card deposits · Klear disclosures · Gaming AmericaFirst-party; press

S6

Responsible use and age: Responsible Trading Hub (988, Birches Health), Voluntary Self-Exclusion, Signing Up as an Individual (“Be 18 years or older”). hub · self-exclusion · sign-upFirst-party

S7

Combos and request-for-quote: API documentation on RFQs and the public trade feed; Rule 5.3(b). RFQ docs · changelogFirst-party

S8

Perpetual futures: help-center articles on perps, access and the margin account; Kalshi Prime customer account agreement (14 September 2026) and risk disclosure. perps · access · margin accountFirst-party

Settlement cases and comparators
S9

Market records and filings: Kalshi public API records for the Yaccarino, Khamenei, Super Bowl LX performer, Brad Pitt and Correspondents’ Dinner markets; Kalshi’s rule filing of 28 April 2026; template amendments; The Block on Khamenei fee refunds (Kalshi’s account). Kalshi regulatory filings · The BlockFirst-party; press

S10

Kalshi calibration study: count of resolved markets to mid-2026. kalshi.com (PDF)First-party

S11

Comparators: CME Rulebook Chapter 8 (Rule 812); Nevada Revised Statutes 463.362–.363; Polymarket’s dispute process. CME · NRS 463 · PolymarketRules; statute

S12

CFTC Reparations Handbook (July 2026): reparations reach registered persons only; settlement complaints go to the exchange first. cftc.govRegulator

Sportsbooks, protections and users
S13

State rules and operator pages: N.J.A.C. 13:69O; 58 Pa. Code chapters 812a and 814a; M.G.L. c. 23N; Ohio Adm. Code 3775-16; DraftKings and FanDuel responsible-gaming pages and house rules; DraftKings Predictions terms. FanDuel · DraftKings · DraftKings PredictionsRegulation; operators

S14

Cost comparisons: Citizens weekly NFL pricing as reported by RotoWire and InGame (September 2026); OddsShopper’s fee-inclusive comparison; a CHI same-minute spot check of 15 NFL games on 5 October 2026. RotoWire · InGame · OddsShopperPress; CHI analysis

S15

CNN, 28 May and 28 August 2026: Kalshi’s figures for the 18–21 share of volume, as republished. May · AugustPress

S16

NPR, 2 October 2026, on state self-exclusion databases, as republished by KPBS; SelfExclude.io; Robinhood’s event-contract help. NPR / KPBS · SelfExclude.io · RobinhoodPress; third party

S17

Winning-user treatment: Massachusetts Gaming Commission staff memo (30 September 2025) on account limiting; trade-press reporting on professional users of Kalshi. report on the memoRegulator; press

Marketing, courts and regulators
S18

Advertising record: Third Circuit opinion with dissent reproducing 2025 Kalshi ads; Media Matters (30 March 2026); Truth in Advertising (7 May 2026). Third Circuit · Media Matters · TINACourt; press

S19

Washington: King County Superior Court amended preliminary injunction, 12 August 2026, as announced by the state Attorney General. atg.wa.govCourt; state

S20

Appellate opinions: Third Circuit No. 25-1922 (6 April 2026); Ninth Circuit No. 25-7516 (28 August 2026) and No. 25-7504 (16 September 2026); Sixth Circuit Nos. 26-3196/5235 (25 September 2026). Third · Ninth (PDF) · Sixth (PDF)Courts

S21

CFTC: Staff Letter 26-27 (22 September 2026), a Division of Market Oversight staff advisory on mention markets that states it represents only the views of staff, not the Commission; order staying Kalshi’s Michigan emergency rule (14 July 2026); settled orders In re Perez and In re Santos. Letter 26-27 · Michigan stay (PDF)Regulator

S22

Massachusetts: Attorney General’s action and the stay of the preliminary injunction (17 February 2026). mass.govState

S23

Litigation status: consolidated class action in the Southern District of New York (order of 16 April 2026 on discovery before an anticipated motion to compel arbitration); Illinois ruling of 2 October 2026 (N.D. Ill., as reported by DeFi Rate); public litigation trackers. Illinois report · trackerCourts; press

The complete research dossier and verification report, with their evidence ledgers and register of points withheld from publication, are preserved by CHI and are not reproduced here. Quotations were read on or before 5 October 2026 and may change. Kalshi and related marks belong to their owners; the name is used only to identify the company, and no endorsement or affiliation is implied. This page is research, not legal or financial advice.

Reading this beside the rest of the index

Every company here is assessed against the same question. On Kalshi, the answer depends on where you look.

This page carries a disposition and no score. Read it alongside the methodology and the other Finance assessments.