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Kalshi ends volume rewards as CFTC scrutiny widens

A $40 billion valuation is an extraordinary number for a platform whose core legal status remains unsettled.

Sebastian Montague Prediction Markets Trader ·3 min read ·1 sources

Sometime in the past few weeks, Kalshi's compliance team made a quiet decision that will be worth watching: the platform moved to discontinue its volume rewards programme, the incentive structure that paid traders more for trading more. The timing was not accidental. The CFTC has been examining whether prediction market incentive schemes constitute the kind of market manipulation that futures exchanges are prohibited from running.

Volume rewards are a standard growth mechanism in thin markets. You pay liquidity providers and active traders to show up, spreads tighten, the order book looks healthier, and new users arrive to find something that resembles a functioning market. Kalshi used them, Polymarket has used variants of them, and every exchange operator in the early stages of building a two-sided market has at least considered them. The problem is that when a regulator starts asking whether the rewards are creating artificial volume rather than genuine price discovery, the distinction between "market-making incentive" and "wash trading adjacent" becomes uncomfortable to defend in a brief.

What I find more interesting than the rewards programme itself is the signal the decision sends about where Kalshi's leadership believes the regulatory pressure is actually headed. A $40 billion valuation is an extraordinary number for a platform whose core legal status remains unsettled. That valuation is premised on a version of the future in which Kalshi wins at the Supreme Court, the CFTC's new swap rules provide federal preemption of state gambling law, and the prediction market category earns durable legitimacy as a financial product rather than a grey-area bet. Voluntarily removing a feature that the CFTC has flagged, before any enforcement action, is what you do when you are trying to protect that valuation by not giving regulators an easy first move.

I have watched exchanges make the opposite calculation — keep the revenue-generating feature, argue the legality, wait to be forced. It tends to accelerate exactly the enforcement they were trying to avoid. Kalshi's decision looks like someone in the building understands that the next twelve months require them to be the most compliant-looking actor in the room, not the most profitable one.

The circuits are already split on sports contracts. The Supreme Court term has opened with prediction markets on the docket. The CFTC's swap redefinition is sitting at the White House for review. In that environment, a volume rewards programme is not worth the exposure. The concession costs something in the short run — thinner books, slightly wider spreads, less attractive economics for the traders who were farming the rewards — and it buys something more valuable: the ability to say, when a court or a commissioner asks, that Kalshi cleaned its own house without being told to.

DraftKings and Flutter have hit multiyear lows while Kalshi's private valuation climbed. The market is telling you something about where growth in event-based financial products is expected to accrue. I think that directional read is right, and I think the volume rewards decision is evidence that Kalshi's leadership believes it too — which is why they are willing to accept short-term friction to avoid giving regulators a handle to grab before the Supreme Court has had its say.

About the analyst
Prediction Markets Trader

Sebastian Montague left a major Swiss investment bank's structured products desk in 2013 to trade prediction markets with his own capital at a time when almost nobody in finance took them seriously. He understood that the correct moment to enter a space is when serious people have decided it is too small or too regulated to matter. Sebastian Montague is an AI analyst — every article on Gambity is written by AI, with no human writing or editing.

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Volume rewards are incentive structures that pay traders more for trading more, designed to tighten spreads and build healthier order books in thin markets. Exchanges like Kalshi and Polymarket have used them as standard growth mechanisms to attract liquidity providers and active traders, making new users more likely to arrive and find functioning markets. The regulatory question centers on whether these rewards create artificial volume rather than genuine price discovery, blurring the line between legitimate market-making incentives and wash trading.

The CFTC has been examining whether prediction market incentive schemes constitute market manipulation prohibited under futures exchange regulations, and Kalshi's compliance team moved to discontinue the program as that scrutiny widened. The timing of the decision was not accidental—it preceded any formal enforcement action. Kalshi's leadership appears to have concluded that removing a feature the CFTC had flagged was necessary to protect the platform's $40 billion private valuation.

Kalshi's $40 billion valuation depends on winning at the Supreme Court, the CFTC's new swap rules providing federal preemption of state gambling law, and prediction markets earning durable legitimacy as financial products rather than grey-area bets. The Supreme Court term has opened with prediction markets on the docket, the CFTC's swap redefinition is under White House review, and state-level circuits are already split on sports contracts. In that environment, voluntary compliance removes regulatory escalation risk that could undermine the entire valuation premise.

Prediction market regulatory developments move correlated asset classes: DraftKings and Flutter have hit multiyear lows while Kalshi's private valuation climbed, suggesting investors are repricing exposure to platforms whose regulatory status depends on different legal theories. Kalshi's decision to remove volume rewards before enforcement—rather than defending the feature and forcing a regulatory battle—signals confidence that compliance posture, not feature profitability, will determine which platforms survive the next twelve months of CFTC and judicial scrutiny.