Reporting Requirements and Transparency

Under the CFTC regulations, licensed exchanges like Kalshi are required to report – both publicly and to the CFTC – a number of specifics about trading and financial activity on the exchange. These provisions allow the general public to view trading data on exchanges and report potential flags or suspicious activity to exchanges, regulators, or law enforcement.

Core Principle 7, codified in 17 CFR 38.400-01, requires registered exchanges like Kalshi to make available to market authorities, market participants, and the general public accurate information concerning:

• Terms and conditions of the contracts listed on contract markets
• Rules, regulations, and mechanisms for executing transactions on or through the facilities of the contract market
• Rules and specifications for describing the operation of the market, including electronic matching systems and trade execution facilities

Core Principle 8, codified at 17 CFR 38.450-51, requires that each licensed exchange make public daily information on settlement prices, volume, open interest, and opening and closing ranges for actively traded contracts on the exchange. When reporting this information, Kalshi must comply with dozens of requirements spelled out in 17 CFR 16.01, which details many requirements for the publication of market data.

Additional regulations, codified at 17 CFR 43.3, require licensed exchanges to report swap transactions as soon as technologically practicable after execution. The same section requires public dissemination of transaction and pricing data by data repositories in real time.

Core Principle 18, codified at 17 CFR 38.950, requires each licensed exchange to maintain records of all activities relating to the business of the exchange for a period of at least five years. These records must be maintained consistent with requirements set forth in 17 CFR 1.31, which outlines specific standards for maintaining electronic regulatory records, retention practices, and the right of the CFTC and Department of Justice to inspect any records at any time.