RFL/01 · Paper 03 · Rev. D
RISKSMART INTELLIGENCE — RFL/01
Vol IV·Paper 03·Rev. D·May 2026·LIVE

YES/NO

The Market Structure of Prediction & Event Markets, 2024–2029.

The rise of information finance — and its first liquid instrument.

A two-year reckoning, and a three-year wager.

In twenty-four months a fringe curiosity priced its way into the financial plumbing. Who built the rails, who is fighting over them, and where the whole thing is pointed next.

SCROLL
The Thesis

Everyone assumed the old infrastructure was permanent.

It never is. The sportsbooks spent a decade and a fortune assembling state-by-state licenses, convinced the patchwork itself was the moat. The exchanges assumed event contracts were a novelty act. The regulators assumed they could simply decline to engage. Each was proven wrong on roughly the same timetable, and for the same reason.

A prediction market is a deceptively boring thing: a contract that pays a dollar if something happens and nothing if it doesn't. Price it between zero and a hundred cents and you have read a probability straight off an order book. That mechanism is older than the people now getting rich from it. What changed in the last two years was not the instrument. It was who was allowed to list it, who decided to clear it, and which regulator was willing to plant a flag.

The contract didn't get more sophisticated. The wrapper around it did — and the wrapper is the entire fight.

This paper does two things. It walks the last two years — the regulatory inversion, the capital flood, the venue scramble, the arrival of the incumbents — participant by participant, because market structure is a story about who occupies which seat. Then it carries the picture three years forward, with the usual caveat that anyone forecasting this industry in 2024 was wrong, and probably modestly so.

Abstract

Between early 2024 and mid-2026, U.S. prediction markets went from a single contested venue trading election contracts to a multi-venue, vertically integrating sector that cleared roughly $44 billion of global volume in 2025 and $29.8 billion in April 2026 alone — with the New York Stock Exchange's parent, the country's largest derivatives exchange, both major sportsbooks, and a Coatue-led $22 billion Kalshi round all inside the stack. The decisive variable was never product. It was jurisdiction: the moment the CFTC chose to treat event contracts as its exclusive province, the federal derivatives wrapper became a way to route around fifty separate state gambling regimes with a single license. Institutions remain on the data more than in the book — estimated under 5% of open interest — but the sell side has begun to stir. The fight that remains — federal preemption versus state police power, now across 19 federal lawsuits with a circuit split forming — is the single largest determinant of the structure that exists in 2029.

$44B
Global sector volume, 2025
$29.8B
Volume in April 2026 alone
~87%
Share of Kalshi's trailing-year volume in sports
19
Federal lawsuits · 38 state AGs filed amicus

Sources: RiskSmart Intelligence global-regulation tracking (Dune Analytics / DeFi Rate); WSJ / CoinDesk / PYMNTS on funding; Congressional Research Service; Holland & Knight, Norton Rose Fulbright; CNBC; Reuters. Figures are point-in-time and move weekly. (An alternative Kalshi+Polymarket-only compilation puts 2025 throughput nearer $63.5B; the $44B figure is the broader sector-tracked number used across this series.)

Part I — The Two Years Back

From one courtroom to the whole street.

The transformation has a clean arc: a regulator stops fighting, capital notices, the product finds its real demand in sports, the venue licenses become trophies, and the incumbents arrive last — as they always do.

The starting point: a single venue, openly resisted

In the first half of 2024, the sector was essentially one disputed exchange and a crypto platform that claimed to block U.S. users. Kalshi was litigating the CFTC for the right to list election contracts at all — a fight it won in the D.C. Circuit, the foundational federal precedent that election contracts are not “gaming.” The Commission, under its prior leadership, went the other way: in June 2024 it proposed a rule branding political and sports event contracts “contrary to the public interest.” The rule was never finalized. That non-finalization became one of the most consequential events in the sector's history.

The one early sign of where this was heading came in April 2024, when Susquehanna International Group — one of the largest options market makers in the world, an entire firm built around pricing probabilities — became the first major financial institution to publicly make markets on Kalshi. The mechanics were familiar. The spreads were absurdly wide. There was nobody else there.

The inversion: the regulator changes sides

The 2024 election cycle proved the demand; the change in administration changed the posture. On January 29, 2026, CFTC Chairman Michael Selig withdrew the Biden-era proposed ban, vacated a 2025 staff advisory, and directed new “clear standards” rulemaking — calling the prior posture “a frolic into merit regulation.” By February the Commission had replaced posture with doctrine: event contracts are swaps, swaps are federal, and the states are intruding.

“Truth machines. They create accountability, transparency, and information.”
CFTC Chairman Michael Selig · FIA Boca · March 10, 2026

The classification that did the work

If a sports event contract is a “swap” under the Commodity Exchange Act, it is federally regulated and — the CFTC argues — shielded from state gambling law by preemption. That single classification lets a platform offer what looks, smells, and pays out like a sports bet in states that never legalized sports betting, under one federal license instead of forty separate state ones. The entire 2025–26 scramble is downstream of that sentence.

The capital flood

Once the legal ambiguity began to clear, the money arrived at a pace that embarrassed every prior estimate.

Apr 2024
Susquehanna onto Kalshi
First major institutional market maker commits to the order book. Proof the mechanics are tradeable by a serious firm.
Jun 2024
CFTC proposes to ban the category
Political and sports event contracts deemed “contrary to the public interest.” The rule is never finalized — and that gap becomes the doorway.
Nov 2024
The election cycle proves demand
Election contracts trade at scale. Prediction markets enter mainstream financial conversation; the regulatory mood begins to turn.
Early 2025
Sports contracts go live on regulated venues
A shift in CFTC posture lets DCMs list sports event contracts. This, not politics, becomes the volume engine — eventually ~87% of the leader's flow.
Jun–Oct 2025
Kalshi's funding ladder: $2B → $5B
$185M at $2B (Paradigm), then $300M at $5B (a16z, Sequoia). The venture establishment commits.
Oct 2025
ICE backs Polymarket; the scramble begins
Intercontinental Exchange commits $2B to the sector, ~$600M directly into Polymarket near a $9B valuation. Polymarket acquires CFTC-registered QCX for compliant U.S. re-entry; DraftKings acquires Railbird. Exchange licenses become acquisition targets.
Dec 2025
Brokerages and sportsbooks enter at once
Robinhood unveils its Prediction Markets Hub (“YES/NO”); DraftKings Predictions launches across 38 states via CME; FanDuel Predicts launches with CME. The retail front opens.
Jan–Feb 2026
The legal war goes hot
Selig withdraws the 2024 rule and declares “exclusive jurisdiction.” Tennessee grants Kalshi a preliminary injunction; Polymarket counter-sues Massachusetts on preemption (Feb 10). Jump Trading reportedly takes equity stakes in both leaders for liquidity.
Feb 12 2026
The Fed validates the data
Federal Reserve staff publish “Kalshi and the Rise of Macro Markets,” finding prediction-market prices forecast Fed moves on par with — or better than — Bloomberg consensus, the NY Fed survey, and fed funds futures.
Mar 2026
The incumbents stop mimicking and start building
CME self-certifies election contracts (a Duffy U-turn) and crosses $100M in eight weeks; Cboe files a patent-pending three-outcome contract; Nasdaq files for Nasdaq-100 binaries. At FIA Boca, Kalshi's CEO sits as an equal beside CME, Nasdaq, Deutsche Börse and SGX. Underdog buys Aristotle.
Apr–May 2026
Preemption holds; a circuit split forms; Washington stirs
The Third Circuit (2–1) finds sports contracts are likely preempted swaps; Maryland's state court rules them “indistinguishable” from wagering, triggering a 38-state amicus brief. The 9th Circuit's consolidated Nevada cases (Kalshi's being KalshiEX v. Hendrick) — where the court below found sports contracts are not swaps — loom as the split-defining ruling. CFTC sues Arizona, Connecticut, Illinois, then Rhode Island. Three bills circulate; the White House reviews the rule; the President backs the CFTC.
May 7 2026
Kalshi closes a $22B Series F
Coatue-led, with Sequoia, a16z, IVP, Paradigm — and Morgan Stanley, a bank now on the cap table. Revenue run-rate reported approaching $1.5B. Polymarket reportedly raising near $15B.
Signal from the field · Podscan intelligence

The shift from retail experimentation toward institutional relevance is now a topic on the volatility podcasts the buyside actually listens to. On Dean Curnutt's Alpha Exchange (May 11, 2026), the conversation turned to prediction markets tied to elections, Fed policy, GDP, inflation, and geopolitical outcomes — framed explicitly as moving from retail experimentation toward institutional relevance, with Kalshi as the reference venue and the discussion's sentiment on the category running net positive.

That is the tell: prediction markets have migrated from the gambling press into cross-asset volatility conversations among risk professionals. The retail plumbing already exists; the institutional analytical layer — mapping event probabilities into pricing, risk, and reset workflows — is the part that still doesn't exist at scale. That gap is the opportunity.

The shape that emerged

By spring 2026 the sector had four things it lacked two years earlier: a federal regulator actively defending it in court, an incumbent exchange complex (ICE, CME, now Cboe and Nasdaq) inside the tent, a retail distribution layer reaching tens of millions of accounts, and a structural enemy — the states, the sports leagues, the tribes, federal prosecutors, and a growing bipartisan bloc in Congress — large enough to put the whole thing at risk. That tension is the market structure. Everything below is who sits where inside it.

Why It Matters

This stopped being about election betting.

Before the history, the question every institutional reader is entitled to ask: why should an exchange, a bank, an asset manager, or a risk desk care about a market that still trades mostly Super Bowl contracts?

Because what is actually being built here is a new financial function, and it has a name now — information finance: the business of turning information into a priced, tradeable, hedgeable instrument. Susquehanna and DRW already staff desks under that banner; what the category lacks is not participants but a definition. Prediction markets are simply its first liquid instrument. Seen that way, the contract is quietly becoming four things at once, only one of which is entertainment:

That is the lens for everything that follows. The history matters because it explains how a fringe instrument acquired federal infrastructure; the infrastructure is why the instrument now lands on the desks of people who have never placed a bet in their lives.

The Missing Question

What event contracts measure that options can't.

The fair challenge: we already have futures, options, CDS, fed funds futures, election ETFs, and structured products. What does a binary event contract measure that those don't?

The distinction is the whole pitch for information finance: options give you volatility; information finance gives you the probability itself. Explicit probability, cleanly, on events the existing toolkit prices only indirectly or not at all. An option encodes a probability distribution over a continuous price, entangled with volatility, time, and rates — you can back out an implied probability, but you are inferring it, not reading it. A prediction contract is the probability: a price of 38 cents is a 38% chance, full stop. And it extends to exogenous, non-financial events — a specific election outcome, a rate decision on a named date, a geopolitical trigger — that no clean listed instrument covers.

InstrumentWhat it actually measures
Polls / surveysStated opinion, no money at risk, slow to update
FuturesDirectional economic exposure to a continuous price
OptionsVolatility and a distribution — probability only by inference
CDSDefault probability, but only for credit events
Prediction / event contractsExplicit probability of a discrete, named outcome — including non-financial ones

That is the intellectual foundation for institutional interest. Not that event contracts replace the derivatives complex — they fill a specific hole in it: a clean, tradeable, centrally-cleared probability on the discrete events that move portfolios but resist the continuous-payoff instruments built for prices.

Exhibit A — The Information Finance Desk of the Future

The information finance desk of the future.

Before the history, the endpoint. An information finance desk is a machine for transformation: information, client demand, and capital flow in; the desk prices, risks, makes markets, and settles; liquidity, structured products, signal, and captured spread flow out. Each particle is a unit of flow, colored by what it is. Hover a node for its role; filter by stream to trace one path. This is the institutional shape everything else in the paper is moving toward.

Inflows → the desk → outflows · live throughput
initializing…
hover a node · ~4,000 particles
An information finance desk turns information into priced risk, and priced risk into revenue. The five outflows on the right map one-to-one to the desk's five fee pools.

Illustrative architecture; particles are a visual abstraction of flow, not measured volume. The five outflows map one-to-one to the dealer-economics fee pools: market-making spread, structured products, data/signal, financing & cross-margin, and captured P&L.

The desk is a function: information in, priced risk out, spread captured on the transformation.
Exhibit B — The Liquidity Migration

Watch the plumbing re-route.

Everything above is described in prose; here it is as flow. Read left to right — who is trading, how they reach the book, who is on the other side. Today it is almost one color: retail, through direct accounts and brokerage apps, matched by market makers. Press play, and watch the ribbons that barely exist today — FCM connectivity, RFQ and block, dealer liquidity — widen year by year. Toggle Notional $ to see the second truth: even as retail's share falls, the book grows, so retail flow keeps rising while the pie expands around it.

Order flow · 2025 → 2029
Sector ≈ $44B
2025You are here
Who trades
How they access
Who's on the other side
illustrative · share of flow

Who trades

Who provides liquidity

Flow shares are illustrative and directional, calibrated to the structure in this brief rather than to reported volumes. The notional path ($44B in 2025, anchored to the ~$29.8B-per-month April 2026 run-rate and scaled forward) is an illustrative trajectory, not a forecast.

Market makers don't lose the book. They stop being the whole book.
Part II — The Stack

Who occupies which seat.

Market structure is seating. A prediction-market trade now passes through a layered stack — a venue to list it, a clearinghouse to guarantee it, a broker to access it, a market maker to price it, demand to take it, and vendors to wire it together. The defining move of 2025–26 was firms racing to own more than one layer at once.

Traderwho takes the position
RetailHedge fundsMarket makers · SIG, Jump, DRWBanks
Broker / accesshow the order reaches the book
RobinhoodIBKRFCMsRFQ / block desks
Venue · DCMwhere it lists & matches
KalshiPolymarketCMECrypto.com / CDNACboe · Nasdaq
Clearing · DCO & marginwho guarantees & margins it
CME ClearingCDNAICE · capitalFCM margin
Settlement / resolutionwho decides what happened
OraclesSurveillance · PalantirIntegrity tooling
Data distributionwhere the price becomes a signal
BloombergGoogleLSEGthe Fed

The vertical stack a single event-contract trade passes through, with representative occupants. The 2025–26 contest is firms racing to own more than one adjacent layer — ICE buying into clearing-and-venue, CME renting venue-and-clearing to sportsbooks, Robinhood building its own venue (Rothera) rather than renting Kalshi's.

The land-grab, measured in license applications

The clearest gauge of the rush isn't the valuations — it's the queue at the regulator. Since early 2025 the CFTC has taken in 17 applications for new designated contract markets; roughly seven were approved and about ten are still pending as of March 2026, with review now running up to six months. And the line keeps lengthening — Smarkets (the UK betting exchange), Bullish (the NYSE-listed digital-asset platform, filing for a clearinghouse alongside), and DimeTrades all filed fresh DCM applications in the weeks after that count. A federal exchange license — once a rarity held by a handful of incumbents — is now something dozens of firms are queuing for, because it is the single key that unlocks fifty states at once.

The rising vertical — one trade, one ownership tent
Robinhood × Susquehanna × Rothera
The most complete vertical integration in the sector, and the one to watch. The distributor and its own market maker jointly own the venue — so a single contract can be sourced, matched, and quoted inside one cap table. This is the Coinbase-style stack assembled not by one firm, but by a three-party alliance.
Distribution
Robinhood45%
tens of millions of retail accounts; the order flow
×
Liquidity
Susquehanna45%
the market maker pricing and quoting the book
×
The license / venue
Rothera10% MIAX
the CFTC venue (ex-LedgerX / MIAXdx), self-certifying contracts
The closed loop: Robinhood routes the flow it owns into a venue it co-owns, where SIG — its own market-making partner — provides the liquidity. Source → match → make markets, all inside one tent — and it lets Robinhood stop renting Kalshi's rails and capture the venue economics itself.
Pure-play venue / DCM
Kalshi
The CFTC-regulated incumbent. Won the election-contracts fight, pioneered legal sports event contracts, and is now the litigation lightning rod and volume leader.
Status: $22B Series F closed May 7 (Coatue, Sequoia, a16z, IVP, Paradigm, Morgan Stanley) · ~87% sports · ~$52B cumulative contracts · 19 federal suits · 200+ internal investigations, two insider-trading referrals.
Venue / dual structure
Polymarket
The crypto-native challenger. Large offshore order book plus an acquired CFTC-registered exchange (QCX) for compliant U.S. re-entry — a deliberate dual onshore/offshore design. Palantir partnership for sports-betting surveillance.
Status: ICE ~$600M of a $2B sector commitment · reportedly raising near $15B · counter-sued Massachusetts on preemption Feb 10.
Full-stack venue (DCM + DCO + FCM)
Crypto.com / CDNA
The only platform holding the complete regulatory stack — exchange, clearing, and brokerage. Sells that infrastructure to others rather than only trading on it.
Powers: Fanatics, Truth Predict, Hollywood.com; added DraftKings player props Feb 2026. The “exchange-as-a-service” play.
Incumbent exchange-for-hire
CME Group
The world's largest derivatives exchange, repositioned as the neutral venue behind the sportsbooks. Self-certified election contracts in March 2026 — reversing CEO Terry Duffy's earlier resistance.
Backs: FanDuel Predicts, DraftKings Predictions. Crossed $100M in eight weeks. Piper Sandler: the FanDuel JV alone could exceed $300M revenue at scale.
Incumbent exchanges — structural plays
Cboe · Nasdaq · Eurex
The exchanges that stopped mimicking the format and started innovating on it. Cboe filed a patent-pending three-outcome contract; Nasdaq filed with the SEC for Nasdaq-100 binaries; Eurex is reportedly weighing entry — which would be Europe's first major exchange treating event contracts as derivatives.
Read: the incumbent complex now competes on contract design, not just distribution. The category has graduated.
Convert-and-clear / license layer
Railbird · Aristotle · QCX · Sporttrade
Small DCM (and often DCO) approvals that became prized acquisition targets. Sporttrade is abandoning state sportsbook licenses to become a federal exchange and clearinghouse outright.
Acquired: QCX→Polymarket, Railbird→DraftKings, Aristotle→Underdog. The license itself is now the asset.
Clearing / FCM rails
The clearing question
Event contracts on DCMs clear through DCOs; access runs through FCMs and introducing brokers. The 2025–26 pattern was vertical integration — buyers acquiring DCM and DCO together to own exchange and clearing in one move.
Open gap: the large traditional FCMs — bank-owned clearers, StoneX and peers — have mostly not stepped in to clear retail event flow at scale. Marex is the exception (see sell side). A structural vacancy.
Market maker / liquidity
Susquehanna (SIG)
First major financial firm to make markets on Kalshi (April 2024). An options house treating event contracts as familiar probability-pricing with anomalous spreads. Standing up dedicated “Information Finance” desks in Philadelphia and Dublin.
Now: 45% co-owner of Rothera (see the vertical above) — SIG both makes the markets and owns the venue it makes them on.
Market makers / Information Finance
Jump · DRW · Jane Street
The quant and HFT cohort. Jump reportedly took stakes in both Kalshi and Polymarket for liquidity; DRW is standing up an Information Finance desk alongside SIG's, treating event probability with HFT rigor. Hunting cross-venue arbitrage, not directional bets.
Edge: siloed venues, fragmented liquidity — arbitrage everywhere, near-zero competition from equities-trained algos. For now.
Sportsbook as market maker
Flutter
Rather than build a retail exchange, Flutter monetizes its pricing infrastructure as a market maker across third-party platforms — selling the one thing sportsbooks are genuinely good at: setting odds.
Model: pricing engine for hire, not a standalone venue. A hedge against its own disruption.
Buy side / real money
Hedge funds
Present but quiet. Saba's Boaz Weinstein frames event contracts as a precise hedging tool — offsetting discrete-outcome risk to size other positions more confidently. Most use the data as a laboratory more than a venue.
Constraint: liquidity ceiling. A $100M hedge can move a contract 20–50%. Institutional share of open interest is estimated under 5%.
Sell side / banks & brokers
The sell side starts to stir
The dog has begun to bark. Marex issued the first prediction-market bond — a $10M structured note paying 7% if Nvidia stays #1 by market cap, principal-protected, hedged via Kalshi — and is building a PM structured-products line. Goldman's CEO confirmed the bank is exploring the space; its research desk already used Polymarket to model Strait of Hormuz closure odds. Morgan Stanley sits in Kalshi's Series F.
Still missing: a bulge-bracket principal desk or client-facing event-contract franchise. The first one is the signal the category has entered core capital markets.
Retail distribution / organic venue
Robinhood & Rothera
The mass-market on-ramp, and now a venue owner. Robinhood began by featuring Kalshi contracts on a revenue split, then co-built Rothera with SIG and MIAX (45/45/10; see the vertical above) — capturing venue economics and cutting its dependence on the rails it helped popularize.
Scale: 2.5B event contracts in Oct 2025 alone; Kalshi once 25–35% of volume. Interactive Brokers and DriveWealth also embedding event contracts.
Sportsbook → exchange
DraftKings & FanDuel
The incumbents most exposed to disruption, hedging by becoming participants. Both launched CFTC-regulated prediction products (via CME, then CDNA), reaching states where sports betting was never legalized.
DraftKings: own exchange via Railbird + CME + CDNA player props. FanDuel: CME JV (“Predicts”). Underdog: bought Aristotle.
Data vendor / distribution
Bloomberg · Google · the Fed
The legitimizing layer. Event probabilities now sit on the Bloomberg Terminal and Google Finance beside the VIX and the yield curve — and the Federal Reserve's own staff have validated the data's forecasting quality.
Effect: event-contract prices treated as a macro feed — faster than wires, increasingly arbitraged against CME FedWatch and rate futures.
Tech vendor / integrity
Matching, oracles, surveillance
The unglamorous middle. Exchange tech, settlement oracles (who decides what actually happened), market-surveillance and integrity tooling (Polymarket's Palantir tie-up; Kalshi's 200+ internal investigations), KYC, and the routing that lets a brokerage front a third-party venue.
Pressure point: resolution & integrity. Disputed settlements and insider-trading concerns are the operational risk that scales fastest.
The data-as-alpha layer
Quant data shops & bots
Firms and tooling that treat the order book as a calibration surface — empirical Kelly sizing, bias detection, order-flow analysis — to inform positions in far larger traditional markets.
Thesis: the prediction market is the lab, not the trade. The value is the signal extracted, not the contract held.

Cards synthesize RiskSmart Intelligence tracking and public reporting (Reuters, CNBC, WSJ via CoinDesk/PYMNTS, Finance Magnates, DeFi Rate, CRS) as of late May 2026. Roles are analytical, not legal designations.

The dealer economics

Banks do not enter markets because they are interesting. They enter because there is revenue, and the revenue case has now appeared in pieces. The event-contract stack offers a dealer at least five identifiable fee pools, several already live:

Revenue lineStatus & who is moving
RFQ / block spreadsThe institutional-size channel; the natural home for Tradeweb- and MarketAxess-style protocols as blocks arrive
Structured products & event-linked notesLive — Marex issued the first $10M prediction-market note (7% if Nvidia stays #1)
Prime brokerage & financingMargin, leverage, and cross-margin against futures — the FCM-adjacent opening
Market makingSIG, Jump and DRW already run it; a bank principal desk is the open question
Data monetizationSelling the probability feed and the surveillance / resolution data as a product

This is where Goldman (confirmed exploring), Morgan Stanley (on Kalshi's cap table), Marex (already issuing), and eventually BNP, Jefferies and BofA become part of the story — not as enthusiasts, but as desks chasing identifiable fee pools. The sell side enters when the spreadsheet works, and the spreadsheet is starting to.

Part III — Fault Lines

Five places where the structure could crack.

A market structure is defined as much by its unresolved questions as by its participants. These are the five that will decide which 2029 actually arrives.

Three things that could kill the thesis

  1. The Supreme Court rejects federal preemption.Sports contracts get pushed back inside the state gambling perimeter; the federal-wrapper advantage — the whole edifice — collapses.
  2. A major insider-trading or resolution scandal.The Iran bet was a warning shot. One large, provable information-abuse case turns a regulatory debate into a criminal one and freezes institutional entry.
  3. A retail speculation bubble that bursts in public.A visible boom-and-collapse hands every opponent — leagues, states, Congress — the political cover to legislate the category back to the margins.

Those are the existential ones. The five fault lines below are the structural pressures that determine which 2029 arrives short of outright death:

Calibrating the binary: where the desk economics actually live

Risk management here is not a configuration change to the options stack; it is a different methodology, because the payoff is binary and the question shifts from “how wide is the spread” to “how accurate is the price.” Two features of these markets are, properly handled, profit centers rather than hazards.

The spread benchmark. Execution cost stratifies cleanly by liquidity, and a desk needs to price the tier it is actually trading: roughly 1–2¢ on flagship high-profile contracts (major elections, marquee sports), 3–5¢ on moderate markets (a specific Fed decision, mid-cap crypto levels), and 10¢+ on thin or stale books where the midpoint is an unreliable signal. The trap is confusing quoted with effective spread: in a thin book a large order sweeps levels, so the cost of size runs well above the screen. This is the same block-versus-CLOB problem from the scale exhibit, priced.

The favorite-longshot bias. Prediction markets inherit a systematic, well-documented mispricing from a century of betting-market data: longshots (around 5¢) are chronically overpriced and heavy favorites (around 95¢) chronically underpriced, because retail overpays for tail lottery tickets. For a calibrated desk this is not noise — it is harvestable edge: sell the overpriced tails, hold the mathematically superior side, and treat calibration accuracy itself as the product. It is the clearest example of why information finance rewards a pricing discipline the retail order book does not have.

The sportsbooks once believed the state-by-state moat protected them. It turns out the moat was a map of exactly where the federal wrapper could route around them.
Part IV — The Three Years Forward

2026 → 2029, in three colors.

Forecasting this sector is a humbling exercise; the people who tried in 2024 undershot reality. So this is framed as three states of the world rather than a point estimate — with the honest admission that the probabilities below are judgment, not measurement.

Before the scenarios, a discipline worth stating plainly — separating what is observed from what is reasoned from what is wagered:

BucketExample from this paper
Observable$29.8B traded in April 2026; 17 DCM applications filed since early 2025; ICE's $2B commitment
InferenceSports likely remains the dominant category through 2028; institutional share stays sub-10% until depth arrives
ScenarioA full-stack market could exceed $2T of annual volume by 2030 — a conditional path, not a forecast

The scenarios below are the third bucket. They are deliberately framed as states of the world, with probabilities that are judgment, not measurement.

Managed federalization

~50% — most likely

Preemption broadly holds but messily. The Supreme Court eventually clarifies that CFTC-registered event contracts are federal instruments, while carving room for state consumer-protection and integrity overlays. Congress passes a narrow framework — the most sensitive categories restricted, the rest legitimized. The sector consolidates into a handful of vertically integrated stacks.

Venues
Consolidation to 3–5 serious DCM stacks. Kalshi and an ICE-backed Polymarket lead; CME, Cboe and Nasdaq are the incumbent backbone. License arbitrage ends as everyone owns their own.
Clearing / FCMs
Vertical integration is the norm; a traditional FCM or two finally enters to clear institutional flow — Marex's structured-products line is the template — signaling that real-money capital can size up.
Market makers
Spreads compress as SIG, Jump, DRW and Jane Street scale Information Finance desks. Cross-venue arbitrage matures into a recognized strategy.
Buy / sell side
Hedge-fund use shifts from data-only toward modest position-taking. Following Marex and Goldman, the first bulge-bracket bank stands up a principal or structured franchise.
Sportsbooks
DraftKings and FanDuel run dual models — state sportsbook plus federal exchange — and stop pretending the two won't cannibalize. Sports stays the volume engine.
Tech / data
Event-contract probabilities become a standard macro feed. Resolution, surveillance and integrity tooling become a real vendor category. Bloomberg/Google/Fed legitimacy is permanent.

Information finance goes mainstream

~25% — upside

Preemption is affirmed cleanly and early. A favorable framework passes. Depth arrives, the liquidity ceiling lifts, and event contracts become a normal line item in institutional risk management. The “truth machine” thesis is realized: prediction prices are a primary macro signal across the street.

Venues
Leaders cross well past $20B; an IPO arrives. A recognized asset class, not a curiosity. International venues (Eurex and peers) interconnect.
Clearing / FCMs
Mainstream FCMs clear event flow as standard product. Capital treatment is clarified. Institutional size becomes absorbable.
Market makers
Tight, deep, two-sided markets across thousands of contracts. The arbitrage edge that built the early fortunes is largely competed away.
Buy / sell side
Banks structure products and offer client access — Marex's PM bond becomes a category. Event contracts appear in real-money hedging mandates; sell-side research treats the data as core.
Sportsbooks
The federal exchange model wins decisively; some state franchises migrate wholesale to event contracts. Leagues negotiate rather than resist.
Tech / data
A full vendor ecosystem — pricing, resolution, surveillance, distribution — matures. Prediction feeds sit beside rates and credit on every desk.

Re-fragmentation

~25% — downside

The Supreme Court declines preemption, or Congress legislates a hard line, or the insider-trading and integrity scandals poison the politics. Sports contracts get pushed back into the state gambling perimeter. The federal-wrapper advantage collapses, the sector re-fragments, valuations reset hard, and the incumbents quietly write down their positions.

Venues
Back to a patchwork. Sports contracts restricted state-by-state; volume craters where the unlock had driven it. Several venues fold or sell for scraps.
Clearing / FCMs
Traditional FCMs stay away; the integration thesis stalls. Clearing remains thin and captive.
Market makers
Liquidity providers retreat as the addressable market shrinks. Equity stakes taken for liquidity are marked down.
Buy / sell side
Institutions revert to data-only or exit. Marex's note is marked down and Goldman's exploration quietly shelved. The hedging use case stalls below scale.
Sportsbooks
DraftKings and FanDuel relieved — their state moats hold — but stuck with stranded exchange acquisitions. Flutter's pricing-engine hedge underperforms.
Tech / data
Bloomberg/Google/Fed distribution persists (the data stays useful) but the venue economy contracts sharply. Integrity failures dominate the narrative.

The variable that dominates all three

Every branch hinges on one node: whether a sports event contract is, finally and durably, a federal swap. Get that right and the rest of the forecast is detail. Get it wrong and no amount of capital, liquidity, or incumbency matters. The market is, fittingly, pricing the answer in real time — which is the most prediction-market thing about the entire situation.

The Value Transfer

Winners and losers.

Every market-structure shift is a transfer. The federal wrapper expands the pie for some participants and quietly erodes the ground under others. Where the value moves:

WinnerWhy
Exchanges & clearersThe federal wrapper expands addressable market to fifty states under one license; clearing is the layer hardest to disintermediate
Market makersA brand-new volatility and probability surface with wide early spreads and cross-venue arbitrage
BrokeragesA high-engagement product that monetizes distribution they already own
Data vendorsA new signal stream to normalize, distribute, and sell across fragmented venues
Risk & infrastructure vendorsA new asset class that needs instrument representation, margining, and lifecycle tooling
LoserWhy
State sportsbooksFederal preemption routes around the state licenses that were their moat
State regulators & tax basesJurisdiction — and gaming-tax revenue — erodes toward a federal regime
Traditional pollingA faster, money-backed probability signal competes with the survey
Sports-data monopoliesPressure on data-licensing economics as a parallel venue prices the same outcomes

Winner / loser placement is analytical judgment, not a prediction of any specific firm's outcome.

Part V — So What

What it means for the people running the plumbing.

Set aside whether you want to trade a Super Bowl contract. The structural story matters to anyone who builds or runs institutional capital-markets infrastructure, for three concrete reasons.

1. A new contract type is being normalized into the derivatives perimeter

Binary event contracts are arriving inside CFTC-regulated venues, cleared through DCOs, surfaced on the same terminals as rates and credit, and now wrapped into structured notes. If they cross into real-money hedging — the bull case — execution, risk, P&L, margin, and lifecycle systems will need to represent them as first-class instruments. The firms that can model a discrete-outcome payoff alongside a swap will be ready; the ones treating it as gambling will be late.

2. The data is already a signal, regardless of the legal outcome

Even in the bear case, prediction-market prices remain a fast, skin-in-the-game probability feed for macro and event risk — now Fed-validated as competitive with consensus forecasts. Treated as an input — calibration surface, early-warning indicator, a cross-check against survey-based forecasts — it has value independent of whether any institution ever trades a contract. The signal survives the venue.

3. It is, again, the infrastructure-permanence lesson

The sportsbooks built a state-by-state empire and assumed the structure was the moat. A federal wrapper made the moat a liability. The same logic has come for printing, for trading floors, for settlement messaging, and it will come for whatever today's incumbents assume is permanent. The useful posture is not to predict which way prediction markets resolve. It is to keep your own plumbing flexible enough that you don't much care.

4. The risk-infrastructure problem this creates

The hardest layer to retrofit is risk infrastructure. Event contracts break assumptions traditional risk systems were built on: payoffs are discontinuous and settle to a binary, not a smooth distribution; positions across contracts carry hidden correlation shocks, since one geopolitical trigger can resolve a dozen contracts at once; and the underlyings include political and geopolitical events with no historical volatility series to lean on. Margining a binary, stress-testing a book of them, and representing them alongside swaps and options in a single risk picture is not a configuration change — it is new methodology. The firms that treat event contracts as a first-class instrument rather than a novelty will be the ones ready when the institutional flow arrives.

The instrument that pays a dollar if you're right is teaching a fifty-state industry that being licensed everywhere is not the same as being protected anywhere.

Two years ago this was a courtroom curiosity. Three years from now it is either a normal corner of the derivatives market or a cautionary tale about jurisdiction. The contracts, naturally, are already trading on which.

Exhibit C — The Volume Projector

Volume to 2030, by category and driver.

Volume decomposes into five categories — the retail engine (sports, mentions) and the emerging macro book (elections, economic, geopolitical) — each with its own growth. Move the four drivers and the curve re-prices live. When every driver clears ~55, a super-additive “stack” synergy engages: the unlocks stop adding and start compounding.

$1.0T
2030 annual volume
from $44B in 2025
31%
CAGR · 2026 → 2030
compound annual
64%
Retail-driven share · 2030
sports + mentions
62→__%
Sports share · 2026 → 2030
the engine, diluting

Drivers

Domestic regulatory harmony50
Federal preemption holds; CFTC framework clear; state actions recede.
International barriers fall50
Eurex / MiCA clarity, new jurisdictions open; global liquidity interconnects.
Institutional contract expansion50
More macro, credit, and single-name event contracts built for hedging.
Margin availability & capital efficiency50
Portfolio margin, FCM clearing, cross-margin with futures — compounds over time.
Stack synergy · dormant

The mix, in 2030

Retail-driven
Macro / institutional

Anchors: $44B in 2025, ~$340B in 2026. 2025–26 are fixed; the levers drive 2027–2030. Growth rates, splits, sensitivities and the synergy term are illustrative and editable, not a forecast.

The size of the pie is a regulatory question. The shape of the pie is an infrastructure question.
Exhibit D — Scale & Size

The volume against the rest of the financial system.

A multi-trillion-dollar number sounds enormous until you put it on the same ruler as the rest of the system. Keep flow (annual volume) separate from stock (notional outstanding), and remember today's volume is tiny retail tickets while the institutional flow arriving is a handful of very large blocks.

Annual volume, log scale · pick a prediction-market scenario
Annual volume traded (flow) Notional outstanding (stock) Prediction markets (projected)
6.7×
vs the entire US sports-betting handle ($150B / yr)
1.2%
of one year's crypto-derivatives volume ($86T)
0.12%
of OTC derivatives notional outstanding ($846T)

Why the dollars arrive in blocks

Illustrative average trade size by channel — log scale

Sources: AGA (US sports-betting handle ~$148B, 2024); CoinGlass/CoinGecko (crypto-derivatives ~$85.7T, 2025); BIS (OTC notional $846T, June 2025); ISDA. PM figures illustrative; flow and stock are different metrics.

Tiny next to rates. Enormous next to the thing it's actually eating.
Exhibit E — The Probability Cloud

The forecast as a distribution, not a line.

The projector draws one curve per scenario; reality is a distribution. This runs thousands of Monte Carlo paths to 2030 in parallel — each a different roll of the dice — and renders them as a probability cloud. The honest output isn't “$1 trillion” but “a 47% chance of clearing a trillion under these assumptions.” It runs live in your browser.

Monte Carlo · 2026 → 2030 · simulated annual volume
initializing…
Median 2030 volume (p50)
90% band (p5 → p95)
P( > $1T by 2030 )
P( > $2T by 2030 )
each faint line is one simulated future · bold = median · band = p5–p95 · right margin = 2030 outcome distribution

Drivers

Domestic regulatory harmony50
International barriers fall50
Institutional contract expansion50
Margin & capital efficiency50

The distribution, 2030

P(>$500B)
P(>$1T)
P(>$2T)
P(>$3T)

Illustrative Monte Carlo. Each path applies the projector's logic plus a per-year stochastic shock whose volatility grows with horizon. Growth rates, sensitivities and the synergy term are editable assumptions, not a forecast.

A forecast you can't attach a probability to isn't a forecast. It's a slogan.