# ProphetX

**Type:** Prediction market exchange  
**Status:** Pre-launch (DCM/DCO applications pending)  
**Founded:** 2024-2025  
**Regulatory approach:** Compliance-first, purpose-built for sports event contracts

## Overview

ProphetX is a U.S.-based prediction market exchange designed specifically for sports event contracts. The company filed applications with the CFTC in November 2025 to register as both a Designated Contract Market (DCM) and Derivatives Clearing Organization (DCO), making it the first U.S. exchange purpose-built for sports prediction markets.

## Regulatory Strategy

ProphetX distinguishes itself through a compliance-first approach rather than the "operate and litigate" strategy pursued by incumbents like Kalshi and Polymarket. In April 2026, ProphetX filed substantive comments to the CFTC's Advance Notice of Proposed Rulemaking (ANPRM) on prediction markets.

### Section 4(c) Framework Proposal

ProphetX's primary regulatory innovation is proposing that the CFTC use Section 4(c) of the Commodity Exchange Act to create a uniform federal standard specifically for sports event contracts. Key elements:

- **Section 4(c) authority:** Allows the CFTC to exempt specific transactions from regulatory requirements when in the public interest
- **Codification of no-action relief:** Would transform recent CFTC staff no-action letters for technology vendors into binding regulatory requirements
- **Federal preemption mechanism:** Creates an additional basis for federal preemption over state gaming laws that is narrower and more targeted than existing "swaps" classification arguments
- **Rule 40.11 resolution:** Provides explicit CFTC authorization that directly overrides Rule 40.11's "shall not list" prohibition for gaming contracts, rather than arguing around it through field preemption

### Recommended Industry Standards

ProphetX's ANPRM comments recommend codifying best practices across the prediction market industry:
- Consumer protection standards
- Anti-manipulation mechanisms
- League partnership requirements

## Market Position

ProphetX represents a new competitive entrant with a different regulatory strategy than established players. While Kalshi and Polymarket have pursued aggressive expansion followed by litigation, ProphetX is building regulatory approval into its launch architecture.

## Timeline

- **November 2025** — Filed CFTC applications for DCM and DCO registration
- **April 20, 2026** — Released public comments on CFTC ANPRM proposing Section 4(c) framework for sports contracts

## Sources

- PR Newswire, "ProphetX Releases Comments to CFTC on Prediction Markets Rulemaking," April 20, 2026