Kalshi S&P 500 Perpetual Futures CFTC Approval Update

Kalshi’s proposed S&P 500 perpetual futures remain unapproved. The Commodity Futures Trading Commission’s product listing for US500PERP still reads “Approval Pending (45),” and a September 23 Federal Register notice says the agency had not yet approved a related Kalshi rule change. The contract is filed but not cleared, and it isn’t shown as available to trade.

The pending index contract is easy to mix up with a separate rule filing. On September 18, Kalshi submitted SR-KALSHIEX-2026-02, which would add Chapter 14 to its rulebook and set listing standards for perpetual security futures. The Federal Register notice says Kalshi also sent that rule change to the CFTC, and that the CFTC had not yet approved it. Those contracts would track an underlying equity security, carry no pre-specified expiration date, and use periodic funding payments between long and short holders.

US500PERP sits on a different track. The CFTC product page lists it as a future, filed August 18, in the equity-index category, with status still pending. A listing standard and a named contract are not the same approval. Until the Commission signs off, traders cannot treat an S&P 500-style perpetual as a live Kalshi product just because a crypto perpetual already trades there.

Monday’s headline sharpened the distinction. Some outlets said the CFTC had approved an S&P 500 stock-index perpetual. The public product record still showed US500PERP awaiting approval.

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What the US500PERP filing actually asks the CFTC to clear

Kalshi filed US500PERP on August 18 through the voluntary review path under CFTC Regulation 40.3. The contract would track the MerQube US Large Cap Index, a broad measure of the 500 largest companies listed and based in the United States.

The same day’s package included COPPERPERP, a copper perpetual referencing a Pyth Network price feed. The Commission did not approve either product, and the public filings did not set a launch date or a decision deadline. The Commission can approve, ask for changes, or reject a submission if it finds a problem under the Commodity Exchange Act or CFTC rules.

A perpetual does not die on a calendar date the way a quarterly equity-index future does. Long and short holders exchange funding payments so the contract price stays near the reference index. That design is familiar in crypto. It is newer in a CFTC-regulated equity-index wrapper, which is why Kalshi put US500PERP in front of the agency instead of self-certifying it and listing the next morning. They knew it would require more substantial review.

Kalshi’s own explainer shows how the firm describes the product traders already use on crypto perpetuals: no expiration, long or short, leverage that cuts both ways, and automatic closeout if the move runs too far.

Why bitcoin perpetual approval did not clear an equity-index contract

On May 29, the CFTC approved Kalshi’s BTCPERP contract, a perpetual referencing the spot price of bitcoin. The order said the contract complied with the Commodity Exchange Act and the core principles for designated contract markets. It also warned that the perpetual design may not suit every asset class, and that contracts on assets outside that order should come in for review under Regulation 40.3.

The Kalshi bitcoin perp approval is the first true bitcoin-referenced perpetual on a regulated U.S. exchange.

After that approval, Kalshi filed contracts tied to other coins, then moved toward metals and a stock-index perpetual. But expanding the same no-expiration design from bitcoin to a large-cap equity index is a bigger step than adding another coin.

Funding payments are the hinge. They keep a no-expiration contract from drifting away from the reference price, and they also sparked a legal fight over whether those payments make the instrument a swap. CME Group sued after the May approvals, arguing the agency had treated swap-like contracts as futures. The CFTC later asked a judge to dismiss the case, saying CME had not shown financial harm and could list competing contracts. The judge had not signed an order when that motion was filed.

CME chief Terrence Duffy argued in June that payments exchanged between two sides look like a swap, and a swap carries different requirements than a future. That fight is still the backdrop for any equity-index perpetual sitting in “Approval Pending.”

How the security-futures rule filing differs from US500PERP

The September rule change is about single-name and fund-linked security futures, not the broad index contract filed in August. Kalshi asked the SEC and the CFTC for authority to list cash-settled perpetual security futures on dozens of U.S. stocks and ETFs.

The product database on September 20 showed Apple, Tesla, Microsoft, Nvidia, Amazon, SPY, and QQQ perpetuals listed as “Approval Pending (45).” The proposed rule would run trading from 6:00 p.m. ET Sunday through 5:00 p.m. ET Friday, with a daily one-hour maintenance window. Kalshi also proposed a 15.50% minimum customer margin and cash settlement through Kalshi Klear. The SEC filing said the rule change would take effect on November 2, 2026, or later if CFTC rules require it.

Security futures sit under both agencies because they are futures on securities. A broad-based security index future is a different legal object from a future on one stock.

Coinbase and Bitnomial filed competing stock-perpetual proposals on September 18, so Kalshi is not the only venue asking. A crowded docket is another reason a pending flag can sit for weeks. Speed in crypto listings does not automatically carry over when the underlying is a stock, an ETF, or a 500-name index.

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What Monday’s no-action letter does and does not change

On October 5, the CFTC’s Division of Market Oversight issued a no-action letter for designated contract markets that want to convert existing perpetual-style broad-based security index futures into true perpetual futures. The release says a venue may remove expiration dates if it seeks feedback from traders with open positions, gives advance notice and a chance to exit, offers risk disclosures, and leaves other material terms unchanged.

The letter also requires a filing under CFTC Regulations 40.5 or 40.6 and a certification that every condition is met. The no-action positions expire on October 20, 2026. A short window to amend an existing contract does not clear US500PERP.

A no-action letter tells staff they will not recommend enforcement if a venue follows the listed steps. It does not change US500PERP as pending. It also does not settle CME’s argument about funding payments, and it does not launch a MerQube-linked contract that Kalshi itself said would wait for authorization.

Crypto perpetuals can already trade at Kalshi because BTCPERP was approved in May. Until the US500PERP status changes, or Kalshi lists a converted contract under the October 20 conditions, the equity-index perpetual remains nothing more than a filing.

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PolyPunter Staff

The PolyPunter staff works tirelessly to bring you the latest and most insightful news, information, and tips on the fast-growing economic, financial, and social phenomenon that is prediction markets.