When we discuss money makers and money losers in prediction markets, we’re not just talking about top forecasters and savvy traders who profit from accurate predictions. Venues like Kalshi offer financial incentives to volume traders, market makers, and other users who help run and promote their markets. Those cash benefits can significantly affect accounts’ bottom lines; in some cases, they make up the bulk of their revenue. But these incentive programs are also ripe for abuse.
KalshiEX LLC told the Commodity Futures Trading Commission on September 28, 2026, that its Volume Incentive Program will stop no earlier than October 13, 2026. The notice, signed by regulatory counsel Rhianna Ross, replaces the October 1, 2027 end date. The KalshiEX termination filing gives no reason. It cites Kalshi Rule 3.13(f), which lets the exchange create, revise, or end incentive programs at its own discretion.
The timing coincides with a public fight over ether perpetual volume. Early last week, a trader posting on X as Beni said repeated trades of about $5,500 made up 48% to 58% of that contract’s volume across four sessions. September volume had already reached $52.98 billion through September 29, a monthly high with the month still open. The allegation was that wash trading was occurring in these markets, where accounts bought and sold the same contract to boost volume, presumably to earn volume-trading bonuses. This would be like buying products on your airline miles card to get bonuses, returning the items, and buying them again and again to churn your air miles benefits.
Until October 13, the program will run under the terms already in force. After that, the share-of-volume payout attached to this program is gone unless Kalshi files a replacement.
Kalshi operates self-certification under Section 5c(c) of the Commodity Exchange Act and CFTC Regulation 40.6(a). Kalshi is telling the Commission the change complies with the statute. It is a notification, not a request for approval, so the exchange set the timing. Ross also certified that a copy went up at the same time on the Kalshi regulatory notices page.
What the October 13 cutoff changes
The Kalshi program launched in March 2023. Its stated purpose was to raise volume and liquidity on the central limit order book and improve pricing efficiency. For each eligible market, Kalshi posted an Eligible Term of no more than 31 days and a fixed Volume Reward. At the end of the term, eligible members received a share of that pot based on their eligible volume relative to everyone else’s—a pretty basic setup for promoting trading volume across its markets.
Eligible volume meant central-book trades priced between $0.03 and $0.97, a band meant to omit near-certain outcomes. That range limit did not apply to perpetual futures. Event-contract rewards were capped at $0.005 per contract, a limit the terms say exists to help avoid price distortion. No matching cap is stated for perpetual futures.
Registered Kalshi affiliates were excluded, along with members who had signed a market-maker agreement, introducing brokers, futures commission merchants, and their non-disclosed customers when those firms stood in the middle of the trade. The Chief Regulatory Officer could pull a member whose activity looked abusive or inconsistent with the program’s purpose. However, the September 28 notice does not mention using that latter “abuse” supervision.
Kalshi did not explain its filing beyond the rule that lets it end such programs on its own.
What keeps running after October 13
The Temporary Perpetual Fee Rebate Program, updated in a separate September 2 filing, remains in effect. Crypto perpetual taker fees are rebated down to 0.3 basis points, and maker fees are adjusted so makers net 0.3 basis points, with payments trimmed so a single trade does not produce a net-negative combined fee. It runs through December 31, 2026, for self-clearing members.
That split matters because the loudest fight was over ether perpetuals. A pot that pays members for trading differs from a rebate that pays a firm for resting orders. Kalshi has leaned on that distinction in its own writing. Closing the Volume Incentive Program does not, by itself, close the perpetual quoting deals.
Under Core Principle 18, Kalshi said it will keep records of trades and payments under the program through the termination date. Core Principle 7 covers public information, so Kalshi should and will post the new end date where members can read it. An August 4 filing from Chief Regulatory Officer Richard Heaslip had extended the same program toward futures contracts, effective on or after August 18. Eight days after coverage of that extension collided with the volume allegations, the company posted the termination notice.
The $5,500 ether perpetual trades that came first
Beni, a co-founder of Stealth Neolab, put the figures in public on September 20. In a follow-up he called “undeniable proof,” he wrote that the same $5,500 size accounted for 48% to 58% of all ether perpetual volume on four separate days. The Beni post regarding repeated ether perpetual trades told readers they could pull the same figures from Kalshi’s public API. He also claimed, without showing a source, that volume deals were pushing market makers into the pattern.
Ether perpetual volume near $539 million in 24 hours was measured against open interest near $3.1 million, a gap of roughly 174:1. A gap that wide does not prove a wash trade, but it looks incredibly suspect. Wu Blockchain’s summary of the allegation carried those figures and noted Kalshi’s reply that prediction-market contracts and perpetual futures were being mixed.
The CFTC looked at more than $5 billion in repeated ether perpetual trades, many close to $5,500. The Wall Street Journal said nearly 1 million trades of almost identical size had moved through that market since August. Kalshi has said it was not under investigation. A Kalshi crypto staffer, posting on X as IcoBeast, said any qualifying firm can become a self-clearing member and rejected the claim that the exchange had hand-picked the flow. In other words, if it happened, it wasn’t us.
How Kalshi answered
The Kalshi perpetuals volume post says wash trading means entering positions a trader does not want, usually to fake activity or price movement. Self-trades are blocked in the matching engine. Pre-arranged trades with a partner are banned and watched. The company wrote that it has seen no evidence of collusion.
Its explanation for the repeated size is mechanical. One market maker rests orders of a fixed size. Faster traders hit those orders because they disagree on price. Kalshi said the takers, described as hundreds of distinct traders, were consistently on the winning side of those fills, and the maker was consistently on the losing side. In that account, both sides wanted the trade when it matched. In other words, this wasn’t washing; the repeated order sizes were explainable.
But the incentive design is the other half of the conversation. Kalshi said the perpetual structures pay for resting liquidity, not for the number of trades they generate. A firm in the program has to stay on the book. Later coverage described a deal of about $100,000 a month to keep bids and offers at least $5,000 apart for most of every hour. A quote near $5,000 or $5,499 is what that kind of deal tends to leave on the screen.
Kalshi’s rebuttal does not really answer the harder question. If a maker loses on the fill and keeps quoting new orders because a bonus stipend covers the loss, the match is real, and the loss is fully subsidized. The September 28 filing never says the Volume Incentive Program caused the pattern, and it never says the program is ending because of it. But we are rationally assuming this connection.
What to watch through the cutoff
Until October 13, eligible members can still earn a share of any Volume Reward already posted for an open term. After the cutoff, that money stops for this program. Firms quoting under market-maker agreements were already outside it, so they are not losing their funds. The perpetual fee rebate, running to December 31, is a separate filing and a separate timeline.
The next useful disclosure is operational. Which markets still show an Eligible Term after October 13? Do perpetual quoting stipends change size or spread requirements once the volume pot closes? Does daily ether perpetual volume fall, hold, or simply change lot size? The September 28 notice answers only one of those questions.
References
- KalshiEX LLC notice of termination of the Volume Incentive Program, September 28, 2026
- Kalshi regulatory notices
- The Block: Kalshi to end liquidity incentive program amid wash trading allegations
- Legal Sports Report: Volume rewards program on Kalshi set to end nearly a year early
- The Crypto Times: Kalshi is ending its Volume Incentive Program nearly a year early
- Crypto Economy: Kalshi ends volume rewards program on October 13
- CoinCentral: Kalshi ends volume reward program as ether trade scrutiny grows
- Unchained: Kalshi rejects wash-trading claims after repeated $5,500 ether perp trades
- Kalshi: The facts behind Kalshi’s perpetuals volume
- Dan Bernstein on X, September 29, 2026
- Beni on X, September 20, 2026
- Wu Blockchain on X, September 21, 2026
