SEC notice sets 19 November start for KalshiEX's faster IPO listing rules on perpetual futures

The Securities and Exchange Commission has published KalshiEX LLC’s proposed change to the listing standards for perpetual security futures on newly public stocks. The notice is dated 6 November and appears in the Federal Register of 12 November (Release No. 34-106841, File No. SR-KALSHIEX-2026-03, 91 FR 72935). The proposed rule change “will become effective on November 19, 2026.” Comments are due on or before 3 December.

When we reported Kalshi’s launch of single-stock perpetual futures on 9 November, we noted that KalshiEX had already self-certified this amendment with the Commodity Futures Trading Commission. The 12 November notice is the Commission’s publication of the same filing. KalshiEX filed it with the SEC on 4 November and certified it with the CFTC on the same day.

What the notice would change

The filing would amend the introductory language of Rule 14.3 of the Kalshi Rulebook, and Rules 14.3(c) and 14.3(d), which set the initial listing eligibility criteria for the underlying common stocks of perpetual security futures products. It would also define an underlying security’s “initial public offering day” as “the first day on which the Underlying Security trades ‘regular way’ on a national securities exchange.”

Under the current Rule 14.3(c), the average daily value of transactions test is framed over the prior month, so it does not cover stocks with less than a month of exchange-trading history. The notice says that if an IPO occurs on a given day, “the earliest date that the Exchange could list a Perpetual SFP on such security would be one month following such date.” The amendment would add that, where the underlying security has been listed for trading for less than one month, it “must have had a trading volume (in all markets in which it is traded) of at least 2,400,000 shares since the Underlying Security’s initial public offering day.”

Separately, Rule 14.3(d) now requires a covered security, as defined in Section 18(b)(1)(A) of the Securities Act of 1933, to have had a closing price of at least $3.00 for the previous five consecutive business days before a listing (or $7.50 over the same period if the security is not a covered security). The exchange proposes to waive that five-day lookback for certain covered securities “for the first three business days following their IPO.” Starting “on or after the second business day following the covered security’s IPO day (i.e., not inclusive of the day of the IPO),” it may list a perpetual security futures product on that security if the company “had a market capitalization of at least $3,000,000,000 (three billion U.S. dollars) based upon the offering price of its IPO.”

The notice’s example is a Monday IPO for a company with a $3bn market capitalisation at the offering price: the exchange “could list a Perpetual SFP for trading on Wednesday, subject to the Underlying Security satisfying all other eligibility criteria in Rule 14.3.” After those first three business days, the five-day lookback “would continue to apply as currently written.” The $7.50 test for securities that are not covered securities is unchanged.

What is not new

Other listing standards would still apply. The existing requirement in Rule 14.3(b) that the underlying security have a market capitalisation of not less than $100bn is not amended. The notice says that test “would be distinct from amended Rule 14.3(d) because it takes into account secondary trading after the IPO.”

Taken together, the amendments would permit a listing “starting on or after the second business day following the IPO (not including the day of the IPO) if all listing criteria in Rule 14.3 are satisfied, including the $100 billion market capitalization requirement in Rule 14.3(b).” A $3bn capitalisation at the offering price is the test for waiving the five-day $3 lookback. It is not, on its own, enough to list the contract.

The other initial eligibility criteria in Rule 14.3 are also unchanged. Those include that the stock be registered and listed on a US national securities exchange and be an NMS security, a public float of not less than 7 million shares, an estimated deliverable supply of more than 20 million shares, an issuer that is current in its periodic reporting obligations, and at least 2,000 security holders.

Kalshi, which is a CFTC-registered designated contract market and is notice-registered with the SEC as a national securities exchange for security futures under Section 6(g) of the Exchange Act, says the amendments are consistent with listing standards adopted by securities options exchanges. The underlying listing-standard rules for these products were filed on 18 September (SR-KALSHIEX-2026-02, Release No. 34-106422).

Effectiveness and comments

The proposed rule change will become effective on 19 November. At any time within 60 days of that effectiveness, the Commission, after consultation with the CFTC, “may summarily abrogate the proposed rule change and require that the proposed rule change be refiled in accordance with the provisions of Section 19(b)(1) of the Act.”

In the notice, KalshiEX says it has not solicited comments on the proposed rule change and has not received any unsolicited written comments from members or other interested parties. Comments to the Commission should refer to File No. SR-KALSHIEX-2026-03 and be submitted on or before 3 December.

The notice does not name any specific forthcoming IPO.

Why it matters

• A published effective date, and a comment deadline. The substance of the amendment was in KalshiEX’s 4 November CFTC self-certification, which we reported on 9 November. What is new today is the SEC’s Federal Register notice, a stated effective date of 19 November, a comment deadline of 3 December, and a 60-day window after effectiveness in which the SEC may abrogate the change after consulting the CFTC.
• Listing timing, not a new product. This filing is only about when Kalshi may list a perpetual security futures product on a newly public stock. It does not change the product itself. Kalshi has already announced perpetual futures on more than 50 NYSE and Nasdaq names.
• The $100bn test is still the binding filter. The $3bn offering-price test only unlocks a short waiver of the five-day $3 lookback, and only for covered securities in the first three business days after the IPO. A second-business-day listing still requires every other Rule 14.3 test, including a current market capitalisation of at least $100bn, which the notice says takes into account secondary trading after the IPO. Only a very large IPO could qualify.
• The clock would match the options market. Kalshi presents the change as aligning its listing timetable with the standards options exchanges already apply to large, newly public stocks.

What we are watching

• Whether the SEC abrogates the change within 60 days of 19 November.
• Comments filed with the Commission by 3 December.
• Whether KalshiEX lists a perpetual security futures product on a newly public stock once the rule is in effect.

Sources

All checked on 12 November 2026 at 06:38 GMT (06:38 London time).

• Federal Register, Self-Regulatory Organizations; KalshiEX LLC; Notice of Filing and Immediate Effectiveness of a Proposed Rule Change Relating to Listing Standards for Security Futures Products (91 FR 72935, document 2026-22958), published 12 Nov 2026, notice dated 6 Nov 2026; official PDF via GovInfo.
• U.S. Securities and Exchange Commission, Release No. 34-106841 (SR-KALSHIEX-2026-03), 6 Nov 2026; Exhibit 4 (rule text); rulemaking page.
• KalshiEX LLC, Self-certification of amendments to Rule 14.3, filed with the CFTC on 4 Nov 2026.