Seventeen pages on the CFTC’s filings portal: the terms for a derivative, certified for listing in the US, on how many kills a player records on a given map. KalshiEX LLC filed it on 6 March 2026. Read as a rulebook rather than a launch, it is drafted with more care than the scene expects, and porous where the scene cares.

The file

Certified is not approved

Start with the verb. Under Section 5c(c) of the Commodity Exchange Act and Regulation 40.2(a), an exchange certifies to the Commission that a contract complies, and files. Nobody signs off in advance. The document establishes terms and an intention, nothing more: not that a market was listed, not that anyone traded one, not a dollar of volume. Its subject can be a named player, a roster, or a group as loose as “any player in the lobby”.

The barred list, and the hands it does not have

Appendix B bars from trading: the player or roster concerned and their coaching, management and support staff; the same for scheduled opponents; paid employees of the tournament organizer or governing body — ESL/FACEIT, BLAST, PGL, Riot and Valve given as examples; referees, observers, administrators and anti-cheat officials assigned to the event; developer staff holding non-public server, match, anti-cheat or patch data; statistics-provider employees with pre-release access; anyone with non-public roster, health or disciplinary information; and the immediate family and household members of all of them.

As a list of who should not be trading a market on a player’s entry duels, it is close to complete. As an enforcement instrument, it is nouns with no verbs: who is prohibited, never how they are found or what becomes of their position. The exchange knows its account holders. It does not know a tier-two roster’s support staff.

A general bar on material non-public information sits above these eight bullets; they are additional. Within them, two seams. The organizer bullet reaches paid employees — a qualifier the officials bullet pointedly omits — so a freelance producer or contracted analyst sits between the two. And “immediate family” is enumerated — parents, siblings, spouses, domestic partners — so an adult child at their own address falls outside it, and outside the household clause after it.

What settles it

Resolution runs down a Source Agency hierarchy: the governing body or official tournament organizer, the designated official statistics provider, the official broadcast platform. Then it descends — Liquipedia, HLTV, op.gg or gol.gg, Dotabuff or Stratz, vlr.gg — and below them the esports trade press and the wire services.

Several of those are resources the scene built for itself, now in the settlement chain of a contract certified to a US regulator. Whether any agreed, were paid, or were asked, the filing does not say; Appendix D, Source Agency, is withheld. That is the question running under the data-rights economy behind esports odds: who owns the record of play.

Then the discretion. One phrase recurs — resolution “to the last fair price determined in the sole discretion of the Exchange” — covering a substitution before the relevant play starts, a cancellation, a postponement past 48 hours, a shortened event whose figures never publish. Where a mid-event patch alters how a statistic is tracked, the Exchange sets the methodology.

One line should stop a reader. The event definition takes in a scrimmage or showmatch, if the Exchange designates one. Scrims are practice — no officiating built for them, no obligation to try. The filing designates none. It reserves the right.

What is sealed, and what is not settled

Appendices C, D and E went in under a confidential-treatment request citing Regulations 40.8 and 145.9, so the risk-mitigation and price-basing analysis — why this is a hedging instrument and not a wager on a player’s aim — stays sealed.

Nor is the frame finished. The Commission’s proposal on how such contracts would be tested, Prediction Markets; Public Interest Determinations, closed comments on 27 July 2026 and, as of this writing, remains a proposal: its regulation identifier still indexes two documents, both proposed rules. The proposal’s taxonomy of permitted sports contracts describes settlement resting on “objective, verifiable, league-certified data”; the Commission’s own preliminary test, a paragraph later, asks only for “objective, verifiable data and robust integrity measures.” The Source Agency ladder’s lower rungs are community wikis.

Both columns

Verdict

What would move that number is dull: a published method for detecting a barred trader, and the Source Agency arrangements out from behind the stamp.

A rulebook drafted this precisely about entry duels, aces and Baron counts says somebody has studied the tape closely enough to price a single player’s map. Whatever wrapper it arrives in, the discipline holds: 18 and over, a budget decided before the map loads and not topped up after it, and — where esports betting is what is meant — licensed sportsbooks, with availability varying by jurisdiction.