Kalshi appears set to offer bets on which college athletes enter the transfer portal, according to new filings submitted to the Commodity Futures Trading Commission (CFTC).
Kalshi submitted a filing Tuesday to self-certify a contract titled “Will <player> enter/withdraw from the transfer portal in time period?” and another titled “Will <player> transfer to <team> in <time period>?”
ptc12162534842The filings say that Kalshi intends to offer the contracts by the end of the business day Wednesday. Exchanges do not always put up the contracts at the time they list in regulatory filings; contracts such as Kalshi’s first player props were listed weeks after the date listed on self-certification filings.
Self-certification is a process where an exchange tells the CFTC that it plans to list a new type of contract, and provides certain details such as the applicable rules. If the CFTC does not object before the listing date specified, the contract may be listed, though it is not technically considered “approved.” It is the method by which almost all CFTC-regulated contracts – in prediction markets and traditional commodities – are listed.
If the CFTC objects to the contracts, it could launch a 90-day “public interest” review into them. However, based on history this would be an unlikely step. Earlier this year, Acting CFTC Chairman Caroline Pham said the agency has not denied a single self-certification during its 50 years of existence. The CFTC has not launched a public interest review into any of the thousands of contracts self-certified by regulated exchanges this year.
The NCAA transfer portal is a database of all college athletes who intend to transfer from one university to another. The portal is open from Jan. 2 to Jan. 16, though some players signal their intent to enter the portal earlier.
Kalshi has not offered college props
Kalshi has mostly avoided offering bets on individual college athletes so far. The exchange has not yet listed collegiate player props, even though its self-certification for props in sports like football and basketball could also apply to the college level of those sports. It did offer bets on the Heisman Trophy, and top picks in the NFL and NBA drafts.
At the start of the college football season, a Kalshi spokesperson told InGame that the prediction market had “no immediate plans” to offer college player props.
The NCAA has opposed allowing sportsbooks to take bets on college player props, “to protect student-athletes and to protect the integrity of the game.”
However, bets on the transfer portal may raise similar, if not larger, concerns, due to the large number of people who may have insider knowledge about potential transfers.
No state-regulated sportsbook offers bets on transfer portal entrants or destinations, and the contracts would be unlikely to be allowed by most state regulators.
Trading prohibitions
As with all newly self-certified contracts, Kalshi listed a number of “trading prohibitions”: people who would not be allowed to place bets on this market.
In this case, the prohibited traders are the athlete involved; “current and former coaches, athletic staff, and student athletes” at the athlete’s school; “agents, advisors, NIL representatives, attorneys” or similar roles; NCAA employees with access to the transfer portal database; university administrative staff who work with athletics; employees or recruiting services like Rivals or 247; and immediate family or household members of any of the previously listed categories.
NCAA athletes or college athletics staff at schools where the transferring player is not enrolled — even including athletes at the school the athlete may transfer to — do not appear to be prohibited.
The degree to which Kalshi enforces these prohibitions is not always clear. In May, Kalshi said its compliance and surveillance teams would “act accordingly” — but did not specify what that means — after California gubernatorial hopeful Kyle Langford bet on himself to win the state’s 2026 election. As a candidate, Langford was covered by that market’s trading prohibitions.
Under CFTC rules, Kalshi must show how its contracts are “not readily subject to manipulation.” During court filings in Nevada – where the state called on Kalshi to produce evidence of its anti-manipulation policies – Kalshi’s lawyers said the prediction market files this evidence confidentially.
As a result, it’s not clear what evidence Kalshi submitted to prove that the contract would not be subject to manipulation.
Resolution can be based on player tweets
The contract applies only to Division I football and basketball transfers.
The filing notes that “<player> may also refer to multiple players using AND/OR logic,” suggesting a transfer portal parlay would be permissible. It may also “refer to player(s) by distinguishing characteristics, or as an element in a set of player(s)”, which would appear to allow for questions such as “Will an Alabama quarterback transfer?”
The contract will be settled based on “public announcements” including players’ social media, as well as school athletic departments and major recruiting services or sports media.
The contract rules explicitly note that if a player announces that they have entered the portal, but then announces they have changed their mind and will remain at their current school, the contract pays out as a “yes.”
The rules also note that “Revisions to the Underlying made after Expiration will not be accounted for in determining the Expiration Value.” As a result, it appears clear based on the written rules that if a player simply tweets about their intent to enter the transfer portal — regardless of whether they actually had plans to do so — the contract should be graded as a “yes.”
