I keep coming back to the same question whenever a new contract design hits the regulatory desk: do people actually want to hold stock exposure that never expires, or do they just want the feeling of control after the cash market closes? That tension sits at the center of Kalshi’s latest move. On September 18, the firm submitted product rules aimed at listing U.S. stock and exchange-traded fund perpetual futures. The paperwork is public. The permission is not. As of September 20, the relevant product records still sat in pending status, which is a polite way of saying nobody should treat these contracts as live markets yet.
Why This Filing Matters More Than The Headline
Perpetual contracts are familiar to anyone who has spent time around crypto derivatives. They do not come with a fixed end date. Positions can roll forward through funding payments instead of being forced into a quarterly expiry circus. Bring that design to Apple, Tesla, Microsoft, Nvidia, Amazon, or the big index funds, and you are no longer talking about a niche experiment. You are talking about a hybrid product that sits between listed equity futures and around-the-clock speculation.
I’ve found that the market usually overreacts to the word “filed.” A filing is a request. It is not a launch. Kalshi’s materials treat the contracts as security futures, which means both market regulators have a role. One side reviews the product as a futures contract. The other side cares because the underlier is a security. That dual track is why this story feels slower and more bureaucratic than a typical crypto listing announcement.
Still, the details are specific enough to study. The proposed customer margin floor is 15.50% of current market value. Trading would run from Sunday evening through Friday afternoon Eastern time, with a daily one-hour pause. Settlement would be in cash. Funding would normally change hands around the regular equity close. Those are not throwaway specs. They tell you how the exchange wants the product to behave when the underlying stock is quiet, when it gaps, and when a halt hits the cash tape.
What A Stock Perpetual Actually Is
Strip away the jargon and the idea is simple. A trader takes a leveraged view on a stock or fund. There is no calendar date that automatically closes the book. Instead of expiry, the contract uses a funding mechanism so the futures price does not drift too far from a reference tied to the cash market. If the perpetual trades rich, one side pays the other. If it trades cheap, the flow reverses.
Kalshi’s draft rule text includes a tiny deadband of 0.002% for small pricing differences and a hard cap of 2.00% on funding magnitude. That combination is meant to keep noise from generating constant micro-payments while still preventing a runaway basis. In my experience, funding design is where these products either feel tradable or feel like a tax on impatience.
The standard contract unit is described as 100 shares of the underlying security, with room for smaller permitted units. Cash settlement matters here. Nobody is promising physical delivery of a stock certificate at 3 a.m. The exposure is synthetic. Gains and losses move through the clearinghouse in money, not shares.
A contract with no expiry is only as honest as its funding, its margin, and the quality of the price it claims to track.
That is the part retail marketing often skips. Perpetuals are not magic. They are a financing wrapper around a price. If the wrapper is tight, the product can be useful for hedging after hours. If the wrapper is loose, it becomes a high-maintenance bet dressed up as convenience.
The Calendar Kalshi Wants To Trade
Proposed Rule 14.11 sketches a near-continuous weekday week. Trading would open at 6:00 p.m. Eastern on Sunday and run through 5:00 p.m. Eastern on Friday. Each day would include a maintenance window from 5:00 p.m. to 6:00 p.m. Eastern. Call it a 23-hour weekday session with a scheduled pit stop.
That schedule is not quite 24/7. It is 24/5 with a daily reset. For people who already watch overseas headlines hit U.S. names after the cash close, the extra hours are the whole point. A chip-stock gap on Sunday night would no longer force every leveraged view into options or offshore venues. At least that is the pitch.
The same notice says trading would stop during required regulatory halts that affect the underlying security. Kalshi could also set different hours for a particular contract when its own rules allow it. In plain English: the perpetual is not supposed to keep spinning if the cash market is frozen for a reason that matters.
- Sunday 6:00 p.m. Eastern start through Friday 5:00 p.m. Eastern close
- Daily maintenance from 5:00 p.m. to 6:00 p.m. Eastern
- Halt alignment when the underlying security is halted
- Possible contract-specific hour changes if rules permit
Perhaps the most interesting operational choice is the funding timestamp. Payments would be exchanged at the daily settlement time, normally 4:00 p.m. Eastern, when the regular U.S. equity session ends. That anchors the perpetual to the cash close rather than to some floating crypto-style heartbeat every eight hours. I like that instinct, even if three-times-daily funding used by a rival filing has its own logic.
Margin, Clearing, And The Cost Of Being Wrong
Leverage is where these products stop being theoretical. Kalshi’s customer-margin rule would require at least 15.50% of the current market value of each position. That is not crypto-exchange margin. It is closer to a regulated futures haircut with a securities overlay. You can still lose more than you planned if the market gaps through the maintenance window. You just start with a thicker cushion than many offshore perp books allow.
Every trade would clear through Kalshi Klear, the firm’s registered clearinghouse under the proposal. That is a big deal for people who care about default waterfalls and who stands in the middle when two counterparties disagree. A listed perpetual that clears at a registered house is a different animal from a bilateral swap booked in a chat window.
| Feature | Kalshi Proposal |
| Product type | Cash-settled security futures with no preset expiry |
| Standard unit | 100 shares, with smaller permitted units |
| Customer margin floor | 15.50% of current market value |
| Funding cap | 2.00% maximum magnitude |
| Funding deadband | 0.002% |
| Typical funding time | 4:00 p.m. Eastern cash close |
| Clearing | Kalshi Klear |
Is 15.50% conservative? Compared with unregulated books, yes. Compared with fully funded stock ownership, no. A 15.50% cushion still implies more than six times notional exposure if you press the structure to its floor. That is enough to amplify a quiet Tuesday and enough to wreck a weekend headline. Anyone who treats the margin rate as a suggestion rather than a survival number is going to learn the difference the hard way.
Which Names Made The First Batch
Public product records listed separate Kalshi submissions for AAPL, TSLA, MSFT, NVDA, AMZN, SPY, and QQQ perpetuals, among other equity-linked contracts dated September 18. Each of those records remained in Approval Pending (45) status when checked on September 20. None of the named stock or fund perpetuals had clearance.
That roster is not random. These are deep, noisy, globally watched underliers. They already move on overseas news. They already attract options volume after hours in other wrappers. If you were going to test whether an American stock perpetual can attract two-sided flow, you would start here rather than with a sleepy mid-cap that barely trades at lunch.
The listing standards in the filing try to keep the universe limited to large, liquid names. An underlier would need an estimated deliverable supply above 20 million shares, a market capitalization of at least $100 billion, and average daily transaction value of at least $450 million over the prior six months. A security listed for less than six months would need at least $1 billion in average daily transaction value over the prior month. Public float would need to be at least 7 million shares.
- Estimated deliverable supply above 20 million shares
- Market capitalization of at least $100 billion
- Six-month average daily transaction value of at least $450 million
- Or, for newer listings, $1 billion average daily value over the prior month
- Public float of at least 7 million shares
Those screens will keep meme-thin names off the board, at least on paper. They will not keep volatility off the board. A $100 billion company can still drop 8% on a product update. The standards are about market structure, not about making the trade easy.
The Dual-Regulator Maze
This is the section where patience beats hype. Because the underliers are securities, the contracts are framed as security futures. Kalshi already received acknowledgment of a Form 1-N notice registration on September 8, which allows a designated contract market to notice-register as a national securities exchange for the limited purpose of security futures. The September 18 filing then supplies the product rules.
The securities-side notice says the proposed rule change “will become effective on November 2, 2026, or such later date” as futures regulations permit. Public comments would be due 21 days after publication in the official register, though a fixed comment deadline had not been posted on the agency page as of September 20. Even after effectiveness, the securities regulator, after consulting the futures regulator, could summarily abrogate the change within 60 days and force a refile under a different process.
So the calendar on the page is not a launch date. It is a legal waypoint. CFTC product approval remains a separate condition. Until that box is checked, the ticker list is a wish list.
Two agencies can agree that a market should exist and still disagree about the exact wrapper that should carry it.
I’ve watched enough of these dockets to know that “pending” can mean weeks or it can mean a quiet freeze. Status labels do not capture staff questions about manipulation, close-price quality, weekend gaps, or how retail customers will misunderstand funding. Those questions are the real work.
Rivals Filed On The Same Day
Kalshi is not alone in the inbox. Records show Coinbase Derivatives submitted its own security-futures rule change on September 18. Its single-stock perpetual futures contract also sat in pending status. That filing covers cash-settled futures on individual equities and exchange-traded fund shares, including perpetual single-stock futures. Notice registrations had already gone in earlier in September before the product proposal arrived.
Bitnomial Exchange filed a separate proposal the same day covering listing standards, customer margin, and related rules. Product records showed 10 stock perpetual submissions in pending status, including AAPL, MSFT, NVDA, TSLA, AMZN, AVGO, MU, GOOGL, and PLTR. Bitnomial’s securities filing proposes a 24/5 weekly session from Sunday evening through Friday and a 15.25% minimum initial and maintenance customer-margin floor. One standard contract would represent 100 shares. Funding would be calculated three times daily. The exchange would halt a stock perpetual whenever the primary listing exchange halts the underlying security.
Related coverage has also noted that Payward planned to use Bitnomial’s regulated infrastructure for U.S. perpetual products, subject to approval, with Bitnomial Exchange and Bitnomial Clearinghouse named as the entities handling listing, clearing, and settlement. That is a reminder that this is not only a product fight. It is an infrastructure fight.
Same-day race, different dials: Kalshi — 15.50% margin, daily funding near the cash close Bitnomial — 15.25% margin, funding three times a day Coinbase — cash-settled single-stock and fund perpetuals, also pending
When three regulated venues show up with similar toys on the same date, you can assume the commercial pressure has been building for months. Nobody coordinates a coincidence that neat unless the legal path finally looked open enough to try.
The Bitcoin Perpetual Shadow
Kalshi already has a live precedent in crypto. The futures regulator approved its BTCPERP contract on May 29 after reviewing it as a futures contract tied to Bitcoin’s spot price. The approval release warned that perpetual design “may not be suitable for all asset classes” and encouraged exchanges to seek review for perpetuals referencing assets outside that Bitcoin order. Kalshi launched the Bitcoin perpetual in early June and later listed other crypto and precious-metals perpetual products.
Stock filings use the joint security-futures process because the underliers are securities. That distinction is not cosmetic. A coin perpetual and an Nvidia perpetual do not raise the same questions about insider news, opening auctions, or Reg SHO-adjacent market structure, even if the payoff diagram looks similar on a whiteboard.
A separate federal case remains pending over the Bitcoin perpetual decision. An exchange group sued the Commission and its chair on June 18, arguing that the May 29 order and related perpetual-contract policy should be vacated. The lawsuit concerns classification and policy. It is not a ruling on Kalshi’s September 18 stock applications. The government moved to dismiss on September 2. No merits ruling had been issued by the latest docket update reviewed. A September 8 schedule gives the plaintiff until October 2 to respond, sets an October 16 reply deadline, requires discovery by November 13, and sets cross-motions for November 20, with later briefing into December.
Does that case kill stock perpetuals? Not by itself. Does it inject uncertainty into how far perpetual design can travel beyond Bitcoin? Obviously. Courts do not have to resolve a stock filing to change the temperature around the whole category.
Who This Product Is For, And Who Should Walk Away
Let’s be blunt. A cash-settled stock perpetual is useful if you need directional exposure when the cash tape is dark and you accept funding as a cost of staying in the trade. It is also useful if you hedge a cash book and want a listed, cleared instrument instead of an informal swap. It is a poor substitute for owning the shares if you care about dividends, voting, or tax lots. It is a worse substitute if you think “no expiry” means “no risk of being closed out.”
Weekend gaps are the unromantic part. A 23-hour weekday session still leaves Saturday. It still leaves that daily maintenance hour. A number can move in the dark and greet you with a margin call when the window reopens. I have seen too many people confuse longer trading hours with safer trading hours. Extra hours just mean more chances to act on incomplete information.
- Hedgers who want listed after-hours equity exposure
- Active traders who already live in funding-rate math
- Not long-term holders seeking shareholder rights
- Not anyone who cannot explain funding, deadbands, and halt logic in one sitting
In my view, the healthiest way to read this filing is as market-structure news, not as a hot tip. If approval comes, liquidity will decide whether the product is a real venue or a press-release contract. Tight spreads around the cash close would be a good sign. Wide, one-sided books at 11 p.m. would tell a different story.
What Approval Would Change In Practice
If these contracts go live, price discovery after 4 p.m. Eastern becomes less dependent on odd-lot prints and overseas listings. News that currently sits in a holding pattern until the next cash open could express itself immediately in a cleared U.S. future. That can be healthier. It can also be noisier. A thin Sunday book can overshoot and then mean-revert once New York arrives.
Options desks would notice. A liquid single-stock perpetual becomes another input for implied move estimates overnight. Cash-and-carry desks would notice too, because funding and basis would create a new arb surface. Retail platforms would notice last, then suddenly all at once, which is usually when the education gap shows up.
There is also a competitive angle among venues. If one house gets the liquid names first and keeps the basis honest, flow may concentrate. If three houses split the same seven tickers, you could get fragmented books and messy settlement comparisons. Fragmentation is not fatal. It is just expensive for anyone who assumes “the perp” is one price.
The Risks Regulators Will Keep Poking
Manipulation around the cash close is the obvious worry because funding is tied to that window. If a perpetual’s daily settlement leans on a price that can be leaned on, funding becomes a weapon instead of a stabilizer. Halt logic is another worry. A stock can halt for news, for volatility, or for system issues. Mapping those events onto a 23-hour derivative without creating orphan positions is harder than it sounds.
Customer understanding sits right behind those market-structure issues. Plenty of people hear “perpetual” and think the position cannot be taken away. They do not hear maintenance margin, funding caps, or summary abrogation windows. A product can be legally tidy and still be socially messy if the user interface hides the financing.
Then there is the suitability question the Bitcoin order already flagged in different language: perpetual design may not travel cleanly across asset classes. Equities have corporate actions, earnings blackouts, index rebalances, and short-sale regimes. A contract unit equal to 100 shares looks neat until a split, a special dividend, or an ETF creation imbalance shows up. Rulebooks can handle those events. Handling them well under speed is the test.
How I Would Watch The Next Few Weeks
Ignore launch rumors until pending status changes. Watch whether comment files fill with thoughtful market-structure notes or with form-letter noise. Watch whether the November 2 waypoint slips because futures approval is still missing. Watch the court calendar on the Bitcoin policy fight, not because it decides this filing on day one, but because it shapes how adventurous staff are willing to be.
Compare the three rule sets side by side as they evolve. Margin floors that look similar on a term sheet can hide different concentration limits, different liquidation waterfalls, and different close-price sources. Funding once a day at the cash close is not the same organism as funding three times a day. Small differences compound when a name gaps 6% in Asia.
And keep the underlier list honest. AAPL and SPY are proof-of-concept names. If the first approved set suddenly includes thinner stories, that would tell you listing standards are more flexible than the first draft suggested. Flexibility is not automatically bad. It just changes the risk conversation.
A Straight Read On Where This Stands
Kalshi asked for a regulated way to list stock and ETF exposure that does not expire, trades most of the week, clears in-house, and finances itself around the U.S. cash close. Competitors asked for close cousins on the same day. The public databases still say pending. That is the whole story, minus the adjectives.
I do not think this is a gimmick. The demand for after-hours equity risk is real. I also do not think approval is a formality. Security futures sit in a legal seam that rewards careful drafting and punishes sloppy analogies to crypto. The firms that treat this as paperwork will lose time. The firms that treat this as market design might actually build something people can use without inventing a new way to blow up on a Monday open.
Until a status flips from pending to approved, the only disciplined posture is curiosity with both hands on the rulebook. Read the hours. Read the margin. Read the funding cap. Read the halt language. Then decide whether a contract with no expiry date is a tool you needed, or just a more fashionable way to stay awake while the cash market sleeps.
