Kalshi will end trading volume awards under a $5 billion transaction review

Kalshi申请终止交易量激励计划，数十亿美元以太坊永续合约交易引发质疑

Kalshi 已提交文件，最早将于 10 月 13 日终止其交易奖励计划。与此同时，该平台因涉及数十亿美元的重复以太坊（Ether）永续合约交易而持续面临质疑。

核心要点

• 文件显示，Kalshi 计划不晚于 10 月 13 日结束其交易量激励计划。
• 数据显示，截至 9 月 29 日，9 月份的交易量达到 529.8 亿美元，超过了 8 月份的 386.7 亿美元总额。
• 据报道，超过 50 亿美元的相似以太坊永续合约交易引发了监管机构的审查。
• Kalshi 否认存在对敲交易（Wash Trading），并称这些重复成交来自做市商和速度更快的交易者。
• 路透社报道，Kalshi 正在讨论以约 400 亿美元的估值进行 10 亿美元的融资。

终止激励计划的背景与细节

美国商品期货交易委员会（CFTC）9 月 28 日的 filing 显示，KalshiEX 打算终止其“交易量激励计划”（Volume Incentive Program）。该计划根据合格交易者在其符合条件的交易活动中的占比来奖励他们。然而，该文件并未说明终止该计划的原因，也未将此决定与该交易所近期涉及的永续合约交易量指控联系起来。

The move came within a record month for Kalshi. According to data cited by The Block, as of September 29, trading volume in September was US$52.98 billion, which was already higher than the total of US$38.67 billion in August. August's data follows July, when Kalshi, Polymarket and their U.S. divisions recorded total transaction volume of approximately $50.6 billion, of which Kalshi contributed approximately $37.7 billion.

Kalshi originally submitted the volume incentive plan to the CFTC in February 2023 and expected it to take effect on March 1 of that year. At the time, the exchange said the plan was aimed at increasing trading volume and liquidity on its central limit order book and encouraging members to participate.

Under the latest terms, eligible traders receive a portion of a fixed reward pool based on their share of qualified transactions completed in a market. Transactions typically need to occur between $0.03 and $0.97, although the document specifically states that the price range does not apply to perpetual contracts. When disclosed on the relevant market page, eligible trading volume may be limited to Maker or Taker transactions.

Kalshi's document states that each reward period cannot exceed a maximum of 31 days. Event contract rewards are capped at US$0.005 per person per contract. If the chief regulatory officer determines that an activity is abusive or inconsistent with the purpose of the plan, Kalshi can remove a trader from the plan.

The CFTC database separately lists the "Deposit and Trading Reward Incentive Plan" Kalshi filed on September 25, which is in a 10-day review period. Therefore, terminating the earlier "Volume Incentive Program" does not mean that Kalshi has eliminated all trading incentives declared to regulators.

Ethereum deal triggers review

Questions about Kalshi's crypto asset trading volume have arisen before the termination plan was submitted. Previous reports on Kalshi's crypto volume knock-on trading allegations detailed trader Beni's allegations, pointing out that the 24-hour trading volume of Ethereum (ETH) perpetual contracts is approximately US$538.6 million, while the value of open interest is only approximately US$3.1 million.

The Wall Street Journal subsequently reported that the CFTC was investigating almost identical trading models involving Ethereum perpetual contracts, many of which were traded in amounts close to $5,500. According to the report, in the past month or so, due to the size of duplicate transactions, the cumulative transaction volume has exceeded US$5 billion. The Wall Street Journal described the regulator's action as a review and did not report a formal law enforcement investigation had been opened.

Kalshi refuted allegations of knock-on transactions. In a September 22 response, the company said the identified transactions involved traders who truly wanted to be on the opposite side of the transaction, including hundreds of buyers who interacted with market makers that issued static quotes. Kalshi stated that self-matching is mechanically prevented, and coordinated knock-on transactions are prohibited and monitored.

该交易所写道：“Kalshi 上不存在对敲交易”，并认为重复的交易规模源于其做市商安排的结构以及交易者反复点击报价订单。Kalshi 表示，它尚未就所报告的审查联系过 CFTC。

永续合约流动性奖励是另一回事

Kalshi 的回应指出了交易量奖励与其永续合约市场中使用的流动性提供者激励之间的一个重要区别。

公司解释称，其永续合约做市商计划通常支付给参与者费用，以要求他们在规定的期限内保持指定大小的买卖订单在定义的价差内。Kalshi 表示，这些安排奖励的是静态流动性，而不是最终针对报价发生的交易量。

因此，9 月 28 日终止“交易量激励计划”的文件不应被单独解读为确认 Kalshi 已终止其在回应有争议的以太坊交易时所引用的特定流动性安排。该文件涉及的是单独命名的“交易量激励计划”，并未声明最近的审查导致了其终止。

Kalshi 今年迅速扩大了永续合约业务。9 月份，它添加了五个涵盖 BNB、Cardano、Worldcoin、Aave 和 Venice Token 的加密合约，使其加密永续合约 offerings 达到比特币及 17 种山寨币。Kalshi 美国加密永续合约系列的扩张，紧随此前永续合约交易量在推出后两周内突破 55 亿美元的历史时期。

交易量与估值持续攀升

Despite the ongoing controversy surrounding its crypto transaction data, Kalshi's September activity continued to rise. The $52.98 billion transaction volume recorded as of September 29 was already approximately 37% higher than the $38.67 billion in August, although September data were still incomplete at the time of the data snapshot.

For comparison, Kalshi generated revenue of US$37.7 billion in July, when Kalshi, Polymarket and their U.S. divisions jointly forecast market trading volume reached a then-record level of US$50.59 billion. Kalshi provided about three-quarters of this total.

As trading activity increases, investor interest is also heating up. Reuters reported on September 29 that Kalshi is in high-level negotiations and plans to raise about US$1 billion at a valuation of nearly US$40 billion. According to people familiar with the matter, Sequoia Capital and Wellington Management are discussing leading the financing, with Tiger Global and Dragoneer among potential participants.

If the transaction is completed at this level, it will be another milestone after Kalshi's previous US$22 billion valuation in its May 2026 financing. Reports of a $40 billion valuation are still in the negotiation stage, and Reuters pointed out that final terms could still change.

与此同时，ARK Invest 通过 ARKK、ARKW 和 ARKF 基金获得了这家私营公司的直接敞口。9 月追踪的持仓数据显示，这三只基金均持有 Kalshi 头寸，而 ARK 公开估计，预测市场最终每年可能产生 1 万亿至 5 万亿美元的交易量。