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#Prediction Markets#Kalshi#Polymarket#Regulation

Prediction Markets Regulation Outside the US: A Global Map

The CFTC model is the exception, not the template. More than 30 jurisdictions now restrict access to at least one major platform, and the UK, EU, and Asia each classify event contracts differently.

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Jared Polites

Aug 25, 2026

PredictionHero article image: Prediction market regulation outside the US.

TL;DR

  • The US is the outlier: the CFTC designated Kalshi a regulated exchange in November 2020, classifying its event contracts as commodity derivatives. Almost no other national regulator has made that same call.
  • The UK Gambling Commission's February 2026 guidance treats event contracts as gambling, not a financial product. Polymarket geoblocks UK visitors rather than seek a UK license.
  • The EU has no bloc-wide rule. France's gambling regulator ordered ISPs to block Polymarket in July 2026, Germany treats these products as illegal gambling, and nine European regulators issued a joint warning about prediction markets in June 2026.
  • Singapore blocked Polymarket at the network level in January 2025, Hong Kong's SFC-affiliated investor-education body has warned traders they have no securities-law protection, and South Korea ordered its own block in August 2026, one of more than 30 jurisdictions now restricting access to the platform.

Researching prediction markets from outside the US? The framework you keep running into online, built around the CFTC, does not apply to you, and each classification below can change as regulators keep ruling. The United States has a federal regulator that has called certain event contracts a commodity derivative. Almost nowhere else has made that same call.

The UK treats event contracts as gambling products under the Gambling Commission. Most of the EU treats them as a legal gray zone that individual member states are only beginning to define. Singapore, Hong Kong, mainland China, and South Korea have each already acted, in different directions, against the platforms in this space.

This is a map of how five major jurisdictions actually classify event contracts, and what that means for the platforms PredictionHero tracks: Polymarket, Kalshi, Limitless, Predict.Fun, Opinion. None of this is legal advice. Check a platform's own terms and your local law before trading.

How Does the US Treat Event Contracts Differently From Everywhere Else?

Start with the US, because every other jurisdiction below gets compared to it. The CFTC designated Kalshi a Designated Contract Market in November 2020, which means its event contracts are treated as derivatives, not gambling products, and federal oversight preempts most state-level restriction. That framework is the exception globally, not the rule. Almost nowhere else has a dedicated federal regulator that has affirmatively classified event contracts as a commodity derivative.

Is Polymarket Legal in the UK?

No, not as a licensed, real-money product. Polymarket does not hold a UK gambling license, and the platform geoblocks UK IP addresses rather than seek one. The UK Gambling Commission addressed the category directly in a February 2026 blog post, writing that "subject to the specific business model a 'prediction market' operator wished to offer in Great Britain, it would appear current products would fall within the definition of a 'Betting Intermediary' under UK legislation."

The Commission warned that operators "should take steps to ensure they are not targeting or transacting with consumers in Great Britain," since "there are criminal offences associated with operating without an appropriate licence here."

That statement addressed prediction markets as a category rather than naming any single platform, but the practical effect is the same across the industry. Providers need a Gambling Commission license to operate legally, advertising is restricted the same way sports betting advertising is restricted, and consumer protection rules (affordability checks, self-exclusion schemes) apply. The one narrow exception is spread betting, which the FCA regulates as a financial product rather than gambling.

Kalshi's CFTC status does not travel. A license from the CFTC has no standing with the Gambling Commission. Any platform serving UK customers legally needs its own UK gambling license, full stop.

Is There a Single EU Rule for Prediction Markets?

No, and that's the most important thing to understand before making any claim about "European regulation." Gambling law in the EU is set at the member-state level, not by Brussels. Gambling has sat outside the EU's cross-border passporting rules since European governments agreed to carve it out of the Services Directive back at the 1992 Edinburgh European Council, and that carve-out is still what makes a single "EU license" impossible today.

MiFID II, the EU's core financial-markets directive, wasn't written with event contracts in mind. ESMA, the EU's securities regulator, tried to draw a line in July 2026, warning that a product's label doesn't determine its legal status: an "event contract" could still qualify as a MiFID II financial instrument, and fall under the EU's existing marketing restrictions for retail investors, depending on its underlying economic terms, while a gambling-classified contract stays a member-state matter.

Some member states have already acted on their own. France's regulator, the ANJ, ordered French internet providers to block Polymarket on 16 July 2026, treating it as unlicensed gambling. The ANJ's own numbers put the site at 578,751 visits and 205,057 unique French visitors in June 2026 alone, the month before the block.

Germany's regulator, the GGL, treats these products as illegal gambling under the country's Glücksspielstaatsvertrag, and joined eight other national regulators, including Belgium, Italy, the Netherlands, Poland, Portugal, Spain, Switzerland, and the UK's Gambling Commission, in a joint statement on 19 June 2026 flagging prediction markets for player-protection gaps and manipulation risk.

Malta, long the licensing hub for online gambling operators serving the EU, issues licenses through the Malta Gaming Authority that some platforms use as a base for EU-facing operations. Because gambling sits outside the Services Directive's passporting regime, an MGA license doesn't reclassify a product as a financial instrument, or extend automatic access, anywhere else in the bloc.

The practical result: a platform can be accessible in one EU country and functionally unavailable, or actively blocked, in the next. Anyone building cross-platform comparisons for a European audience needs to check country by country, not treat "the EU" as one regulatory zone.

How Do Singapore, Hong Kong, China, and South Korea Regulate Prediction Markets?

Asian regulation runs in two directions, and neither looks like the US model.

Singapore's Gambling Regulatory Authority, operational since August 2022, licenses gambling tightly, and event-outcome contracts sit inside that regime under the Gambling Control Act 2022. Singapore blocked access to Polymarket at the network level on 12 January 2025, one of the earliest jurisdiction-wide actions taken against a prediction market platform anywhere; enforcement of that kind of block has sat with the Singapore Police Force since then.

An individual caught gambling with an unlicensed operator faces a fine of up to S$10,000, up to six months in prison, or both. An unlicensed operator itself faces up to S$500,000 and seven years.

Hong Kong takes a similarly tight approach to gambling under its Gambling Ordinance, which grants the Hong Kong Jockey Club exclusive rights to horse racing, football betting, and the Mark Six lottery. On the financial-markets side, the Investor and Financial Education Council, a body affiliated with Hong Kong's Securities and Futures Commission, warned in April 2026 that prediction-market participants "do not have the protections under the Securities and Futures Ordinance or any laws and regulations administered by the SFC," and that trading on these platforms "may constitute illegal gambling" because it goes beyond wagering on probabilities.

That's a warning from an SFC-affiliated investor-education body, not a formal SFC ruling, but it signals which way Hong Kong's classification fight is currently leaning.

Mainland China prohibits online gambling outright. Article 303 of China's Criminal Law criminalizes gambling for profit, and a 2010 joint opinion from the Supreme People's Court, the Supreme People's Procuratorate, and the Ministry of Public Security extended that liability explicitly to internet and mobile-based operations, with no carve-out for prediction markets or decentralized platforms.

South Korea restricts most forms of online betting for residents to two narrow, government-run channels: Sports Toto through the Korea Sports Promotion Foundation, and horse racing through the Korea Racing Authority. Both are unrelated to the platforms PredictionHero tracks.

On 18 August 2026, Korea's Communications Standards Commission ordered domestic providers to block Polymarket, calling it a "substantive illegal gambling environment" and rejecting the platform's decentralization defense outright: "Regardless of whether a service is decentralized or centralized, its technological characteristics and service methods cannot exempt it from the application of domestic laws." By that point, per CoinDesk's count, Korea had become one of more than 30 jurisdictions restricting access to the platform.

That scale, more than 30 jurisdictions acting on the same underlying classification question within about 18 months of each other, says less about any single platform's conduct than about how unresolved this fight still is worldwide. A platform's compliance posture and where its users can actually reach it from remain two different maps, and that gap narrows every time a new regulator issues a ruling.

Why Does It Matter Whether an Event Contract Is Classified as a Bet or a Derivative?

Every regulatory outcome above traces back to one question: is an event contract a bet, or is it a derivative?

Call it a bet, and you get the UK model: a gambling license, advertising restrictions, consumer protection rules built for betting shops and sportsbooks.

Call it a derivative, and you get the US model: margin rules, position limits, and a regulator built for commodity markets, not casinos.

Most of the world has not made that call definitively yet. That ambiguity is exactly why the space looks so fragmented from the outside. A platform can be a fully compliant financial product in one country and a blocked, unlicensed operation in the next, with the underlying contract unchanged. The classification, not the product, is what moves.

JurisdictionPrimary ClassificationRegulatorPractical Effect
United StatesDerivative (Kalshi) / mixedCFTCFederal designation (since Nov. 2020) preempts most state gambling law
United KingdomGambling productGambling CommissionNo license issued; Polymarket geoblocks UK visitors
European UnionSet by member state, no bloc-wide ruleNational regulators (ANJ, GGL, MGA) + ESMAFrance ordered an ISP block of Polymarket (July 2026); access varies by country
SingaporeGambling productGambling Regulatory AuthorityBlocked nationally since January 2025
Hong KongContested (gambling vs. financial derivative)SFC-affiliated IFEC / gambling regulatorsLicensing path depends on classification outcome
Mainland ChinaProhibitedState prohibition (Criminal Law Art. 303)No legal access
South KoreaRestrictedKorea Communications Standards CommissionBlocked nationally since August 2026

How Does This Patchwork Shape Which Platforms You Can Actually Access?

This is why PredictionHero exists as a neutral aggregation layer rather than a single-jurisdiction product. Polymarket, Kalshi, Limitless, Predict.Fun, and Opinion each carry a different regulatory posture depending on where a reader sits, and comparing their odds side by side means understanding that the underlying legal ground is not the same everywhere.

Kalshi's CFTC registration makes it the most straightforward on-ramp for US residents wanting regulated access. Polymarket runs a global, crypto-collateralized model that doesn't map onto any single national gambling or securities framework, which is exactly why regulators in different countries have reached different conclusions about it, and why its accessibility varies so much from one border to the next.

Limitless runs on-chain with a similar crypto-native structure. Predict.Fun, built on BNB Chain, and Opinion, focused on macro event contracts, both serve a trader base that skews toward jurisdictions where crypto-collateralized products have so far faced less direct scrutiny.

Compare odds across all five on PredictionHero, and check each platform's own terms for your jurisdiction before relying on access.

Frequently asked questions

No, not as a licensed, real-money product. Polymarket geoblocks UK visitors rather than seek a Gambling Commission license. The Commission's February 2026 guidance treats event contracts as a betting product, meaning providers need a license to serve UK customers, and unlicensed operation carries criminal penalties there.

No. Gambling regulation is set at the member-state level, and gambling sits outside the EU's cross-border licensing rules. France ordered an ISP block of Polymarket in July 2026, and Germany treats these products as gambling, while Malta issues licenses some platforms use as an EU base elsewhere.

None allow unlicensed access outright. Singapore blocked Polymarket in January 2025 under its Gambling Control Act, Hong Kong's SFC-affiliated investor body has warned traders they have no securities protections, mainland China bans online gambling under its Criminal Law, and South Korea ordered its own block in August 2026.

Because the CFTC designated Kalshi a regulated exchange in 2020, classifying certain event contracts as commodity derivatives rather than gambling products. Most other regulators haven't made that same classification call, which is why the US model looks like an outlier rather than a template.

No. CFTC registration only applies within the United States. Operating in the UK, EU member states, or Asian jurisdictions requires separate licensing under each region's own gambling or financial regulator, and several of those regulators have already ruled against unlicensed access.

Sources

  • Gambling Commission (UK). "Prediction markets – here's what you need to know." Blog post, 4 February 2026. gamblingcommission.gov.uk
  • Autorité Nationale des Jeux (ANJ). "Promotion d'une offre de jeux d'argent illégale : blocage du site Polymarket." Press release, 17 July 2026. anj.fr
  • Gemeinsame Glücksspielbehörde der Länder (GGL). Joint statement of European gambling regulators on prediction markets. 19 June 2026. gluecksspiel-behoerde.de
  • Norton Rose Fulbright. "The EU's approach to prediction markets and event contracts." 2026. nortonrosefulbright.com
  • Ministry of Home Affairs, Singapore. "Gambling Regulatory Authority of Singapore to be Operational from 1 August 2022." mha.gov.sg
  • SBC News. "Singapore defines Polymarket as an illegal gambling site." 13 January 2025. sbcnews.co.uk
  • Home and Youth Affairs Bureau, HKSAR Government. Gambling policy overview (Gambling Ordinance, Cap. 148). hyab.gov.hk
  • The Standard (Hong Kong). "Trading on prediction markets may be illegal in Hong Kong, SFC says." 17 April 2026. thestandard.com.hk
  • China Law Translate. PRC Criminal Law, Article 303 (Criminal Law Amendment XI), official English translation. chinalawtranslate.com
  • Supreme People's Court of China. Explanation of the 2010 joint opinion on online gambling crimes (公通字〔2010〕40号). court.gov.cn
  • The Korea Times. "Korea moves to block Polymarket over illegal gambling." 19 August 2026. koreatimes.co.kr
  • CoinDesk. "South Korea joins more than 30 jurisdictions restricting Polymarket access." 18 August 2026. coindesk.com
  • CFTC. "CFTC Designates KalshiEX LLC as a Contract Market." Press release, 4 November 2020. cftc.gov

PredictionHero aggregates publicly available prediction market data for informational purposes only. This is not financial or legal advice. Prediction markets may not be available in all jurisdictions, and the legal and regulatory status described here can change; verify current status with the relevant regulator before relying on it.

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