Polymarket US is a different legal entity from Polymarket.com

If you are in the United States and someone tells you "Polymarket is legal now", they are talking about QCX LLC, doing business as Polymarket US, which is a CFTC designated contract market. They are not talking about polymarket.com, which is the offshore platform that paid a $1.4 million civil monetary penalty to the CFTC in January 2022 and was ordered to wind down its non-compliant markets.

Same brand. Two entities, two regulatory regimes, and the distinction decides what you can legally access.

The primary evidence

CFTC Letter No. 26-14, dated 13 May 2026 and issued jointly by the Division of Market Oversight and the Division of Clearing and Risk, lists the firms that have sought no-action positions on swap reporting for fully collateralised event contracts. Two Polymarket entities appear by name:

• QCX LLC d/b/a Polymarket US
• QC Clearing LLC d/b/a Polymarket Clearing

They sit in a list alongside KalshiEX LLC and Kalshi Klear LLC, the Chicago Mercantile Exchange, ForecastEx, Railbird Exchange, Bitnomial, Gemini Titan, Gemini Olympus, Aristotle Exchange, Electron Exchange, FMX Futures Exchange (formerly Cantor Futures Exchange), Rothera Exchange and Clearing (formerly LedgerX), and North American Derivatives Exchange trading as Crypto.com.

That list is worth sitting with. It is, effectively, the roster of venues operating event contracts inside the CFTC's registered perimeter as of May 2026, published by the regulator itself rather than assembled by a blog.

What the 2022 order actually said

CFTC Release 8478-22, dated 3 January 2022, concerns Blockratize, Inc. d/b/a Polymarket. The order:

• imposed a $1.4 million civil monetary penalty
• required Polymarket to wind down all non-compliant markets
• required it to cease and desist from further violations

The conduct began around June 2020, and the platform had offered more than 900 separate event markets. The Commission's operative finding was that

> such event market contracts, each of which is composed of a pair of binary > options, constitute swaps under the CFTC's jurisdiction

which is why they had to be on a registered exchange. Polymarket was neither a designated contract market nor a registered swap execution facility at the time.

This is the document that made polymarket.com geofence US users. It is also the reason the US-facing business had to be built as a separate, registered entity rather than by simply switching the old one back on.

What the no-action letter does and does not do

Letter 26-14 is narrow, and it is worth being precise because "CFTC approval" gets thrown around loosely.

The Divisions said they will not recommend enforcement against a designated contract market, a clearing organisation or their participants for failing to comply with Regulations 38.8(b), 38.10, 38.951 (only so far as it requires Part 45 compliance), 39.20(b)(2), and applicable provisions of Parts 43 and 45, with respect to "Covered Contracts".

A Covered Contract has three characteristics, all three required:

1. based on the outcome of an underlying occurrence, the extent of an

occurrence, or a contingency;

1. listed for trade on a designated contract market; and
2. traded as a fully collateralised position as defined by Regulation 39.2.

So this is relief from swap data reporting and recordkeeping, conditional on reporting through the futures-style route instead. It is not a blessing of any particular contract, and it is emphatically not a ruling on state law.

Point 2 is the one that matters to you as a user: the relief attaches to contracts listed on a DCM. Polymarket US is one. Polymarket.com is not.

Fully collateralised, and why the phrase keeps appearing

Regulation 39.2 defines a fully collateralised position as one where the clearing organisation holds, at all times, funds in the form of the required payment. In plain terms: the full payout is posted up front.

That is genuinely different from a sportsbook, where the operator takes the other side and owes you if you win. On a fully collateralised event contract the money for your win is already sitting there. It is the strongest single structural argument in this category, and it is also the reason the CFTC treats these venues differently from ordinary derivatives markets on reporting.

It does not mean insured, and it does not mean your account is protected against every failure mode. It means the payout is not a promise.

Practical read

• Check which entity you are on. Polymarket US, operated by QCX LLC, is the

registered venue. If you are a US person, that is the one you can use.

• Federal registration is still not state permission. These are separate

questions. A designated contract market can still face state litigation, as Kalshi is doing.

• The 2022 order is not ancient history to hide. It is the reason the

current structure exists, and any page that omits it is giving you the story with the load-bearing part removed.

What we could not verify

• The $112 million QCEX acquisition price. Widely reported, and we did not

retrieve a filing or company release confirming it. Treat it as secondary.

• Exactly which contracts Polymarket US lists today, and whether they match

polymarket.com's catalogue. We have not audited both catalogues.

• Whether QCX's DCM designation has conditions attached. Letter 26-14

establishes that QCX LLC sought no-action relief as a DCM. It does not set out the terms of the designation itself, and we did not retrieve those.

• State-level access. Not addressed by any document on this page.

Questions people actually ask

Is Polymarket legal in the US? Polymarket US, the entity QCX LLC, is a CFTC designated contract market and is named in CFTC Letter 26-14 dated 13 May 2026. Polymarket.com, operated by Blockratize Inc., paid a $1.4 million CFTC penalty in January 2022 and was ordered to wind down non-compliant markets.

What is the difference between Polymarket US and Polymarket.com? Different legal entities under one brand. Polymarket US is QCX LLC, a registered designated contract market with its own clearing entity, QC Clearing LLC. Polymarket.com is the offshore platform that was the subject of the 2022 CFTC order.

Why did Polymarket get fined? CFTC Release 8478-22, 3 January 2022: operating an unregistered facility for event-based binary options from around June 2020, having offered more than 900 event markets, without being a designated contract market or a registered swap execution facility. The penalty was $1.4 million.

Does the CFTC no-action letter mean Polymarket is approved? No. Letter 26-14 grants narrow relief from swap reporting and recordkeeping under Regulations 38.8(b), 38.10, 38.951, 39.20(b)(2) and Parts 43 and 45, on condition the firm reports through the futures route instead. It approves no contract and settles no state law question.

What does fully collateralised mean? Under Regulation 39.2, the clearing organisation holds funds equal to the required payment at all times, so your payout is already posted rather than owed to you by a counterparty. It is not the same as being insured.

Which prediction market venues are CFTC-registered? CFTC Letter 26-14 names KalshiEX, Kalshi Klear, QCX (Polymarket US), QC Clearing, the Chicago Mercantile Exchange, ForecastEx, Railbird, Bitnomial, Gemini Titan, Gemini Olympus, Aristotle, Electron, FMX Futures and Rothera (formerly LedgerX), among the firms that sought this relief.