Kalshi Launches Sector KPI Markets on Carbon Arc Data, Which Already Settles Its Sportsbook Ad Spend Contracts

Kalshi has started listing contracts on industry-wide indices of card spending, point-of-sale sales and app downloads, all settled on figures from the data company Carbon Arc. The same vendor already settles Kalshi markets on sportsbook and casino advertising and on DraftKings and FanDuel downloads, and its numbers appear to sit outside the test the SEC used on 13 October to class Cboe's KPI options as securities.

• Kalshi said on 23 October it had launched sector KPI contracts that settle on Carbon Arc data, letting traders take a view on a whole category, such as AI app downloads, rather than on one company
• Kalshi's market data lists nine sector "arrays", from fast food card spend to AI chat app downloads, each an equally weighted average of year-on-year indices for four or five named companies, first listed on 15 October
• Carbon Arc already settles 109 Kalshi series, including Online Sportsbook Ad Spend, which settled at 127.45 for September, and Casino Ad Spend, which settled at 71.34
• A search of the CFTC's public filings found no certification describing the sector contracts; the one Kalshi certification found that names Carbon Arc, from June, covers rankings of company credit card spend
• The SEC's approval of Cboe's binary KPI options rested on figures companies report to the SEC; Kalshi's indices settle on a data vendor's estimates instead

Kalshi Takes Its Company KPI Markets to the Sector Level, With Carbon Arc as the Referee

Kalshi announced on 23 October "a new class of event contracts" tracking credit card spend, point-of-sale data, foot traffic and app downloads across whole industries, settled against Prisms data from Carbon Arc. It already lists KPI contracts on single companies; the new ones apply the same metrics to a sector, according to the announcement. Chief executive Tarek Mansour called atomising equities into events and KPIs "one of Kalshi's best use cases" and the sector level "the next logical step".

Kalshi's public market data supplies the detail the announcement leaves out. Each array is the equally weighted mean of its members' year-on-year indices, where 100 means the same value as a year earlier. The AI chat apps array holds ChatGPT, Claude, Gemini and Grok at 25% each; the fast food card spend array holds McDonald's, Starbucks, Chipotle, Wendy's and Chick-fil-A at 20% each. The others cover big box card spend, delivery, streaming and rideshare app downloads, and energy drink, nicotine and soda point-of-sale spend. Each contract asks whether the October index will finish above a strike, using the value Kalshi records a few days after the month ends (four days for fast food, seven for AI apps); later revisions do not count. By 24 October the AI array had traded 332 contracts and the fast food array about 5,670.

Kalshi says the contracts open hedging uses for retailers, restaurant operators and app developers, and that its prices form a "crowdsourced, continuously updated forecast" of where an industry is heading. It gave no evidence of hedging demand. Jack Such of Kalshi told Business Insider the aim was to "ETF-ify" its corporate KPI markets.

Carbon Arc Already Prices Gambling Advertising

Carbon Arc, founded in 2021 according to the release, calls itself "the neutral data layer for the AI economy". Its website lists Kalshi among its clients alongside Morgan Stanley, Perplexity and Paychex and claims more than 500 proprietary data assets across eight sectors. Chief executive Kirk McKeown was previously head of proprietary research at Point72, according to Business Insider. Its card data comes from a panel: a Kalshi filing bars staff of Facteus "and the nine underlying provider sources feeding the panel" from trading.

The relationship predates the announcement. Kalshi's API lists 109 series that name Carbon Arc as their settlement source, among them 34 on company card spend, 24 on app downloads and 11 on advertising spend by category, including Online Sportsbook Ad Spend, Casino Ad Spend, and DraftKings and FanDuel downloads. The September sportsbook advertising index settled at 127.45, which under Kalshi's definition means 27.45% growth on September 2025, and casino advertising at 71.34, a fall of about 29%. DraftKings' September download index settled at 161.98 and FanDuel's at 62.5. The September sportsbook advertising event traded 66,443 contracts and DraftKings downloads 119,647, Kalshi's data shows. The rules do not say which channels or advertisers the ad spend indices cover.

The CFTC Record Is Thinner Than the Product List

Kalshi self-certifies contracts with the Commodity Futures Trading Commission (CFTC). A search of KalshiEX product and rule filings on the CFTC website, through entries dated 22 October, found no certification describing sector KPI contracts and no amendment adding Carbon Arc as a source. The certification Kalshi links from its Carbon Arc markets, a file named CARBONARC.pdf, is its 16 July 2025 certification of a generic economic statistics contract whose terms name official statistical agencies and Trading Economics; it says a new source "can be added via a Part 40 amendment". The one public certification found that names Carbon Arc, filed on 18 June 2026, covers which company records the highest card spend in a set. Kalshi's source appendices are confidential.

Kalshi Is Building on the Ground the SEC Left Open

The Securities and Exchange Commission (SEC) approved Cboe's binary KPI options as options on a security because they are limited to issuers with listed equity and settle on KPIs those issuers report in SEC filings, figures whose value moves the share price. The order said it "does not foreclose" other structures, and that similar products "may be structured in different ways and be subject to CFTC jurisdiction". Kalshi's contracts differ on both counts: they settle on a vendor's panel estimate rather than a company disclosure, and the arrays blend several companies. The statute's event test for a security-based swap covers an event relating to a single issuer only where it "directly affects the financial statements, financial condition, or financial obligations of the issuer", and a third party's estimate of DraftKings downloads arguably does not. Neither agency has ruled on that question, which sits inside the joint request for comment on the swap definitions the two agencies issued on 18 June; Kalshi was among the commenters who urged the SEC to wait for it, and the CFTC has since proposed to define event contracts as swaps.

For Operators, the Data Is Now Someone Else's Market

Sportsbook advertising and app downloads are now tradable on numbers no operator produces or can correct. In September Carbon Arc's indices put DraftKings' download growth at 161.98 and FanDuel's at 62.5, and those are the numbers the contracts settled on, whatever the companies' own figures show. The June filing bars Carbon Arc staff, panel providers and company insiders with access to their own card spend, but the ad spend markets list only source agency staff and holders of non-public information. An operator's marketing team knows its budget before any panel measures it, and the reported KPMG case over Polymarket bets on audit clients shows that markets near company data attract insiders. Kalshi's ad spend rules carry a standard line saying it is not affiliated with Carbon Arc.

The Hedging Case Is Still a Promise

Trading in tens of thousands of $1-notional contracts a month is not where a restaurant chain hedges a consumer slowdown. The arrays look more like a retail answer to Cboe, whose clearing house received temporary SEC registration on 23 October, with KPI options planned for Robinhood in the fourth quarter.

Kalshi has built a product line on data it neither produces nor files with any regulator, settled on numbers the SEC's KPI test does not obviously reach. Whether regulators treat a vendor's estimate of a company's sales as a commodity or as a company event will decide how far it can go.