Designated contract market

Also written DCM

A US exchange the CFTC has designated under section 5 of the Commodity Exchange Act, and which must keep meeting that section's 23 core principles to stay designated. It is a status of a legal entity, not of a brand, an app or a contract: it names who runs the rulebook and answers to the regulator, not who holds your money, who your broker is, or whether a contract is lawful where you live.

Every US venue in this catalogue calls itself some version of "CFTC-regulated". The phrase with legal weight is narrower, and it attaches to one company in a structure that usually has three. Reading it as a property of the brand, or of the app you downloaded, is how a reader ends up certain of something that is only true of an entity they have never heard of.

How it works

Designation is applied for, and then kept. Section 5 of the Commodity Exchange Act — 7 U.S.C. 7 — has a board of trade apply to the Commission, and 17 CFR 38.3 sets the procedure: an application on Form DCM, reviewed on the 180-day timeframe of section 6(a), after which the Commission approves, denies, or designates the applicant subject to conditions. The statute's sentence is "to be designated, and maintain a designation" — compliance with the core principles is the condition of keeping the status, not only of getting it.

There are 23 core principles, and the statute gives the exchange "reasonable discretion" in how it meets them unless the Commission sets the manner by rule. Part 38 is that rule, one subpart per principle. Four of them are the ones a reader of this catalogue actually runs into:

  • Contracts not readily subject to manipulation. The exchange "shall list on the contract market only contracts that are not readily susceptible to manipulation". Every designated venue in this catalogue names a settlement source contract by contract.
  • Financial integrity of transactions, which the statute spells out as including "the clearance and settlement of the transactions with a derivatives clearing organization", plus rules on the financial integrity of brokers and the protection of customer funds.
  • Protection of markets and market participants, against abusive practices "including abusive practices committed by a party acting as an agent for a participant".
  • Impartial access. 17 CFR 38.151(b) requires impartial access for members, persons with trading privileges and independent software vendors, under criteria that are "impartial, transparent, and applied in a non-discriminatory manner", with comparable fee structures.

What it may list, and to whom. The CFTC's own page says a DCM may list futures or options on "any underlying commodity, index or instrument", adds new products by certifying them or by asking for approval, and "may allow access to their facilities by all types of traders, including retail customers".

One registration out of three

Money on a US event exchange usually touches three separately registered roles. The DCM runs the rulebook, lists the contracts and determines outcomes under its own rules. The derivatives clearing organization holds the collateral and settles. The futures commission merchant is a broker: it holds your account and can charge its own fees. The catalogue has every combination:

  • ForecastEx is a DCM and a clearing organization in one entity, and admits no individuals as members, so every reader arrives through a broker.
  • Kalshi splits exchange and clearing across two companies, KalshiEX and Kalshi Klear, and takes individual accounts directly.
  • Polymarket US is QCX LLC, designated on 9 July 2025, clearing through QC Clearing LLC. Its original order barred brokers from intermediating; an amended order of 24 November 2025 removed that condition — "subject to conditions" in practice.
  • Crypto.com Prediction lists on an exchange the CFTC has carried as designated since 18 February 2004, under three names.
  • Robinhood Prediction Markets is the broker only, routing to three designated exchanges.

What the catalogue records

No field on a card says "DCM", and that is deliberate: it is a fact about an entity, and the card body names the entity. What the fields do show is how tightly the status is bound up with the rest. Of the ten cards in prediction-market venues, six set availability.us_persons to true, and those same six are the ones that settle in cash and require identity verification. They are three different regulatory shapes, not one: four designated exchanges, one broker routing to designated exchanges, and PredictIt, which its card records as operating under CFTC staff no-action relief with a per-contract cap. The four cards that settle in crypto serve no US persons and hold no designation.

Why it matters here

It decides who resolves your contract. On a designated exchange, the exchange determines the outcome under its filed rulebook and its determination is final. That is the other half of the contrast drawn under optimistic oracle; the timetables and the review clauses are in who decides the outcome.

It does not tell you who your account is with. A card for a brokered route and a card for a direct exchange can list the same contract and differ on fees, on who answers when a withdrawal stalls, and on who sends you a tax form. The Kalshi card records that customers coming through a broker may be charged different fees by that broker.

It is not a verdict on the contract. Designation is a status of the exchange, and most contracts on it are self-certified rather than approved; what that means, and the dispute it sits inside, is in event contract or swap.

It is not a verdict on your state. Whether a designated exchange's contracts reach you is a separate question with its own mechanisms, set out in why a venue is unavailable where you are.

It matters to tools as well as venues. The impartial-access rule names independent software vendors alongside members. It does not promise anyone an API; it requires that the criteria for access, whatever they are, be impartial, transparent and applied without discrimination, with comparable fees for equal access. Whether a given client or SDK in this catalogue falls under that wording is a question for the exchange's own rules, not for this page.

Where you will meet this

Cards in the catalogue whose own text uses the term.

Sources

  1. 7 U.S.C. 7, Designation of boards of trade as contract markets (2024 edition of the United States Code) — Office of the Law Revision Counsel, U.S. House of Representatives, read
  2. 17 CFR Part 38, Designated Contract Markets (revised as of April 1, 2025) — Office of the Federal Register and Government Publishing Office,
  3. Designated Contract Markets (DCMs) — Commodity Futures Trading Commission, read
  4. Trading Organizations, designated contract market search — Commodity Futures Trading Commission, read

FAQ

Is Robinhood a designated contract market?

Not for these contracts. The Robinhood Prediction Markets card records Robinhood Derivatives, LLC as a futures commission merchant — a broker — routing event contracts to three exchanges that are designated, KalshiEX, ForecastEx and Rothera Exchange and Clearing. The rulebook that settles your position is the exchange's, not the app's.

Does designation mean the CFTC approved each contract?

No. The CFTC's own description is that a DCM may list a new product by filing a certification that it complies with the Act and the Commission's regulations, or by requesting approval. Designation is a status of the exchange; most contracts arrive by the first route. What that means, and why it is contested, is in the guide on event contracts and swaps.

Where can I check whether an exchange is designated?

In the CFTC's own trading-organisation search, which lists each registered entity by its legal name and status. Search by the operator's name rather than the brand — Polymarket US appears as QCX LLC, and Crypto.com's prediction markets sit on the exchange long known as North American Derivatives Exchange.

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