# How much one account may hold, and what happens past the line

Position limits and accountability levels sound alike and work differently. Where each venue draws the line, in which unit, and what happens past it.

*https://predictionmarkets.tools/guides/how-much-one-account-may-hold · background to Prediction Market Venues*

**Answer:** A position limit is a ceiling: holding past it, or bidding to get past it, breaks the venue's rules. A position accountability level is a tripwire: above it the exchange may ask why you hold the position, stop it growing or order it reduced. A US exchange must adopt one or the other, and Kalshi moved most of its contracts from limits to accountability levels in November 2024. Each venue counts the number in its own unit.

Every regulated venue in this catalogue puts a number on how much of one outcome a single account may own,
and almost none of them call the cap by the same name, measure it in the same unit or enforce it
the same way. The two names that matter are **position limit** and **position accountability
level**. They sound like synonyms. They are opposite ends of the same regulation.

## How it works

### One core principle, two tools

A designated contract market in the United States is bound by Core Principle 5, which
[17 CFR 38.300](https://www.law.cornell.edu/cfr/text/17/38.300) states in one sentence: to reduce
the potential threat of market manipulation or congestion, the exchange "shall adopt for each
contract ... as is necessary and appropriate, position limitations or position accountability
for speculators." Where the Commission has set a federal limit for a contract, the exchange's own
may not be higher. [Section 38.301](https://www.law.cornell.edu/cfr/text/17/38.301) adds that the
exchange must meet parts 150 and 151 of the Commission's regulations, as applicable.

"Or" is the operative word. The regulation lets the exchange choose, contract by contract, and
the two choices behave differently once you reach the number.

### A position limit is a wall

Kalshi's rulebook, version 1.29, defines a Position Limit as "the maximum loss that can be
incurred as a result of a position in a Contract that is allowed to be held or controlled by one
Member or FCM Customer". Rule 5.19 makes it a violation to exceed one, and also to enter bids or
offers "which would cause that Participant to exceed the applicable Position Limit" if accepted.
A first violation may bring a warning letter or disciplinary proceedings; a second within twelve
months of a warning brings proceedings. If you do not reduce as directed, the exchange may
liquidate the excess.

Polymarket US's rulebook, dated 30 September 2026, puts it more briefly in Rule 5.9(a): no person
may enter into a transaction that would cause it to exceed a position limit, except that the
exchange may, on application, exempt a participant "for hedging or other good cause shown", with
new limits of its own and the right to rescind them.

### A position accountability level is a tripwire

Kalshi's rulebook defines a Position Accountability Level as the level of loss "above which
Kalshi may impose restrictions or obligations on the Member". Under Rule 5.18 a participant above
it must give the compliance staff whatever information they consider necessary, and must
"refrain from increasing the size of their position or reduce the size of their position in a
timely fashion if instructed to do so". If the reduction does not happen, Kalshi may liquidate
the position down to the level, or to a limit it imposes on that participant.

Polymarket US defines its level as the size of positions "above which a Participant holding the
positions is required to submit reports". Rule 5.9(b) lets the exchange ask for the nature and
size of the position, "the trading strategy employed", and anything supporting a claim that the
position is a hedge, and to order a reduction from a participant who fails to answer or to order
that a position above the threshold not be increased.

Nothing in either rulebook stops the order that takes you over an accountability level. What
changes is that the position is now the exchange's business.

### Kalshi moved most contracts from one to the other

On [14 November 2024](https://www.cftc.gov/filings/orgrules/rules1114248729.pdf) Kalshi notified
the CFTC that it was replacing "Position Limit" with "Position Accountability Level" for every
contract listed in the filing's appendix, effective no earlier than 27 November 2024 and
alongside rulebook amendments adopting accountability rules. The appendix sets 25,000 contracts
for most of the listed contracts, and 7,000,000 for fourteen of them: seven on the Federal
Reserve and economic data, seven on nominations, confirmations and appointments to office. The reasons given are that accountability levels let Kalshi
"take more holistic views of its members' risk exposures" and that "other event contracts
exchanges use position accountability instead of position limits".

Not every contract moved. The [CONTROL](https://kalshi-public-docs.s3.amazonaws.com/contract_terms/CONTROL.pdf)
terms for which party controls a chamber of Congress, as posted in Kalshi's contract-terms store
on 23 October 2026, still carry Position Limits, in three tiers:

- individuals, $125,000 per member, or $250,000 with a demonstrated hedging need;
- entities, $5,000,000, or $10,000,000;
- eligible contract participants, $50,000,000, or $100,000,000.

Whether a hedging need has been shown "is determined solely at Kalshi's discretion".

### Market makers get more room

Kalshi's Rule 4.5 gives market makers accountability levels ten times those of other members on
contracts where they have quoting obligations, unless otherwise specified, and exempts them from
position limits on those contracts. The filing of November 2024 explains why: a quoter who has
to keep two-sided prices up will otherwise run into the level just by doing the job. Polymarket
US's Rule 4.3 lists "different Position Accountability Levels" among the benefits a market maker
programme may confer. Kalshi's Rule 4.5(c) adds that a market maker's position may never exceed
a limit the CFTC itself has set.
[Who is paid to quote](https://predictionmarkets.tools/guides/who-is-paid-to-quote) covers what the quoter owes in return.

## What the number is counted in

Three things vary, and a number quoted without them cannot be compared with anything.

**The unit.** Kalshi's definitions measure both thresholds as a level of *loss*. Its November
2024 filing rewrote the example clause from "$25,000 per strike" to "25,000 contracts per strike";
on a contract that pays $1, the most a contract can lose is under $1, so the two are close but not
the same. Its FOOTBALLSTATS combo terms, in turn, set "$25,000 per strike, per Member". Polymarket
US's filed combo terms set "$25,000 of notional exposure". OG's
[Fees & Limits page](https://help.og.com/en/articles/12958828-fees-limits), dated 15 September
2026, gives 2,500,000 for a contract value of $1, defined as "the maximum total number of open
positions you can hold for the same event".

**The scope.** Per strike means per market inside a series: one threshold for each price or
outcome line. Per event, as on OG, covers every market attached to the same event together. Per
member means per account holder, and both US rulebooks then aggregate.

**The aggregation.** Kalshi's Rule 5.19(f) applies limits to all accounts in which a person
"directly or indirectly holds positions or controls trading", and to positions held by two or
more persons acting under "an express or implied agreement or understanding", as if one person
held them. Polymarket US's Rule 5.9(a) aggregates accounts as CFTC Regulation 150.4 provides.

| Venue and contract | Type | Number | Unit and scope |
|---|---|---|---|
| Kalshi, most contracts converted in November 2024 | Accountability level | 25,000 | contracts, per strike, per member |
| Kalshi, fourteen contracts in the same filing, Fed, economic data and appointments | Accountability level | 7,000,000 | contracts |
| Kalshi, FOOTBALLSTATS combos | Accountability level | $25,000 | per strike, per member |
| Kalshi, CONTROL, individuals | Position limit | $125,000 | per member; $250,000 with a hedging need |
| Polymarket US, combinatorial sports contracts | Accountability level, no position limit | $25,000 | notional exposure |
| OG | Position limit | 2,500,000 | open positions per event, $1 contract value |
| PredictIt | Investment limit | $3,500 | per participant, per contract |

PredictIt's row comes from a different kind of document. It operates under a CFTC no-action
position rather than as an exchange, and [CFTC Letter No. 25-20](https://www.cftc.gov/csl/25-20/download)
of 14 July 2025 sets "the investment limit for a single participant in any particular contract"
at the federal limit on individual campaign contributions per election, per candidate, which the
letter gives as $3,500 and the Federal Election Commission adjusts every two years.

### An order cap is not a position limit

Polymarket US's [Trading Limits page](https://docs.polymarket.us/learn/trading/access-and-limits/trading-limits)
says a single market buy in the app or on the web is limited to $1,000,000, and that combos have
their own maximum stake. That caps one order, not what you may own; the rulebook separately lets
the exchange set a maximum order size per account from the funds available and the account's
trading behaviour.

## What you can do about it

**Read the line in the contract's own terms.** Every contract's terms carry either "Position
Limit:" or "Position Accountability Level:", and on the two US exchanges read here that one line
is where the number is stated. The rulebook tells you what happens when you reach it; the terms
tell you where it is. A help-centre summary may lag a refiled contract.

**Convert the number to your own unit before you size anything.** A threshold in dollars of loss,
one in notional and one in contracts give three different answers for the same position, and a
per-strike level is not a per-event one.

**Count every account you control.** Splitting a position across accounts, or across people who
trade by agreement, does not reset the count on either US exchange.

**Expect questions above an accountability level, not a rejection.** Have the answer the
rulebooks ask for: what the position is for, and whether it hedges something. A hedging exemption
from a limit has to be applied for and is granted at the exchange's discretion; it is not
assumed.

**Treat order caps and position caps as two checks.** An order may be refused for size while the
position it would create is within every limit, and the reverse.

The venue cards for [Kalshi](https://predictionmarkets.tools/tools/kalshi), [Polymarket US](https://predictionmarkets.tools/tools/polymarket-us) and
[PredictIt](https://predictionmarkets.tools/tools/predictit) carry the rest of each venue's terms; multi-leg contracts and their
own thresholds are on [what a combo contract is](https://predictionmarkets.tools/guides/what-a-combo-contract-is).

## Tools this bears on

- [Kalshi](https://predictionmarkets.tools/tools/kalshi.md) — A CFTC-designated exchange for event contracts, settled in dollars against named sources.
- [Polymarket US](https://predictionmarkets.tools/tools/polymarket-us.md) — Polymarket's CFTC-designated US exchange — dollars, KYC, and no on-chain oracle.
- [PredictIt](https://predictionmarkets.tools/tools/predictit.md) — Political event contracts under CFTC no-action relief, capped at $3,500 a contract.

## FAQ

### What is the difference between a position limit and a position accountability level?

A position limit is a maximum; Kalshi's rulebook makes it a violation to exceed one, or to enter a bid that would exceed it if accepted. An accountability level is a threshold above which the exchange may demand information, tell you not to increase the position, or order it reduced, and liquidate it if you do not comply.

### Can I hold more than the accountability level?

The rules do not stop you at the line. Above it you must answer the exchange's questions about the position and comply if it tells you to stop adding or to reduce. Kalshi's Rule 5.18 lets the exchange liquidate the position if you fail to reduce it as instructed.

### Does a position limit count across several accounts?

Yes, on both US exchanges read for this page. Kalshi's Rule 5.19 applies limits to all accounts a person controls and to positions held by people acting under an agreement, as if one person held them. Polymarket US aggregates accounts under CFTC Regulation 150.4.

### How much may I put into one PredictIt contract?

CFTC Letter No. 25-20 of 14 July 2025 sets the limit for one participant in one contract at the federal limit on individual campaign contributions per election, per candidate. The letter gives that figure as $3,500 and notes that the Federal Election Commission adjusts it for inflation every two years.

## Sources

1. [17 CFR 38.300, Core Principle 5 (Position limitations or accountability)](https://www.law.cornell.edu/cfr/text/17/38.300) — Legal Information Institute, Cornell Law School (Electronic Code of Federal Regulations), read 2026-10-23
2. [17 CFR 38.301, Position limitations and accountability](https://www.law.cornell.edu/cfr/text/17/38.301) — Legal Information Institute, Cornell Law School (Electronic Code of Federal Regulations), read 2026-10-23
3. [KalshiEX LLC, CFTC Regulation 40.6 Notification Regarding the Amendment of Various Kalshi Contracts (Position Limit replaced by Position Accountability Level)](https://www.cftc.gov/filings/orgrules/rules1114248729.pdf) — KalshiEX LLC, 2024-11-14
4. [KalshiEX LLC Rulebook, version 1.29 (Chapter 1 definitions, Chapter 4, Rules 5.18 and 5.19)](https://kalshi-public-docs.s3.amazonaws.com/regulatory/rulebook/Kalshi%20DCM%20Rulebook%20v.1.29.pdf) — KalshiEX LLC, read 2026-10-23
5. [CONTROL contract terms and conditions](https://kalshi-public-docs.s3.amazonaws.com/contract_terms/CONTROL.pdf) — KalshiEX LLC, read 2026-10-23
6. [FOOTBALLSTATS contract terms](https://kalshi-public-docs.s3.amazonaws.com/contract_terms/FOOTBALLSTATS.pdf) — KalshiEX LLC, read 2026-10-23
7. [QCX LLC, Product Self-Certification for Combinatorial Athletic Outcome Contract (CAOC), Attachment A](https://www.cftc.gov/filings/ptc/ptc0520263802.pdf) — QCX LLC d/b/a Polymarket US, 2026-05-20
8. [Polymarket US Rulebook (Rules 4.3 and 5.9, definition of Position Accountability Level)](https://www.polymarketexchange.com/files/legal/Polymarket%20US%20Rulebook%20%282026.09.30%29.pdf) — QCX LLC d/b/a Polymarket US, 2026-09-30
9. [Trading Limits](https://docs.polymarket.us/learn/trading/access-and-limits/trading-limits) — Polymarket US, read 2026-10-23
10. [Fees & Limits (help centre article)](https://help.og.com/en/articles/12958828-fees-limits) — OG.com, 2026-09-15
11. [CFTC Letter No. 25-20 (No-Action), to Victoria University of Wellington](https://www.cftc.gov/csl/25-20/download) — Commodity Futures Trading Commission, Division of Market Oversight, 2025-07-14

*Last updated 2026-10-23. A reference page, corrected in place — not a dated post.*