183 Kalshi election markets had already traded when their resolution rules changed.

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Kalshi's emergency submission was received by the CFTC on October 28, 2025, with an October 31 effective date. The filing described an amendment to already-certified election contracts. It added a route to resolve them using declarations from designated news organizations, before certification or swearing-in. CFTC filing 58376.

For U.S. elections, the new route required agreement from at least four of eight designated sources, no contradictory declaration, and a 48-hour period without a retraction. This gave the affected contracts an additional route to resolution before the official milestones in their earlier terms.

The amendment was publicly filed at the time. MSR's contribution is to measure the affected markets and their exposure, and to connect the successive changes. We do not claim to have discovered the October amendment.

Of the 250 affected markets we identified as open when the October amendment took effect, 183 had already traded. The remaining 67 had no recorded pre-amendment trading in our reconstruction.

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Trading volume and open interest answer different questions. Volume counts contracts changing hands over time. Open interest measures positions still outstanding at a snapshot. The 83,191,414 traded contracts are not 83,191,414 outstanding contracts.

For October, open interest was measurable on 59 markets and positive on 58. Another 124 markets with earlier trading had no usable snapshot and were excluded, not counted as zero. The measured subtotal has a face value of about $44.3 million at $1 per contract. It is not a measure of trader losses, and it does not establish total open interest at the exact effective time.

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In the March amendment, Kalshi said experience from the 2025 election cycle supported removing the waiting period. The requirement for agreement among designated U.S. sources and the restriction on contradictory declarations remained. CFTC filing 59849.

The June amendment addressed individual strikes: separate outcomes or thresholds within a contract could resolve once the required declarations established their result. It covered the contracts named in that filing; it does not establish that every market in our October cohort received a third amendment. CFTC filing 60971.

Our reconstruction identified 126 markets open at both the October and March effective dates, with trading before each. At the September 5, 2026 checkpoint, 124 remained unsettled. These are market-level observations; they do not establish that the same traders held the same positions throughout.

The Virginia markets in our timing review settled on November 7, 2025, according to the retained exchange records. Virginia's State Board of Elections certified the election on December 1. Settlement therefore preceded certification by more than three weeks. Virginia State Board of Elections, 2025 annual report, page 8.

That chronology is consistent with an accelerated route to settlement. It does not identify the precise moment when the required media declarations were satisfied; we did not establish those timestamps.

Kalshi's November 3 submission explained that earlier resolution could release capital otherwise tied up for weeks or months. It also described member demand for faster resolution. That is a material part of the exchange's stated rationale. Kalshi's November 3 submission, pages 1–3.

For a person holding an affected position, the terms governing when settlement could occur changed after the market had begun trading. The practical question is whether the rule version applicable to a position can be identified and its subsequent changes traced.

No wrong winner or payout reversal was demonstrated. This report does not establish that the amendments caused a trader to lose money or that a different side would have won under the earlier terms.

Direct notice remains an open question. MSR located the public filings but has not independently established when or how holders of affected positions were notified. We do not infer that notice was absent or inadequate.

This is not a finding of illegality or unauthorized action. The reviewed terms include provisions allowing contract specifications to change after trading begins. We have not determined whether any amendment breached a legal or contractual obligation.

Reimbursement is unresolved. Kalshi's filing contemplated reimbursement for certain pre-filing positions held through resolution if the amendment changed what would otherwise have been a favorable result. Our research has not established whether that provision was triggered or payments were made.

This is a historical case study of specified amendments, not a claim about every Kalshi market or every rule change. Market counts reflect the affected markets identified by our review and may omit markets we could not reliably associate with the filing. Open-interest coverage is incomplete, and all unsettled counts refer to September 5, 2026 rather than today's market status.

The CFTC sources above let readers inspect the terms, dates, and exchange explanations. MSR's market-level research supports the exposure and overlap figures; those figures are not published CFTC estimates. Public records and reported results are distinguished throughout.

The unresolved questions are concrete: how holders were notified, whether any reimbursement occurred, and how a customer can retrieve the rule version applicable when a position was opened. This report does not represent a response from Kalshi or the CFTC to those questions.