Apple's insider trading policy has a section on prediction markets. It tells employees not to use Apple confidential information to bet or trade on them. The text is in Exhibit 19.1 to Apple's fiscal 2026 Form 10-K, and the pages are marked "Updated October 2026."
What does the policy say?
The section is titled "No Trading in Prediction Markets Based on Confidential Information." It tells employees not to take part in "prediction markets" or similar platforms to wager, bet, trade, buy or sell contracts while using Apple Confidential Information.
That covers information about Apple, and also about other companies such as suppliers, vendors, customers and business partners, when an employee learned it through their work at Apple.
Employees also may not pass that information to others who might take part in those markets.
Does it only apply if the activity counts as securities trading?
No. The policy says the ban applies whether or not the activity would count as insider trading under the law. The rule does not depend on whether the activity is legally securities trading.
What the policy does not say
- It does not name any prediction-market platform.
- It does not mention any incident or any employee.
- It does not give a reason for the section.
- It sets no penalty for this section alone. A separate clause in the same policy says violators may face disciplinary action, up to termination and repayment of equity awards.
We read the exhibit itself and rely on it for everything here.
What this means for you
The section covers a kind of market that is not always securities trading. For Apple staff, the rule is the same whether the confidential detail concerns Apple or one of its partners.
For readers, it is an internal policy, public through a filing. It is not a rule about customers, products or prices. This is separate from Apple's legal fight with OpenAI over trade secrets, which is about alleged taking of confidential files, and from Apple's September-quarter results.
What we do not know
- Reason: Apple has not said, in this document, why the section is there.
- Timing: the exhibit is marked October 2026. It does not say whether the section is new or what changed from the prior version.
- Enforcement: the policy does not say how Apple would detect a breach.
We will update this page if Apple or the filing gives more detail.
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