Nasdaq has filed with the U.S. Securities and Exchange Commission to introduce cash-settled, fixed-payout contracts tied to its flagship Nasdaq-100 index, which marks a formal entry into the fast-expanding prediction-style derivatives market under securities oversight.
The proposal, submitted by its options exchange subsidiary Nasdaq MRX on March 2, outlines a new rulebook section titled Options 3B – Outcome-Related Options. The filing states:
“The exchange’s proposal adopts rules at new Options 3B to govern the listing and trading of cash-settled, European-style binary options referred to as Outcome-Related Options or ‘OROs.’”
Under the plan, the exchange would list “Nasdaq-100® OROs” on the Nasdaq-100 Index and similar contracts on the Nasdaq-100 Micro Index. Each contract would carry a $100 multiplier and a fixed $100 settlement amount. Premiums would range from $0.01 to $1.00, with minimum price increments of $0.01. Contracts would settle based on the Nasdaq Closing Cross pursuant to Nasdaq Equity 4, Rule 4757.
Unlike traditional index options, which deliver returns that vary with the size of a price move, the proposed contracts would pay a fixed amount if the settlement value closes at, above, or below a specified strike. A binary option, often called an all-or-nothing contract, offers a payout based solely on the outcome of a yes-or-no condition.
Reuters reported that the New York-based exchange operator is seeking to list binary options on both the Nasdaq 100 and its micro version. The so-called Outcome-Related Options would be priced between 1 cent and $1 and let traders bet on binary outcomes of a specific event.
The Nasdaq-100 tracks 100 of the largest non-financial companies listed on Nasdaq’s exchange, including Apple, Nvidia and Intel. The micro index represents one-hundredth of the full index value.
Regulatory lines drawn between SEC and CFTC
The filing places the proposed products under SEC supervision rather than the Commodity Futures Trading Commission. The document characterizes binary options as securities under 15 U.S.C. § 78c(a)(10) and contains no discussion of CFTC supervision.
This distinction separates Nasdaq’s approach from platforms such as Kalshi and Polymarket, whose event contracts fall under CFTC oversight. Nasdaq’s contracts would remain within the securities framework that governs listed equity and index options.
Nasdaq MRX proposed a position limit of 25,000 contracts on the same side of the market, separate from other broad-based index options. The exchange stated that these contracts would not qualify for standard position limit exemptions. It also noted that its existing surveillance programs, participation in the Intermarket Surveillance Group, and regulatory services agreement with FINRA would extend to trading in the new products. The exchange represented that both it and the Options Price Reporting Authority have adequate systems capacity to support the additional series.
Wall Street intensifies push into prediction-style markets
The filing arrives as prediction markets draw sustained volume growth. Trading across such platforms reached $63.5 billion in 2025, according to a report by blockchain security firm CertiK, a fourfold increase from the prior year. The surge followed heightened retail interest during the 2024 U.S. presidential race.
Several major exchange operators have signaled interest in the segment. Intercontinental Exchange committed $2 billion to Polymarket last October. Goldman Sachs has assessed potential opportunities in the space, according to CNBC news.
Cboe Global Markets has targeted a second-quarter launch for its own all-or-none style contracts focused on financial and economic events, subject to regulatory approval. CME Group, which operates under CFTC supervision, has partnered with FanDuel to power a consumer-facing prediction market app.
Sports betting operator DraftKings has also expanded its contract-trading arm across 38 states and set a volume record during the Super Bowl, with a target of $10 billion in annual revenue and plans for a market-making launch this year.
Nasdaq executives indicated last week that the firm would focus first on the Nasdaq-100 as it enters the space. The company also intends to explore offering Outcome-Related Options on other affiliated exchanges, including Nasdaq NOM and Nasdaq PHLX.
Nasdaq MRX operates on a first-come, first-served allocation model and does not pay trading incentives. By contrast, Nasdaq NOM and Nasdaq PHLX use pricing structures that can reward participants who add liquidity.
The SEC must approve the rule change before the contracts can launch. If authorized, Nasdaq’s entry would expand binary-style derivatives within U.S. equity options markets under securities regulation, rather than commodities law. The move places one of the world’s largest exchange operators directly into a segment that has until now seen the most rapid growth on crypto-native and CFTC-regulated venues.
Matvii Diadkov
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