Apple updates insider trading policy to ban prediction market trading

Apple has closed a loophole most corporate compliance manuals never imagined. The company now explicitly prohibits employees from using confidential work information to trade on prediction markets.

The change appears in Apple’s fiscal 2026 Form 10-K, filed with the SEC on November 3, 2026, after the company’s fourth-quarter earnings release. It reflects a world where you can bet on almost anything, including what Apple executives say on a conference call.

What the new rule actually says

The revised insider trading policy adds a specific ban on using “Apple Confidential Information” to participate in prediction markets or event contracts. Put simply, if you learned it at work, you can’t wager on it.

The scope is wide. The policy covers approximately 167,000 employees and independent contractors who work with Apple.

It also follows people out the door. Former employees remain bound by the restriction until the information in question becomes public.

The ban isn’t limited to Apple’s own secrets either. It extends to nonpublic information about the company’s partners, such as suppliers and customers.

Participation isn’t the only thing off the table. The policy also bars staff from passing nonpublic information along to others who might trade on it.

The penalties carry real weight. Violators could face termination and may be required to repay equity awards, which for many Apple employees represent a large chunk of compensation.

Why Apple felt the need to spell it out

The most telling detail is a single clause. Apple says the policy applies regardless of whether the activity qualifies as insider trading or securities trading under the law.

Apple’s previous policy already restricted trading in company securities while an employee held material nonpublic information. That covered the obvious case of buying shares ahead of a blowout quarter.

What it didn’t clearly address was a growing category of markets tied to Apple-specific events. Recent examples have included contracts on how many times the word “iPhone” gets said during an earnings call.

Others have centered on forecasts for product pricing. Some of these Apple-linked markets have drawn significant trading volume.

A word-count bet sounds trivial. But anyone who helped prepare an executive’s remarks would hold a meaningful edge, and that edge is exactly what the new rule targets.

What this means for prediction markets and other companies

The most immediate effect lands on the markets themselves. Contracts tied to corporate events depend on the assumption that nobody is trading with a stacked deck.

The partner clause is worth watching too. By covering suppliers and customers, Apple effectively asks its own workforce to protect information that belongs to other businesses.

For regulators, the move highlights a gap. Apple felt it needed to write a rule that works whether or not existing law treats these bets as securities trading, which suggests the legal framework has not kept pace with the products.

For employees, the message is simpler. If a bet hinges on something you heard in a meeting, Apple now considers it a firing offense, and the company has put that in writing for the SEC to see.