Apple’s new prediction markets ban covers any bet that uses confidential information about Apple or its suppliers, as per the company’s fiscal 2026 Form 10-K. It applies to contractors and consultants as well as employees, and Apple can fire violators and require them to repay equity awards.
Apple added the rule to the insider trading policy it filed as Exhibit 19.1 with the 10-K, and 9to5Mac first reported the change. Apple’s 2024 rules covered only securities trades, so the rule now extends them to event contracts.
The Apple prediction markets ban applies even when no law is broken
The rule bars wagers, trades and event contracts on prediction markets and similar platforms whenever the activity uses Apple Confidential Information, as defined in Apple’s Business Conduct Policy. That covers information about Apple and about other companies, including suppliers, manufacturers, vendors and customers such as cellular network carriers, when an employee learned it through work.
The ban holds whether or not the activity counts as insider trading or securities trading under applicable laws, so it does not depend on how regulators classify event contracts. Employees also cannot pass Apple Confidential Information to others who may use those markets.
Apple Confidential Information includes material nonpublic information but is not limited to it. That makes the rule wider than the securities rules, which turn on whether the information would move a stock.
Contractors, consultants and family members fall under the policy
Apple’s insider trading rules apply to all Apple personnel, including directors, officers, employees, independent contractors and consultants. It also reaches family members who live with an employee or depend on them financially, and entities the person controls or influences, such as family trusts.
Violators can face disciplinary action that includes termination and repayment of equity awards. Illegal insider trading or tipping carries separate criminal and civil penalties. The prohibitions continue after someone leaves Apple if they still hold material nonpublic information, until it becomes public or stops being material.
Apple treats information as nonpublic for 24 hours after it is announced
Information stays nonpublic for at least 24 hours after a press release, SEC filing or similar announcement, and accurate rumors that reach the media do not count as public disclosure. The same 24 hours applies to stock trading windows.
The restricted period for Apple’s fourth fiscal quarter began September 1 and ends 24 hours after Apple’s fourth quarter results became public on November 2. The prediction markets ban applies at any time confidential information is involved, and the next regular restricted period for stock trades starts December 1.
