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Apple now explicitly bans employees from using confidential information in prediction markets

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Apple now explicitly bans employees from using confidential information in prediction markets

Apple has updated its insider trading policy to explicitly prohibit employees from using confidential information to bet on prediction markets. Here are the details.

Following yesterday’s fiscal Q4 2026 earnings report, Apple today published its fiscal 2026 Form 10-K, which is a mandatory annual filing with the SEC that provides a detailed look at the company’s finances, business, and risks.

Among the documents included in the filing is an updated version of Apple’s insider trading policy.

Until last year, Apple’s insider trading policy, filed with the SEC as Exhibit 19.1, included the following prohibitions:

No Trading in Prediction Markets Based on Confidential Information. Do not participate in “prediction markets” or similar platforms to wager, bet, trade, buy or sell contracts based on the outcome of future events, or otherwise enter into event contracts, when such activity involves the use of Apple Confidential Information (as defined in Apple’s Business Conduct Policy) about Apple or any other company (including Apple suppliers, manufacturers, vendors or customers, such as cellular network carriers or other business partners) obtained in connection with your work at Apple. You must also not tip Apple Confidential Information to others who may participate in such markets. Apple Confidential Information includes, but is not limited to, material nonpublic information. This prohibition applies whether or not the activity constitutes insider trading or securities trading under applicable laws.

In Apple’s case, the new language explicitly extends restrictions beyond traditional securities trading, making it clear that employees cannot use confidential information to place bets on prediction markets, even when those transactions don’t qualify as insider trading under applicable laws.


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