Apple has updated its insider trading policy to explicitly prohibit employees from using confidential information to bet on prediction markets. Here are the details.
No betting on confidential information
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 while aware of material nonpublic information
- No tipping
- No third-party trading or tipping
- No trading during restricted trading periods
- No short sales, hedging or trading in derivatives
However, the updated policy includes a new prohibition:
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.
While much of this may seem obvious, how insider trading rules apply to prediction markets has been something of a gray area, to put it mildly. And while major prediciton markets explicitly ban the practice in their terms of service, enforcement remains a challenge.
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.
You can read Apple’s full 2026 Form 10-K on its Investor Relations page.
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