Apple has added a direct prohibition on using confidential information for prediction-market trading to its insider-trading policy. The updated policy, marked “Updated October 2026,” was filed as an exhibit to Apple’s annual Form 10-K with the U.S. Securities and Exchange Commission.
The addition is narrow in one important sense but broad in who it can affect. It does not prohibit every Apple-connected person from participating in every prediction market. Instead, it prohibits participation when confidential information obtained through work is involved. That restriction also reaches confidential information concerning companies connected to Apple, including suppliers, manufacturers, vendors, customers and carrier partners.
In practical terms, the policy recognizes that a wager on an upcoming event can create the same fundamental compliance problem as a conventional trade when the bettor has nonpublic information that could influence the outcome. The venue may be different, but the advantage created by confidential knowledge is the issue Apple is addressing.
What Apple changed
The new section is titled “No Trading in Prediction Markets Based on Confidential Information.” It tells covered individuals not to participate in prediction markets or similar services to wager, bet, trade, buy or sell contracts tied to future outcomes when confidential Apple-related information is used.
An earlier version of the policy filed in 2024 did not contain language referring to prediction markets. The October 2026 revision makes the company’s position express rather than leaving this type of activity unmentioned in the policy document.
That specificity matters because prediction markets can look unlike familiar stock-market transactions. Their contracts are generally tied to whether a stated event happens. A participant can buy or sell a position whose eventual payout depends on that outcome. The event might concern a company, a product, an industry relationship or another future development. Apple’s updated policy is aimed at the use of confidential information in those event-based transactions.
Prediction markets, explained without the finance fog
A prediction market is a platform where people trade contracts connected to future events. If the specified event occurs, the contract pays out under its terms; if it does not, it resolves differently. Participants therefore put money behind their expectations about what will happen.
The key distinction is that the object of the trade is not necessarily a share in a company. It is a contract related to an outcome. But that difference does not erase the integrity concern where someone knows something that the market does not.
Consider the basic scenario implied by Apple’s policy. A person learns confidentially that an event involving Apple or one of its business partners is likely to occur. If that person then uses the knowledge to take a position on a contract built around that event, the potential edge comes from workplace information, not ordinary public research or personal judgment. The updated clause says that is off limits.
The policy also covers more than directly clicking the buy or sell button. Apple says confidential information cannot be shared with another person who may then use it on these markets. That addresses the indirect route: passing a tip to somebody else rather than placing a trade personally.
The restriction is not a blanket ban
Apple’s wording does not say that every director, employee, contractor or consultant is forbidden from all prediction-market participation. Its limitation is tied to the use of confidential information acquired through Apple work.
That is an important boundary. A general ban would turn on the platform itself. Apple’s stated restriction turns on whether confidential information is being used or communicated. The policy therefore focuses on the information advantage and the connection between that advantage and a trade, wager or contract transaction.
For covered people, the practical question is not merely, “Is this a stock trade?” It is also, “Does this position concern an outcome about which I possess nonpublic information through my work?” The policy’s language makes clear that a prediction market or a similar platform does not create an exception to the company’s confidentiality expectations.
It extends beyond Apple’s own business
One of the most consequential details is the policy’s reach beyond information solely about Apple. The restriction includes confidential information involving Apple’s suppliers, manufacturers, vendors, customers and carrier partners.
That makes sense in the context of a large technology company’s operations. Information encountered through work can concern many parties: companies that make components, organizations that provide services, businesses that sell products, customers, or network carriers. Even if a future-event contract names a partner rather than Apple itself, the policy can still apply when the information was obtained in the course of Apple-related work and remains confidential.
This is also why the change is relevant to the broader technology business landscape rather than being just a footnote for people who trade Apple shares. Prediction markets can be framed around a wide range of future events. The policy identifies the use of workplace knowledge—not the corporate name at the center of a given contract—as the essential problem.
Who is covered
Apple’s insider-trading policy applies to directors, officers, employees, independent contractors and consultants. It also applies to family members who live with a covered person or are financially dependent on them.
That household and dependent-family provision is particularly notable for ordinary compliance purposes. Confidential information may be mishandled through casual conversations, shared devices or an attempt to have someone else act on a tip. Apple’s policy makes clear that responsibility is not neatly limited to an individual’s own trading account.
The update also underscores that confidentiality obligations are not only relevant to executives or people working directly on high-profile plans. The covered groups listed in the policy include employees and external workers such as independent contractors and consultants. Where a person has access to confidential information through their role, the policy can be relevant regardless of whether the person thinks of themselves as part of the company’s investing or finance world.
Why explicit language matters
Policies often have to keep pace with the places where financial speculation can happen. The core concern behind insider-trading rules is not changed simply because a contract is framed around a yes-or-no event instead of a company share price. Still, plainly naming prediction markets removes uncertainty about how Apple expects covered people to treat them.
For compliance teams, precision can be useful because it gives workers a recognizable example of prohibited conduct. A person might understand a warning about buying or selling securities, yet not immediately connect that warning to a contract that pays out based on a future event. Apple’s new language closes that apparent gap by naming wagering, betting, trading, buying and selling contracts on prediction markets or similar platforms.
It also keeps the policy focused on conduct rather than labels. Calling a transaction a wager does not make confidential information acceptable to use. Calling it a prediction does not transform a workplace tip into public knowledge. Apple’s update treats the transaction’s outcome-based structure as another setting in which confidential information must not be exploited.
Practical implications for covered people
The policy provides a useful rule of thumb: if confidential work information could give a person an edge on an event-based contract, that person should not use the information to participate. Nor should they pass the information to someone who could do so.
- Do not focus only on Apple-branded events. Confidential information about a supplier, manufacturer, vendor, customer or carrier partner can also fall within the restriction.
- Do not treat a different transaction format as a loophole. The policy expressly references wagers, bets, trades and buying or selling contracts.
- Do not outsource the action. Sharing confidential information with somebody else who could use it on a prediction market is also prohibited by the policy.
- Remember the scope of coverage. Directors, officers, employees, contractors, consultants and specified household or financially dependent family members are included.
None of this changes the basic character of prediction markets: they remain platforms where participants take positions on possible future outcomes. What Apple has changed is the clarity of its internal rule for people with access to nonpublic business information.
The filing arrives amid continued interest in the many ways future events can be turned into tradable propositions. For companies handling sensitive product, supply-chain, customer and partner information, that creates an obvious compliance consideration. The more forms a market can take, the more explicit a policy may need to be about what confidential information cannot be used for.
Apple’s revised language is therefore less about predicting any one future event than setting a firm boundary around the use of privileged knowledge. Whether the transaction looks like a traditional investment, a wager or an event contract, the company’s stated standard is the same when the information came from confidential work: do not use it, and do not pass it along for someone else to use.
For more Apple business and platform coverage, see our report on the possibility of future changes to high-end MacBook Pro designs.
