The Sports Traders Union

Responsible Trading Code

Model Standards for Sports Event Contracts and Comparable Retail Financial Products

Last updated July 2026

Why This Code Exists

In only a few years, sports event contracts have grown from a regulatory novelty into a product traded by millions of Americans, most from their smartphones. As they have expanded, so have questions about how the people using them should be protected.

Most existing guidance asks users to manage their own risk. We ask a different question: what responsibilities do platforms have?

Financial markets have long developed rules governing fraud, manipulation, settlement, and fair dealing. Those protections remain essential. They were not designed to answer questions about product design, marketing, user controls, or how platforms should treat the people who use them.

Throughout this code, “gambling-like behavior” refers to a pattern of participation driven by the hope of a quick gain rather than a reasoned view of price. The phrase describes behavior rather than legal classification, leaving questions about the legal status of sports event contracts to courts and regulators.

The Responsible Trading Code covers education, marketing, product design, user controls, incentives, monitoring, accountability, and age restrictions. It sets expectations for what people should know before they trade, what protections should be available while they trade, and how platforms should respond when behavior points to harm. The Code focuses on sports event contracts because that is where market growth and regulatory attention are concentrated today. Many of the same principles apply to sportsbooks, brokerages that distribute event contracts, and other platforms offering comparable products.

An exchange that adopts this code (an “Adopting Exchange”) commits to the standards below. Regulators can use the same standards as a benchmark for reviewing exchange rules, product design, marketing, incentives, monitoring, and participant-protection practices.

Age and Access

An Adopting Exchange restricts trading in sports event contracts to participants 21 years of age or older, even where federal law permits access at 18. Standards include:

Age verified at account opening, before any deposit or trade
No marketing, advertising, or promotions directed at persons under 21
Accounts identified as belonging to persons under 21 are closed and funds returned
Age verification renewed when account ownership or payment methods materially change
No promotional offer may be delivered before age verification is complete

Nearly every state that licenses online sports betting sets its minimum age at 21. A participant should not receive less protection on a federally regulated exchange than state law would give them at a sportsbook.

Marketing

An Adopting Exchange markets sports event contracts accurately and does not use advertising to obscure risk, misrepresent likely outcomes, or encourage impulsive participation. Standards include:

No “free money,” “risk-free,” “easy money,” or similar claims that misstate the possibility of loss
No appeals suggesting that trading offers a solution to debt, financial hardship, or economic insecurity
No marketing directed at persons under 21, placed in media primarily consumed by minors, or designed to appeal primarily to minors
No person who reasonably appears to be under the age of 21 may be depicted as a trader or customer in advertising or promotional materials
No advertising or promotional outreach triggered by recent losses, repeated deposits, or other indicators of elevated risk
Influencers and affiliates may not portray profits as easy, typical, or guaranteed
No marketing to participants who are self-excluded, cooling off, or subject to a responsible-trading intervention
Paid partnerships, affiliate relationships, compensation arrangements, and material conflicts of interest must be clearly disclosed
Claims about prices, fees, liquidity, execution quality, or participant profitability must be accurate and capable of substantiation

Marketing accurately describes the product rather than exploiting participants’ hopes about what it might deliver. Honest marketing supports informed participation and public trust.

Education

An Adopting Exchange explains how its markets work, what they cost, and what tools participants can use to manage risk before the participant begins trading. Education is presented during onboarding and remains easy to find afterward. Education is not satisfied solely by requiring participants to acknowledge a terms-of-service agreement or similar disclosure. It covers:

Trading carries a meaningful risk of loss, including the possible loss of the participant’s full position
Participants trade against one another in zero-sum markets, and fees make aggregate participant returns negative
Trading is not a reliable source of income, and consistent profitability generally requires information, skill, disciplined risk management, and prices that are favorable after fees
Prices, implied probability, liquidity, spreads, money at risk, maximum loss, and potential payout are explained in plain language
All fees and charges are explained before a participant incurs them
Participants are shown the exchange’s available deposit, loss, exposure, time, cooling-off, and self-exclusion tools during onboarding
Participants are told where to find those tools later and what happens after each tool is activated
The differences between event contracts, sportsbook wagers, and comparable products are described factually without asserting a legal classification

A participant cannot make an informed decision without understanding both the economics of the market and the protections available to them.

Product Interface

An Adopting Exchange designs its interface so participants can understand the price, cost, exposure, and status of a trade before acting. The interface does not use casino-style mechanics or artificial pressure to increase participation. Standards include:

Clear display of money at risk, potential payout, and maximum loss before an order is submitted
Clear display of all transaction-specific fees before confirmation
Clear realized and unrealized profit-and-loss information together with cumulative net profit or loss since account opening
Clear display of open positions, pending orders, total exposure, and available funds
Clear settlement rules accessible directly from the trading screen
Order confirmations clearly distinguish submitted, open, partially filled, filled, canceled, rejected, and settled orders
The interface does not hide or minimize information about fees or losses
No confetti, coins, flashing lights, or other casino-style celebrations tied to trades, fills, or wins
No near-miss animations, graphics, or messages implying that a losing position was almost a win
No countdowns, prompts, or scarcity messages that create urgency beyond a genuine market or event deadline
No pre-filled order sizes, default selections, or other interface designs that encourage larger or more frequent trades
No streak counters, “hot trader” messages, immediate re-entry prompts, or similar features designed to increase trading frequency
Added friction when participants deposit repeatedly, increase exposure rapidly, trade immediately after significant losses, or exhibit other indicators of elevated risk

Interface design determines what information participants notice and how quickly they act. A fair interface makes prices, costs, rules, and account status easy to understand, while avoiding design features that encourage impulsive or repetitive trading.

User Controls

An Adopting Exchange gives participants practical tools to control how much money and time they commit. These tools are presented during onboarding, remain accessible from the main account interface, and do not require a participant to contact customer support. They include:

Deposit, loss, and exposure limits available across daily, weekly, and monthly periods
Time reminders
Cooling-off periods
Self-exclusion
Immediate effect when a limit is lowered and at least 24 hours before a limit increase becomes effective
No marketing during cooling-off or self-exclusion
Clear confirmation of the duration, scope, and consequences of each control before activation
No opportunity to cancel a cooling-off period or self-exclusion before the selected period expires
Participants can download their transaction history, deposits, withdrawals, fees, positions, and profit-and-loss record in a usable format
Closing an account or activating a protection does not prevent a participant from withdrawing available funds or obtaining account records

An Adopting Exchange enables participants to manage both their risk and their own account information without unnecessary obstacles. Controls are useful only when people know about them, can activate them easily, and can trust that the platform will honor them.

Incentives

An Adopting Exchange ensures that promotions, loyalty programs, and “VIP” arrangements have clear terms and do not exploit losses or pressure participants to increase their activity. Standards include:

Opt-in, not opt-out
Clear, simple terms
Clear disclosure of the value of the incentive and any trading, volume, holding-period, or withdrawal requirement
Not triggered by recent losses, repeated deposits, canceled withdrawals, or unsuccessful attempts to recover losses
Not offered to participants subject to an intervention or showing indicators of elevated risk
No misleading free-money or risk-free language
“VIP” or similar programs may not reward losses, escalating deposits, or increases in activity that follow elevated-risk alerts
Gifts, credits, hospitality, personal outreach, and enhanced service may not be used to encourage a participant to recover losses or continue trading after expressing concern about their activity
No incentive may require trading volume disproportionate to the value of the incentive. Required trading multiples are disclosed before participation.
A participant may leave a loyalty, VIP, or hosted-trader program without losing access to ordinary account service or withdrawal rights
Compensation for employees, hosts, affiliates, and influencers is not primarily based on participant deposits, losses, or trading volume

Incentives offer genuine and understandable value rather than using personalized attention or complex conditions to encourage participants to trade more than they otherwise would.

Contract Design

An Adopting Exchange reviews contracts for clarity, integrity, participant value, and responsible-trading risk before listing and periodically thereafter. Features warranting additional review include:

Very short duration
High repeatability
Low informational value
Close resemblance to pure chance
Designs that invite rapid re-entry after losses
Designs that create casino-like feedback loops
Contracts that raise unusual integrity or consumer-protection concerns
Settlement terms that depend on vague, subjective, or difficult-to-verify criteria
Reliance on a settlement source that may be unavailable, delayed, conflicted, or capable of being changed after trading begins
A material risk that ordinary participants will misunderstand what outcome the contract measures
Fee structures that make the contract unusually costly for retail participants

A contract exhibiting several of these features is listed only after a documented review determines that it offers sufficient informational, hedging, or participant value and that its risks have been addressed through measures such as clearer disclosures, tighter position limits, added friction, exclusion from promotions, or restrictions on repeat trading. Settlement terms may not be materially changed after trading begins except to correct a clear error or address circumstances specified in advance. When a contract is voided, positions are unwound at cost and participant funds are returned promptly.

These reviews ensure that participants understand what they are trading and how the outcome will be determined, while reducing casino-like design, ambiguous terms, inconsistent voiding, and avoidable disputes.

Monitoring and Intervention

For purposes of this Code, “Defined Indicators of Elevated Risk” are objective, documented patterns of participant behavior identified in advance by an Adopting Exchange as warranting review or intervention. Adopting Exchanges periodically evaluate these indicators to ensure they accurately identify elevated risk. An “Intervention” is any action taken in response to Defined Indicators of Elevated Risk, including informational prompts, responsible-trading tools, promotional restrictions, direct outreach, account review, or temporary account restrictions.

An Adopting Exchange maintains automated and human-review systems to identify participants exhibiting Defined Indicators of Elevated Risk. Alerts lead to documented, proportionate responses rather than serving solely as internal analytics. Indicators include:

Rapid increases in deposits or position size
Repeated deposits immediately following losses
Repeated deposits within a short period
Canceled withdrawals followed by renewed trading
Repeated attempts to raise limits
Trading right after large losses
Unusual trading intensity
Apparent loss-chasing
Sustained trading over unusually long periods or at unusual hours
Abrupt changes in activity, funding, or risk relative to the participant’s prior behavior
Statements voluntarily made by participants to customer-support personnel indicating loss of control, financial distress, or an attempt to recover losses
Repeated activation and expiration of cooling-off periods
Multiple indicators occurring at the same time

An Adopting Exchange maintains a documented, tiered response framework for patterns that may indicate elevated risk. Lower-level alerts may trigger spending reminders, limit-setting prompts, or cooling-off options, while sustained or escalating patterns trigger human review and stronger measures, including suspension of promotional outreach, direct contact with the participant, temporary account restrictions, or other proportionate protections. Adopting Exchanges define their alert thresholds and escalation procedures in advance, document Interventions and outcomes, and periodically evaluate whether they identify risk accurately.

Adopting Exchanges maintain documented participant risk-scoring systems, or comparable methodologies, that use Defined Indicators of Elevated Risk to identify accounts for review. Participants aged 21 through 24 receive enhanced monitoring using age-appropriate thresholds, and participants subject to material account restrictions have access to a clear explanation and review process. The purpose of monitoring is to identify elevated risk early enough that timely intervention can still make a difference.

Transparency and Accountability

An Adopting Exchange collects and publishes enough information to evaluate participant outcomes, whether its responsible-trading program works, and whether it complies with this Code. Relevant metrics include:

Use of deposit, loss, exposure, and time limits
Frequency of cooling-off and self-exclusion
Deposit size and frequency following losses
Rapid increases in position size or trading intensity
Participant profit-and-loss patterns over time
Incentive use by participant segment
Activity by age cohort, where legally and operationally appropriate
Affiliate and paid-promoter activity
Fees paid by participants, including their distribution across participant groups and levels of activity
The number, type, and outcome of responsible-trading alerts and Interventions
Profit-and-loss outcomes of participants enrolled in “VIP” or similar programs compared with the broader participant population
Account limitations, suspensions, and closures, including the principal reasons for those actions

At least annually, an Adopting Exchange publishes a publicly accessible report describing its compliance with this Code, material shortcomings identified during the year, and corrective actions taken. More detailed information is provided to regulators and made available for periodic independent review to assess not only whether these policies exist, but whether they are implemented consistently and achieve their intended purpose. Responsible-trading claims and fair-treatment commitments must be capable of independent verification, allowing participants, regulators, and researchers to distinguish meaningful protections from policies that exist only on paper.

Review and Revision

The Responsible Trading Code is intended to evolve as markets, products, and evidence change. The Sports Traders Union reviews the Code at least every six months, invites public comment, and publishes any revisions together with a summary of what changed and why. The Union also publishes periodic assessments evaluating exchanges against the Code’s standards, identifying each exchange’s level of compliance with the Code, which provisions it has adopted, where additional progress is needed, and changes over time. Adopting Exchanges likewise review and update their responsible trading programs at least annually rather than treating compliance as a one-time exercise.