Apple Updates Insider Trading Policy to Ban Confidential Information Use in Prediction Markets

Policy Update Details

Apple has revised its insider trading policy, as detailed in its fiscal 2026 Form 10-K filing with the SEC. The updated policy introduces a specific prohibition against employees using confidential information to engage in prediction markets or similar platforms. This includes wagering, betting, trading, buying, or selling contracts based on future events when Apple Confidential Information is involved.

Scope of the New Prohibition

The new rule clarifies that this ban applies to confidential information about Apple itself, as well as its suppliers, manufacturers, vendors, customers, and other business partners. It also states that employees must not tip confidential information to others who might participate in such markets. This prohibition is in effect whether or not the activity would be considered insider trading or securities trading under applicable laws.

Context and Implications

Previously, the application of insider trading rules to prediction markets was considered a gray area. While major prediction markets often ban such practices in their terms of service, enforcement can be challenging. Apple's explicit policy change extends its restrictions beyond traditional securities trading, providing clear guidelines for its employees regarding confidential information and prediction market participation.