On 13 July and 30 September 2026, respectively, the Ministry of Finance of the Czech Republic (“Ministry”) listed Polymarket and Kalshi on the List of Unauthorised Internet Games under Act No. 186/2016 Coll., on Gambling, as amended (“Gambling Act”). The listings provide a broader warning: depending on their product design, prediction markets available to Czech users may fall within Czech gambling regulation.
Prediction markets allow users to buy and sell contracts tied to the outcome of future events. Polymarket and Kalshi are prominent examples, but the Czech legal analysis is not limited to those platforms: it turns on the features of each product and any applicable statutory exclusion.
When can a prediction market qualify as gambling?
Section 3(1) of the Gambling Act defines “game of chance” as a game, bet or lottery in which the bettor places a wager the return of which is not guaranteed, and in which winning or losing is decided wholly or partly by chance or an unknown circumstance.
Section 33(1) of the Gambling Act also includes “events of public attention” among betting events. These may include, inter alia, elections, economic indicators, geopolitical developments and weather.
Section 2(2)(a) of the Gambling Act provides that an internet game of chance available in the Czech Republic is deemed to be operated in the Czech Republic.
Section 2(3) of the Gambling Act excludes specified financial, commodity and insurance contracts from its scope.
Although the Ministry has not published detailed reasoning for the listings of Polymarket and Kalshi, they illustrate how the statutory test may apply to prediction markets:
- Wager without guarantee of return: a user purchasing a prediction contract commits funds that may be lost in their entirety.
- Possibility of winning: a favourable outcome entitles the user to a payout under the contract terms.
- Chance or unknown circumstance: the outcome of the underlying event is not known at the time the wager is placed.
Kalshi illustrates why a product-by-product assessment is necessary. It is licensed in the United States by the Commodity Futures Trading Commission as a designated contract market, yet the Ministry still listed its domain. Foreign financial market regulation therefore does not, by itself, determine the Czech qualification; the substance of the product remains decisive.
What happens if a platform is listed?
A listing is limited to the identified domain and does not automatically extend to other services. For the currently listed polymarket.com and kalshi.com domains, the immediate consequences are:
- Internet service providers are required to block access to each listed website no later than 15 days after its listing.
- Non-compliance by an internet service provider constitutes an administrative offence carrying a fine of up to CZK 1,000,000.
The blocking obligation applies to access provided by internet service providers in the Czech Republic only.
What this means for operators and users
For operators
Operators should assess each prediction market product before making it available to Czech users. The assessment should address three questions:
- Does the product satisfy the statutory definition of a game of chance (Section 3(1) of the Gambling Act)?
- Does the product fall within a type of game regulated by the Gambling Act (Section 3(2) of the Gambling Act)?
- Does a statutory exclusion for specified financial, commodity and insurance contracts apply (Section 2(3) of the Gambling Act)?
The outcome of this assessment determines whether, and subject to what regulatory requirements, the product may be lawfully operated in the Czech Republic; foreign authorisation alone does not determine its qualification under Czech law.
For users
Users accessing Polymarket or Kalshi from the Czech Republic may encounter network-level blocking by their internet service providers. The Gambling Act does not establish an offence based solely on an individual’s use of an unauthorised platform.
Next steps
The Polymarket and Kalshi listings do not determine the qualification of every prediction market, but they signal closer scrutiny of prediction market products made available in the Czech Republic. Existing and prospective operators of prediction markets should assess their products under the Gambling Act before making them available to Czech users.
If you are interested in the topic of prediction markets regulation in the Czech Republic and want to learn more, please contact your CMS client partner or our expert Jan Ježek.
