Proposal Under SEC Review Could Let Investors Bet on Subscriber Counts and Revenue Targets

cboe sec Jul 16, 2026

A proposed financial product could turn individual company results into market bets. The filing does not describe a process for asking the companies to approve the contracts or opt in.

Cboe Exchange, which operates one of the largest options markets in the United States, wants to create tradable contracts tied to specific results reported by public companies.

Investors could trade on whether a company reaches a set subscriber count, revenue level, average revenue per user, or profit target during a reporting period.

The company wouldn’t create the contract. The filing also doesn’t describe a process for asking the business to participate or approve the use of its reported results.

Based on the proposed rules, Cboe appears able to select an eligible company measure listed in the proposal and build contracts around it without the company requesting the product or agreeing to take part.

For public subscription businesses, that could place even more attention on one quarterly number.

How the proposed contracts would work

Cboe calls the proposed products “binary KPI options.”

KPI stands for key performance indicator. In this case, it means a financial or operating result included in a company’s earnings-related filing with the Securities and Exchange Commission.

“Binary” means there are two possible outcomes.

For example, a contract could ask whether Robinhood will report at least a specified number of Gold subscribers for the quarter.

If the reported result reaches the target, the contract would settle at $1. If it misses, the contract would settle at zero.

Investors would be trading directly on that one result instead of trying to predict how the company’s stock will respond to its full earnings report.

A company could hit the subscriber threshold in the contract while disappointing investors on profit. The contract could still pay even if the company’s stock falls.

Which companies and measures are included?

The proposal covers a defined list of large public companies. It does not currently apply to every public subscription or recurring-revenue business.

Subscription-related measures include:

Robinhood Gold subscribers and average revenue per user
Coinbase Subscription and Services Revenue
Apple Services net sales
Disney streaming operating income
Netflix revenue and operating margin

The proposal also includes results reported by Amazon, Alphabet, Meta, Microsoft, Tesla, SoFi, and other public companies.

Subscriber totals are only one type of measure. Contracts could also be tied to revenue, margins, customer counts, production figures, or sales from a specific part of the business.

If the structure is approved and attracts investors, Cboe or another exchange could later seek SEC approval to add more companies and reported measures.

Public recurring-revenue companies outside the first group should still pay attention.

The filing does not describe a company approval process

Cboe would use information a company already includes in an earnings-related SEC filing, such as a Form 8-K, 10-Q, or 10-K.

The proposal does not describe a requirement to contact the company, ask it to participate, or allow it to reject a contract tied to one of the measures listed in the proposal.

A company could find that investors are trading on one of its reported results even though it didn’t request the product or help select the target.

The company would still control what it reports, subject to securities laws and disclosure requirements. It would not control the financial product created around that information.

Cboe would use the result reported in the SEC filing to settle the contract. A later correction or restatement would not change a completed payout.

That puts more weight on the accuracy and clarity of the original filing.

Finance, legal, investor relations, and disclosure teams would need to understand that one reported result could determine who wins or loses money in a separate market.

What happens next

Cboe Exchange filed the proposed rule change with the SEC on June 30, 2026. The SEC issued its notice on July 10 and opened the filing for public comment.

Comments are due August 5, 2026, under file number SR-CBOE-2026-061. Comments submitted to the SEC become public.

The SEC can approve or reject the proposal. It can also extend the review or begin a longer process to consider whether the rule change should be rejected.

Cboe lists the filing as pending. No contracts are trading under this proposal.

Companies named in the filing may want their securities counsel, finance leaders, investor relations teams, and boards to review it now. They can also decide whether to submit a public comment before the deadline.

Insider Take

Public subscription companies already face a hard conflict between quarterly market expectations and the long-term economics of recurring revenue.

They may need to spend more now, accept lower margins, or slow near-term growth to improve retention and future customer value. Those choices can make sense for the business even when they weaken one quarterly result.

A contract tied to one reported number would leave out most of that context.

Wall Street already puts enormous pressure on public companies to hit quarterly numbers. Turning subscriber counts and recurring revenue into tradable contracts could pour gasoline on that pressure.

The current proposal names a limited group of companies. If these contracts succeed, the idea could spread.

Public subscription companies already have to defend long-term investments against short-term market pressure. Giving investors a separate way to trade on one quarterly result could make that balance even harder to protect.