DICE ETF Launches on Cboe Giving Retail Investors Pre-IPO Access to Kalshi and Polymarket

Tema ETFs launched the Tema Trading & Prediction Markets ETF (DICE) on Cboe on September 9, 2026 — the first ETF to give retail investors direct economic exposure to Kalshi and Polymarket before either company IPOs. Kalshi and Polymarket each account for approximately 7.3% of DICE's total assets (15% combined), accessed through a special purpose vehicle that holds stakes in the private companies. The remaining 85% is publicly traded companies including Robinhood Markets (HOOD) and Coinbase Global (COIN). Expense ratio: 0.75%. Tema President Steve Munroe cites Bernstein's $1 trillion annual volume projection by 2030 as the fund thesis.

For UK readers, the SPV structure is the key mechanism. An ETF normally holds publicly listed securities whose prices update continuously in a market. A special purpose vehicle allows the ETF to reference a private-company equity stake — Kalshi and Polymarket are both private — by packaging the stake in a separate legal entity that the ETF can hold as a portfolio asset. The SPV's value is typically marked to a reference price from the most recent secondary transaction or third-party valuation rather than a live market price, which means the ETF's exposure to Kalshi and Polymarket does not update in real time the way its Robinhood and Coinbase holdings do. The structure is commonly used for pre-IPO exposure ETFs in the UK alternative investment market as well. Its limitation is that private valuations can lag market sentiment materially in either direction.

The Robinhood and Coinbase holdings are the publicly traded legs of the fund's prediction market thesis. Robinhood Derivatives is one of the five largest prediction market platforms in the US; its contribution to Robinhood's total revenue and user engagement has grown substantially in 2026 as sports contract volume surged. Coinbase operates Coinbase Predictions and is named as a co-defendant in the Baltimore City lawsuit against Kalshi, reflecting its role as a distribution partner for Kalshi's sports contracts. Holding HOOD and COIN gives DICE liquid exposure to the prediction market sector's growth while the Kalshi and Polymarket SPV positions provide higher-beta private-company upside if either platform IPOs at a premium to current private valuations.

The timing of the DICE launch — September 9, 2026 — is significant. It follows the Ninth Circuit's August 28 ruling against Kalshi (adverse to the platforms), the Robinhood Michigan stipulation (signals regulatory risk), and two SCOTUS cert petitions accumulating. A fund manager that believes the legal risk is terminal would not launch a 15%-private-prediction-market ETF during this window. Tema's launch implicitly argues that the legal uncertainty is temporary, that SCOTUS will eventually resolve the circuit split in a way that preserves platforms' national operating ability, and that the $14.1 billion in weekly volume the sector was generating in NFL kickoff week is the correct baseline for projecting forward — not the disrupted scenario where state enforcement succeeds in fragmenting the market. Whether that assessment proves correct will determine DICE's performance more than any individual market movement in the fund's publicly traded holdings.

Operators mentioned in this article

CFTC-regulated

Kalshi

First fully CFTC-regulated US event-contract exchange.

Crypto / On-chain

Polymarket

USDC-settled on Polygon. Largest prediction market by volume.

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