DICE ETF Launches on Cboe Giving Retail Investors Pre-IPO Access to Kalshi and Polymarket
Tema ETFs launched the Tema Trading & Prediction Markets ETF (ticker: DICE) on the Cboe exchange on September 9 — the first ETF to offer direct exposure to both Kalshi and Polymarket before either company goes public. Kalshi and Polymarket together account for 15% of DICE's portfolio, each at approximately 7.3%, accessed through a special purpose vehicle that holds stakes in the private companies. The fund also holds publicly traded Robinhood Markets and Coinbase. DICE carries a 0.75% expense ratio. Tema's president cites the Bernstein projection that prediction market volume could reach $1 trillion annually by 2030.
Tema ETFs launched the Tema Trading & Prediction Markets ETF (ticker: DICE) on the Cboe BZX Exchange on September 9, 2026 — becoming the first exchange-traded fund to offer retail investors direct exposure to both Kalshi and Polymarket while neither company is publicly traded. Kalshi and Polymarket together account for approximately 15% of DICE's total assets, with each platform allocated roughly 7.3% of the fund. Because neither company has completed an IPO, Tema accesses the private-company stakes through a special purpose vehicle (SPV) — a legal structure that holds the private equity and allows the ETF to reference it without requiring the underlying companies to be publicly listed. The remaining 85% of the fund consists of publicly traded companies in the trading and digital-asset ecosystem, including Robinhood Markets (HOOD) and Coinbase Global (COIN). The fund carries a gross expense ratio of 75 basis points (0.75%).
The SPV structure that gives DICE access to private Kalshi and Polymarket stakes is the same mechanism used by other ETFs that hold pre-IPO companies — the fund manager negotiates secondary-market access to private shares or restricted equity interests, packages them into a vehicle, and references the vehicle within the ETF portfolio. This allows retail investors to gain economic exposure to companies they could not otherwise access before an IPO. The structure is not without limitations: the SPV's value is not continuously mark-to-market against a liquid market for the underlying shares, which can create valuation lag and premium/discount dynamics in the ETF that are more pronounced than in funds holding publicly traded securities. For investors who believe Kalshi or Polymarket will IPO at significantly higher valuations than current private-market prices — Polymarket was last valued at approximately $1.5 billion privately; Kalshi has been valued at higher figures in secondary markets — DICE offers an accessible route to that upside without requiring access to private placement.
Tema President Steve Munroe cited the Bernstein Research projection that prediction market annual volume could reach $1 trillion by 2030 as the thesis underlying the fund — a figure the week's $14.1 billion in combined Kalshi-Polymarket weekly volume, if annualized, would approach within two to three years. The fund is positioned as a bet on prediction market infrastructure: both the private companies operating the markets (Kalshi, Polymarket) and the publicly traded companies whose businesses are partially or substantially tied to the sector's growth (Robinhood, which holds Robinhood Rothera, its prediction markets unit; Coinbase, which operates Coinbase Predictions and is named as a co-defendant in the Baltimore lawsuit). The ETF launch comes at a moment when the sector is generating record volumes — $14.1 billion in NFL kickoff week — while simultaneously facing its most consequential legal challenges: Ninth Circuit en banc petition, two SCOTUS cert petitions, a Massachusetts SJC decision pending, and ongoing state enforcement actions in multiple jurisdictions.
The DICE launch is a market structure signal as much as a product. ETF issuers typically build products when they expect sustained institutional and retail demand for an exposure, not when they expect it to decline. The decision to launch DICE in September 2026 — during the NFL season, as multiple SCOTUS petitions accumulate and a Bernstein $1T volume projection circulates — reflects a bet that the prediction market sector will survive its current legal challenges and continue growing toward the scale its platform operators are projecting. The 15% private-company allocation is DICE's highest-conviction position; the Robinhood and Coinbase holdings provide liquidity and publicly-priced anchoring for the rest of the portfolio. Whether the fund generates significant AUM will depend on how the legal landscape resolves: a favorable SCOTUS ruling for platforms would likely accelerate both platform growth and DICE's private-company holdings' valuation. An adverse ruling that restricts sports contracts across multiple states would create meaningful headwinds for the private-company positions even if the publicly traded holdings (Robinhood, Coinbase) survive through their diversified businesses.
Operators mentioned in this article
Recent updates
Missouri AG Sends Cease-and-Desist Letters to Six Prediction Market Operators
Missouri Attorney General Catherine Hanaway issued cease-and-desist letters on September 18 to six prediction market operators — Kalshi, Polymarket, Robinhood, Crypto.com, Novig, and Underdog — alleging their sports event contracts constitute unlicensed sports wagering under Missouri law. The letters give platforms 30 days to comply or obtain licenses from the Missouri Gaming Commission. Missouri is the broadest multi-platform C&D action to date, targeting all major operators simultaneously. The action arrives one day after Montana and Kalshi filed a joint stipulation in which Montana agreed to pause enforcement while Ninth Circuit en banc review is pending.
Yahoo Finance Ends Polymarket Data Partnership After Five Months
Yahoo Finance and Polymarket mutually ended their prediction market data partnership on September 18, approximately five months after the companies announced an exclusive arrangement in November 2025. The Polymarket data hub that Yahoo Finance launched in January-February 2026 was quietly taken down in April 2026. No reason was publicly disclosed. Yahoo Finance retains an advertising relationship with Polymarket. The partnership's end is a setback for Polymarket's strategy of embedding its probability data into mainstream financial media platforms.
Montana and Kalshi Reach Joint Stipulation — State Pauses Enforcement Pending Ninth Circuit En Banc
Kalshi dismissed its lawsuit against the Montana Department of Justice on September 17 after both sides filed a joint stipulation in which Montana agreed to pause all enforcement, investigations, and cease-and-desist proceedings against Kalshi's event contracts. The pause lasts until the Ninth Circuit either denies en banc review of the August 28 ruling or issues an en banc decision. Montana must give Kalshi 30 days written notice before resuming any enforcement action after that window closes. The agreement mirrors the Robinhood-Michigan stipulation from September 4 and reinforces a pattern of states reaching negotiated compliance pauses while the appellate process plays out.