CME Compute Futures

CME Compute Futures are a planned family of financially settled futures contracts tied to Silicon Data benchmarks for hourly rentals of Nvidia H100 and B200 graphics processors. New York Mercantile Exchange, Inc. (NYMEX), a CME Group exchange, announced two contracts: Silicon Data H100 Rental Index Futures and Silicon Data B200 Rental Index Futures. NYMEX filed both products with the US Commodity Futures Trading Commission (CFTC) on August 11, 2026 as a voluntary request for formal approval, and CME Group announced the same day that it planned to launch them on October 5, 2026, pending regulatory review.^[1][17][25] On September 21, 2026, the CFTC's Division of Market Oversight extended its review by 45 days, to the end of November 9, 2026, citing "novel or complex issues" and the Commission's pending request for comment on compute derivatives. A revised CME Clearing advisory dated September 25 lists the listing and trade date as "TBD".^{[15][16][22][26]}

The contracts are intended to turn changes in standardized GPU rental rates into a cash-settled financial exposure. They do not reserve, deliver, or guarantee access to physical computing capacity. As of September 28, 2026, they had not begun trading, so no trading volume, open interest, bid-ask spread, or adoption record existed for the products.^{[2][15][16][26]}

Announcement and status

CME Group and Silicon Data announced their partnership on May 12, 2026. The initial release said the companies planned to introduce compute futures later in the year, pending regulatory review, and that the products would use Silicon Data's daily benchmarks for on-demand GPU rental rates. The release described Silicon Data as backed by the trading firm DRW. It did not yet identify the individual contracts or their sizes.^[3]

NYMEX supplied those details in Special Executive Report 9785 on August 11, which gives October 5, 2026 as the effective date. The same-day regulatory filing states that, subject to Commission approval, the exchange intended to list the contracts effective Sunday, October 4, for trade date Monday, October 5, 2026.^[1][17] CME Group's press release that day announced plans to launch the two contracts on October 5, "pending regulatory review", and said each contract would represent a month's worth of rent for the respective GPU.^[25] In August, CME's dedicated product page gave the same October 5 date. As of September 28, 2026, that page instead said CME planned to launch compute futures "later this year", pending regulatory review.^[2]

The same-day CFTC filing, NYMEX Submission 26-370, is a voluntary request for product approval under Regulation 40.3, not a product self-certification under Regulation 40.2. NYMEX also filed a supplemental submission, 26-370S, with a request for confidential treatment of its supplemental information. The CFTC register listed the H100 and B200 products as "Approval Pending (45)" on August 17.^[15][16][17] Regulation 40.3 provides an initial 45-day review period. The Commission may extend that period by as much as 45 additional days for novel or complex issues, an incomplete submission, or an untimely response, and it may extend the period for any duration agreed to by the exchange. A product submitted under the rule is deemed approved at the end of the applicable review period unless the Commission issues a notice of non-approval within it.^[19]

Review extension (September 2026)

On September 21, 2026, the CFTC's Division of Market Oversight wrote to CME Group that it had extended the review period for Submissions 26-370 and 26-370S by an additional 45 days after the initial 45-day period, "until the end of November 9, 2026". The letter, signed by Acting Director DJ Hennes, based the decision on "the need for additional time to analyze the Products in light of novel or complex issues". It also noted that the Commission was examining, through a pending request for comment, the factors an exchange should consider when listing derivatives with compute as the underlier.^[22] The CFTC register entries for both products changed to "Approval Pending (90)" with a date of September 21, 2026.^[15][16]

Four days later, CME Clearing reissued its new-product advisory for the two contracts as a "Revised New Product Summary" with the effective date "to be announced". The revised advisory, dated September 25, 2026, lists the listing date, trade date, and initial contracts as "TBD" and keeps the note "Pending All Relevant CFTC Regulatory Review Periods".^[26] Finimize, citing The Information, reported on September 23 that the extension had delayed CME's planned launch.^[27] As of September 28, 2026, the CFTC register showed no approval and CME had not published a new launch date.^{[2][15][16][26]}

CFTC request for comment

On August 19, 2026, eight days after the NYMEX filing, the CFTC issued a request for comment "to better inform its understanding and oversight of derivatives markets in compute". Chairman Michael S. Selig said: "America cannot win the AI race without a robust derivatives market for compute." The press release said the request covers the size and liquidity of compute cash markets, market oversight and manipulation concerns, customer protection, and perpetual compute futures.^[23] The notice was published in the Federal Register on August 21, 2026 (91 FR 54259), with comments due by October 20, 2026. Its voting summary records that Chairman Selig voted in favor and no commissioner voted against.^[24]

The notice sets out the Commission's preliminary views. It says compute markets are fragmented, that price formation happens mainly in opaque bilateral transactions, and that pricing can vary widely across providers, regions, and contract structures. It adds that compute "may not yet exhibit certain of the characteristics of commodities that typically underlie a commodity derivatives market, including fungibility, standardization, and sufficient liquidity".^[24] Several of its questions bear directly on index-settled contracts such as the CME products:

• Whether it would be appropriate to trade a contract that settles to a price computed from data the Commission may not be able to observe, verify, or surveil.
• How to treat the possibility that the parties best placed to influence a reference price are the same parties that supply capacity or contribute the transactions or posted rates from which it is computed.
• Whether any existing compute price series meets the Appendix C standard of being reliable, acceptable, publicly available, and timely, and is computed from a sufficiently liquid cash market.
• What surveillance capabilities an exchange would need, and whether it should have information-sharing arrangements with every venue and provider whose data enter a settlement price.^[24]

The Commission said it preliminarily expects most compute derivatives to be cash-settled at first, because of the difficulty of delivering the underlying commodity.^[24] The comment period closes on October 20, before the extended review period for the CME products ends on November 9.^[22][24]

Distinction between announcement and launch

The distinction between an announcement, a regulatory filing, and a launch is material. Before a successful regulatory outcome and an actual listing, the products remain prospective. CME and Silicon Data describe possible benefits for traders, financial institutions, AI builders, and cloud-service providers, but those descriptions are intended uses. They are not evidence that a liquid market or an effective hedge already exists.^[2][3][25]

Contract design

Both contracts represent 730 GPU-hours and are quoted in dollars per GPU-hour. A quoted price of P therefore corresponds to a reference contract value of 730 x P. The minimum price change is one cent per GPU-hour, producing the $7.30 tick value published by NYMEX.^[1][17][26]

Trading is planned on CME Globex, with trades also eligible for submission for clearing through CME ClearPort. The contracts use a first-in, first-out matching algorithm. NYMEX plans to list 36 consecutive monthly contracts, and trading in an expiring month is scheduled to end on the last business day of that month. The block-trade threshold is five contracts with a 15-minute reporting window.^[17][26] The proposed rules also allow $0.005-per-GPU-hour increments for inter-commodity spreads executed as simultaneous transactions on CME Globex.^[17] Filed CME Globex hours run from Sunday 5:00 p.m. to Friday 4:00 p.m. Central Time, with a daily maintenance period from 4:00 to 5:00 p.m. The filing sets a Globex non-reviewable trading range of $0.20 per GPU-hour and exchange fees of $3.65 (member) and $5.50 (non-member) for CME Globex trades, with a cash-settlement processing fee of $0.90 (member) and $1.35 (non-member).^[17] CME Clearing's advisory gives the final settlement date as "LTD+2" and a contract multiplier of 730.^[26]

NYMEX classifies the settlement type as financial. The CFTC uses financial settlement and cash settlement as equivalent terms: an expiring position is settled by a cash amount based on an index or price rather than by delivery of the underlying commodity.^[8] A holder therefore cannot use the contract to obtain an H100 or B200 instance, a cluster reservation, a service-level agreement, or a place in a data center. The instrument addresses an index-linked price exposure only.

Proposed Chapters 1045 and 1047 define each month's final settlement price as the arithmetic average of the applicable Silicon Data on-demand settlement price on every business day during that contract month. The H100 contract uses SD-H100; the B200 contract uses SD-B200. Both specify the United States as the index geography, and the filing names the publisher as Silicon Derivatives Inc. (Silicon Data).^[17] The index-derived contract value at final settlement is therefore 730 times that monthly average.^[17]

The filing's position-control appendix sets a reportable level of 25 contracts for each product. The initial spot-month limits are 7,500 H100 contracts and 5,500 B200 contracts, effective at the close three business days before the last trading day. The single-month accountability levels are 15,000 and 11,000 contracts, respectively, while all-month accountability levels are 22,500 and 16,500.^[18] The appendix classifies both contracts in its "Power" group. These are filed terms for products awaiting approval, not evidence of live positions. The public filing does not specify initial or maintenance margin, or a contingency rule for unavailable index observations.^[17][18]

Reference indices

Silicon Data publishes daily rental-price benchmarks for several accelerators. Its public methodology overview says it draws observations from cloud providers, colocation markets, brokered cluster sales, and private rental platforms. It says the data are standardized for machine specifications, rental terms, platform performance, cluster scale, interconnect, and geography, then processed with outlier removal and quality-control checks.^[4][5][6]

For NVIDIA H100, Silicon Data publishes a neo-cloud reading under ticker SDH100RT and a separate hyperscaler reading. Both are described as standardized hourly rental rates. For NVIDIA B200, its public page describes a single standardized reading under ticker SDB200RT and says B200 coverage is expanding as more neo-cloud providers bring Blackwell capacity online. Silicon Data's index notices call the two series the H100 Neocloud Index and the B200 Neocloud Index.^[4][5][7] Silicon Data's public pages, updated September 27, 2026, showed the H100 neo-cloud reading at $2.70 per GPU-hour and the B200 reading at $5.87 per GPU-hour.^[4][5]

The proposed rulebook chapters identify the legal settlement series as the US on-demand SD-H100 and SD-B200 indices and do not mention Bloomberg tickers.^[17] Silicon Data's public product pages display SDH100RT and SDB200RT ticker labels.^[4][5] CME's product page names the underlying indices as the Silicon Data Daily H100 Rental Index and the Silicon Data Daily B200 Rental Index, says both futures "will track neocloud indices (non-hyperscaler)", and lists Bloomberg codes SDH100RT and SDRB200RT. The second code differs from the SDB200RT ticker that Silicon Data publishes.^[2][5] The legal settlement identifiers in the rulebook remain SD-H100 and SD-B200.^[17]

Silicon Data's methodology is also not static. A December 2025 index notice describes a restatement that removed a divisor adjustment and changed its pricing model and provider weights. The company estimated that change would reduce the H100 index by 4 to 6 percent. A provider expansion effective in April 2026 had an estimated negative effect of 3 to 7 percent without restating prior values.^[7] Later notices announced more changes without restatement: a B200 provider expansion, announced June 30 and effective July 15, 2026, with an estimated impact of up to a 6 percent decrease; and, effective September 25, 2026, an update to the H100 index's hardware baseline configuration and the removal of "a small number of stale providers" from the B200 index, each with an estimated impact of up to a 4 percent increase.^[7] These disclosed changes illustrate why index governance, provider coverage, and revision policies matter to a cash-settled contract.

US rules place continuing duties on a designated contract market that lists a cash-settled product. Regulation 38.253 requires the exchange to monitor both the price and the continuing appropriateness of the settlement-index methodology, and to make a good-faith effort to address threats of manipulation, disruption, or distortion.^[20] Appendix C to Part 38 identifies acceptable-practice considerations for a third-party cash index, including reliability, commercial acceptance, public availability, timeliness, calculation safeguards, any needed licensing, and information sharing where practicable.^[21] Regulation 38.253 imposes continuing duties; Appendix C supplies guidance. Neither is a finding that the pending contracts satisfy those standards. NYMEX's public submission asserts that the reference indices are broad and supported by robust trading in the underlying cash market, but its supplemental market information is redacted under a request for confidential treatment.^[17]

Hardware scope

The products do not treat all computing resources as interchangeable. H100 is a Hopper-architecture data-center GPU, while B200 is part of the Blackwell generation.^[13][14] Separate contracts allow the prices of the two rental markets to move independently. They do not imply that one GPU-hour on each device provides the same performance, memory capacity, energy use, networking capability, or value for a particular workload.

That distinction also limits the meaning of the generic phrase "compute futures." The announced CME products cover rental-price indices for two specific AI infrastructure components. They do not reference CPUs, custom AI accelerators, inference tokens, electricity, complete servers, or a performance-normalized unit of computing.^[1][4][5]

Intended hedging use

CME presents the products as a way for traders, financial institutions, AI builders, and cloud-service providers to manage volatility and price risk in compute, and its August release said they would allow companies, including AI developers and hyperscalers, "to lock in their costs".^[3][25] In a simplified case, a buyer whose future H100 bill moves closely with the designated H100 index could take a position intended to gain value when the index rises. A provider with index-linked rental revenue could use the opposite exposure. The actual hedge ratio would depend on the size and behavior of the cash exposure.

This mechanism cannot lock in physical availability. A cash payout may offset part of a price increase, but it cannot supply GPUs if a region or provider has no capacity. It also cannot make a rented instance conform to the index's standardized configuration. The CFTC calls the risk that the relationship between a cash price and its futures hedge changes unexpectedly basis risk.^[8]

Potential sources of basis risk include provider type, region, GPU form factor, host configuration, memory, interconnect, cluster scale, support terms, rental duration, and availability guarantees. Silicon Data says it normalizes several of those variables, but a benchmark cannot be assumed to match every cloud computing invoice or provider revenue stream.^[4][6][8]

A working paper by Federico M. Bandi and Yinan Su, first posted to arXiv on July 13, 2026 and most recently revised on September 10, highlights a second difference from many physical commodities. Compute service is non-storable: a GPU-hour left unused today cannot be carried into a future month. The authors argue that ordinary cash-and-carry pricing does not directly connect today's spot rental rate to a later compute-futures price. They also distinguish a financial contract from a term rental, which includes actual access to capacity. Their empirical analysis uses synthetic forward curves because traded compute-futures returns did not yet exist, and its findings are preliminary rather than measurements of the CME products. The authors thank Silicon Data and Ornn for providing data.^[10] The CFTC's August 2026 request for comment cites the paper for its estimate of the economic scale of AI compute.^[24]

Market context and open questions

CME called the project a "first-in-class" market in its May announcement. That wording is the company's positioning, not proof that it will be the first active venue.^[3] Several other exchanges and index providers announced compute derivatives in 2026. The US exchange-listed futures plans were all conditional on regulatory processes as of September 28, 2026:

Ornn's index has also been used outside futures exchanges. Kalshi, a CFTC-regulated prediction market, listed contracts on GPU compute prices resolved with Ornn data in March 2026, and FalconX announced on May 27, 2026 an over-the-counter swap referencing Ornn's H100 index, which it described as "the first over-the-counter swap referencing the forward price of compute".^[30][31] Nodal and Compute Desk described Compute Desk's indexes as "IOSCO-compliant"; that is the companies' own description.^[28]

These initiatives use different index concepts and cannot be treated as interchangeable. Their existence shows that compute derivatives are a developing category, while their conditional status makes any ranking by launch order premature.^{[9][11][12][28]} The CFTC's request for comment also asked whether perpetual compute futures would offer advantages over fixed-date contracts or pose unique risks.^[24]

Several questions will remain open unless and until the CME products receive approval, begin trading, and produce an observable market record:

• How will the CFTC's review, and the comments it receives by October 20, 2026, affect the contract terms or the listing date?
• How will corrections, methodology changes, or unavailable index observations be handled?
• What initial and maintenance margins will apply at launch?
• Will trading remain active across several monthly maturities?
• How closely will the futures track the rental exposures of actual buyers and providers?

Until those points have public answers and observed market data, claims that the contracts create reliable price discovery, deep liquidity, cheaper financing, or consistently effective hedges remain projections rather than established outcomes.^{[1][2][7][9][15][16][22][24]}

References

1. ^1 ^2 ^3 ^4 ^5CME Group. *SER-9785: Initial Listing of Two (2) Compute Futures Contracts - Silicon Data H100 Rental Index Futures and Silicon Data B200 Rental Index Futures*. August 11, 2026. cmegroup.com/...ser-9785
2. ^1 ^2 ^3 ^4 ^5 ^6CME Group. *Compute Futures*. Accessed August 15 and September 28, 2026. cmegroup.com/...compute-futures
3. ^1 ^2 ^3 ^4CME Group. *CME Group and Silicon Data Partner to Launch First Compute Futures*. May 12, 2026. cmegroup.com/...partnertolaunchfirstcomputefutures
4. ^1 ^2 ^3 ^4 ^5 ^6Silicon Data. *H100 Rental Price Index*. Accessed September 28, 2026. silicondata.com/...h100
5. ^1 ^2 ^3 ^4 ^5 ^6Silicon Data. *B200 Rental Price Index*. Accessed September 28, 2026. silicondata.com/...b200
6. ^1 ^2Silicon Data. *GPU Rental Price Indices*. Accessed September 28, 2026. silicondata.com/...silicon-index
7. ^1 ^2 ^3 ^4Silicon Data. *GPU Index Announcements*. Accessed September 28, 2026. docs.silicondata.com/...gpu-index-announcements
8. ^1 ^2 ^3US Commodity Futures Trading Commission. *Futures Glossary*. Accessed August 15, 2026. cftc.gov/...CFTCGlossary
9. ^1 ^2 ^3Emily Peck. *The push to create a futures market for AI compute*. Axios, August 12, 2026. axios.com/...ai-futures-compute-cme
10. ^Federico M. Bandi and Yinan Su. *(Early) AI Compute Asset Pricing*. arXiv working paper, first posted July 13, 2026, revised September 10, 2026 (v3). arxiv.org/...2607.12156
11. ^1 ^2Intercontinental Exchange. *ICE and Ornn to Launch GPU Compute Futures Contracts*. May 19, 2026. ir.theice.com/...default
12. ^1 ^2Intercontinental Exchange. *ICE and NATIVX to Launch Energy-Normalized Compute Futures Contracts*. July 1, 2026. ir.theice.com/...default
13. ^Nvidia. *H100 GPU*. Accessed August 15, 2026. nvidia.com/...h100
14. ^Nvidia. *Supported GPUs*. NVIDIA Multi-Instance GPU User Guide, accessed August 15, 2026. docs.nvidia.com/...supported-gpus
15. ^1 ^2 ^3 ^4 ^5 ^6US Commodity Futures Trading Commission. *Designated Contract Market Products: Silicon Data H100 Rental Index Futures*. Filing 62544, accessed August 17 and September 28, 2026. cftc.gov/...62544
16. ^1 ^2 ^3 ^4 ^5 ^6US Commodity Futures Trading Commission. *Designated Contract Market Products: Silicon Data B200 Rental Index Futures*. Filing 62545, accessed August 17 and September 28, 2026. cftc.gov/...62545
17. ^1 ^2 ^3 ^4 ^5 ^6 ^7 ^8 ^9 ^10 ^11 ^12 ^13New York Mercantile Exchange. *NYMEX Submission No. 26-370: Voluntary Submission for Product Approval*. Filed with the US Commodity Futures Trading Commission, August 11, 2026. cftc.gov/...ptc08112615405.pdf
18. ^1 ^2New York Mercantile Exchange. *NYMEX Submission No. 26-370, Appendix B: Position Limit, Position Accountability and Reportable Level Table*. Filed with the US Commodity Futures Trading Commission, August 11, 2026. cftc.gov/...ptc08112615406.xlsx
19. ^Electronic Code of Federal Regulations. *17 CFR 40.3: Voluntary submission of new products for Commission review and approval*. Accessed August 17, 2026. ecfr.gov/...section-40.3
20. ^Electronic Code of Federal Regulations. *17 CFR 38.253: Additional requirements for cash-settled contracts*. Accessed August 17, 2026. ecfr.gov/...section-38.253
21. ^Electronic Code of Federal Regulations. *Appendix C to Part 38: Demonstration of Compliance That a Contract Is Not Readily Susceptible to Manipulation*. Accessed August 17, 2026. ecfr.gov/...appendix-Appendix%20C%20to%20Part%2038
22. ^1 ^2 ^3 ^4 ^5US Commodity Futures Trading Commission, Division of Market Oversight. *Extension of Initial Review Period of NYMEX Submission No. 26-370 and Submission No. 26-370S for an Additional 45-Days*. Letter to CME Group, September 21, 2026. cftc.gov/...orgdcmnymexcompcontr260921.pdf
23. ^US Commodity Futures Trading Commission. *CFTC Requests Comment on the Listing of Compute Derivatives Contracts*. Release 9286-26, August 19, 2026. cftc.gov/...9286-26
24. ^1 ^2 ^3 ^4 ^5 ^6 ^7 ^8US Commodity Futures Trading Commission. *Request for Comment on the Listing of Compute Derivatives Contracts*. Federal Register, Vol. 91, No. 161, pp. 54259-54264 (FR Doc. 2026-17163), August 21, 2026. govinfo.gov/...2026-17163.pdf
25. ^1 ^2 ^3 ^4CME Group. *CME Group and Silicon Data to Launch Compute Futures on October 5 to Unlock New Way to Hedge AI Risks*. August 11, 2026. cmegroup.com/...nchcomputefuturesonoctober5tounloc
26. ^1 ^2 ^3 ^4 ^5 ^6 ^7 ^8CME Clearing. *Revised New Product Summary: Initial Listing of Two (2) Compute Futures Contracts - Silicon Data H100 Rental Index Futures and Silicon Data B200 Rental Index Futures, Effective Date to be Announced*. Advisory 26-274, September 25, 2026. cmegroup.com/...26-274
27. ^Finimize. *CME's Nvidia GPU Futures Hit A Regulatory Speed Bump*. September 23, 2026. finimize.com/...utures-hit-a-regulatory-speed-bump
28. ^1 ^2 ^3Nodal Exchange. *Nodal Exchange and Compute Desk to launch Compute Futures Contracts*. September 3, 2026. nodalexchange.com/...nch-compute-futures-contracts
29. ^Architect Financial Technologies (PR Newswire). *Architect Financial Technologies Partners with Compute Index Provider Ornn to Launch Exchange-Traded Futures on GPU and RAM Prices*. January 21, 2026. prnewswire.com/...-on-gpu-and-ram-prices-302666613
30. ^Sebastian Moss. *Kalshi users able to wager on Nvidia GPU compute prices, based on Ornn's compute derivatives platform*. Data Center Dynamics, March 4, 2026. datacenterdynamics.com/...ute-derivatives-platform
31. ^FalconX. *FalconX Executes First OTC Compute Forward Trade*. May 27, 2026. falconx.io/...utes-first-otc-compute-forward-trade
32. ^1 ^2Architect Financial Technologies (PR Newswire). *Architect Financial Technologies to Launch U.S. Futures Exchange for Compute and AI Commodities Following DCM Acquisition*. May 28, 2026. prnewswire.com/...lowing-dcm-acquisition-302784564