CMECME Group

Please represent to us that you will revise future filings to include the geographic disclosures under ASC 280-10-50-41. Otherwise, tell us why they are not required. Exhibit 99.1, page General

We will provide the geographic disclosures in our future annual filings, as required by ASC 280-10-50-41. The following is an illustration of the proposed disclosure to be included within footnote 18, Segment Reporting, in our Form 10-K.

Material revenue and long-lived assets are defined as those which represent 10% or more of total revenues and long lived assets.

Rest of the answer

Revenue and long lived assets by country for the years ended December 31, 2025, 2024 and 2023 and as of December 31, 2025 and 2024 are set forth in the table below:

Revenues (b)

Long-lived Assets (c)

(in millions) 2025 2024 2023 2025 2024

United States $ xxx $ xxx $ xxx $ xxx $ xxx

United Kingdom (a) xxx xxx xxx xxx xxx

Other foreign countries xxx xxx xxx xxx xxx

Totals $ xxx $ xxx $ xxx $ xxx $ xxx

(a) United Kingdom includes Great Britain and Northern Ireland.

(b) Revenues are classified based upon the location of the customer.

(c) Long-lived assets represent property, plant and equipment, indefinite-lived intangible assets, amortizable intangible assets, and other investments included in other assets. See Note 5 for further information on property. See Note 6 for further information on goodwill and other intangible assets. See Note 17 for further information on investments included in other assets. These assets are reported in the country where they are primarily used.

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You reference Adjusted Operating Income and state that you recorded all-time record Adjusted Operating Income in the second quarter of 2025. We note that you do not quantify Adjusted Operating Income or include a reconciliation from a GAAP measure to this non-GAAP measure.

Rest of the question

Please either remove reference to this non- GAAP measure in future releases furnished on Forms 8-K, or advise otherwise as to why it is a meaningful and useful measure and include all of the disclosure requirements of Item 10(e) or Regulation S-K.

In future filings, the Company will include all applicable disclosure requirements of Item 10(e) of Regulation S-K for non-GAAP measures used. We believe that the presentation of non-GAAP Operating Income provides important supplemental information to management and investors about financial and business trends relating to the company’s financial condition and results of operations. We propose to include the following table within our future releases on Form 8-K to quantify and provide a reconciliation for GAAP to non-GAAP Operating Income.

CME Group Inc.

Rest of the answer

and Subsidiaries

Adjusted Revenue, Operating Expense and Operating Income Reconciliation

(dollars in millions, except per share amounts; shares in thousands)

Quarter Ended

September 30,

Nine Months Ended

2025 2024 2025 2024

Total Revenues $

XXX

$

Real estate-related costs (credits)

Adjusted Revenues $

Expenses

Restructuring and severance

Deferred compensation(1)

Amortization of purchased intangibles

Strategic transaction-related costs

Foreign exchange transactions (gains) losses

Unrealized and realized (gains) losses on assets

Litigation matters or settlements

Adjusted Operating Expenses $

Operating Income $

Adjusted Operating Income $

1. Includes $X.X million and $X.X million for a change in our non-qualified deferred compensation liability in the third quarter and first nine months of 2025. This impact does not affect net income, because the compensation and benefits change has an equal and offsetting change in investment income.

We will also continue to include the reconciliation for GAAP to non-GAAP Net Income, Net Income Attributable to CME Group and Diluted EPS as shown in the following table.

Adjusted Net Income, Net Income Attributable to CME Group and Diluted EPS Reconciliation

Net Income $

Amortization of purchased intangibles(1)

Strategic transaction-related costs (credits)

Foreign exchange transaction (gains) losses

Unrealized and realized (gains) losses on investments

Income tax effect related to above

Other income tax items

Adjusted Net Income $

Adjusted Net Income Attributable to Common Shareholders of CME Group $

Earnings per Share Attributable to Common Shareholders of CME Group:

Basic $

Diluted

Adjusted Earnings per Share Attributable to Common Shareholders of CME Group:

Weighted Average Number of Common Shares:

Basic

Preferred shares(2)

1. Includes $X.X million and $X.X million of amortization of purchased intangibles (net of tax) at OSTTRA and $X.X million and $X.X million of amortization of purchased intangibles at S&P Dow Jones Indices LLC in the third quarter and first nine months of 2025. This is reported in Equity in net earnings of unconsolidated subsidiaries on the Consolidated Statements of Income.

2. Preferred shares have similar rights as common shares without voting rights.

In addition, the Company acknowledges:

•the Company is responsible for the adequacy and accuracy of the disclosures in the filing;

•Staff comments or changes to disclosures in response to Staff comments do not foreclose the Commission from taking any action with respect to the filing; and

•the Company may not assert Staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws in the United States.

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