In the current system of allocation, patients awaiting orthotopic liver transplantation (OLT) remain at risk of developing de novo hepatocellular carcinoma (HCC) and removal from the waiting list. Using the United Network for Organ Sharing database, we calculated the rate and identified predictors of de novo HCC in patients listed for OLT between February 2002 and December 2004. Among 8566 patients, 1167 (13.6%) developed de novo HCC. Predictors of increased odds of de novo HCC were older age, male gender, Asian race, other race, hepatitis C, and hepatitis B. A sensitivity analysis of 2067 patients waiting at least 6 months found that 16.2% developed de novo HCC. Older age [odds ratio (OR) 1.05; 95% confidence interval (CI) 1.03, 1.07], male gender (OR 2.01; 95% CI 1.49, 2.71), Asian race (OR 2.39; 95% CI 1.20, 4.76), other race (OR 1.94; 95% CI 1.40, 2.68), hepatitis C (OR 2.36; 95% CI 1.76, 3.16), and hepatitis B (OR 1.96; 95% CI 1.19, 3.23) remained predictors of increased odds of de novo HCC, and alcoholic liver disease (OR 1.40; 95% CI 1.06, 1.86) emerged as a predictor of increased odds of de novo HCC. A significant proportion of patients listed for OLT develop de novo HCC. Identifying predictors of HCC in these patients may facilitate timely HCC screening and diagnosis.