Course owner the Jockey Club is considering plans with Redrow for 3,000 homes on the historic track.
Money raised from the sell-off would help fund a £500m investment in horse racing by the Jockey Club.
Re-investment plans include a new floodlit all-weather racecourse in Newmarket.
Any sale of Kempton Park would not be until 2021 at the earliest and would be dependent on raising at least £100m.
Plans have been submitted by the Jockey Club to Spelthorne Borough Council to redevelop Kempton Park.
A planning application for the all-weather track at Newmarket is currently being prepared.
The Jockey Club said: “We would build this new course subject to achieving planning consent in Newmarket and a positive outcome from the planning process at Kempton Park.”