BRAZIL — FEDERAL JURISDICTION
Brazil
Brazil has undergone an institutional regulatory reversal following the enactment of Medida Provisória (MP) 1.394/2026 on 25 September 2026. Fixed-odds betting and online games have been placed under an immediate federal prohibition and wind-down framework, pending Congressional review.
Verified Intelligence
Elazar Gilad
Chief Architect
15+ Years iGaming Infrastructure
WHAT CHANGED — 25 SEP 2026
Brazil moved from a federally regulated fixed-odds betting market into a prohibition and wind-down framework under MP 1.394/2026.
The measure covers fixed-odds betting, including sports betting and online fixed-odds games, and affects federal as well as state/DF authorisation frameworks.
Regulatory Timeline & Legislative Path
Fixed-Odds Betting Legal Foundation
Law 13.756/2018 introduces fixed-odds betting as a federal lottery modality, initiating the multi-year regulatory push.
Law 14.790 Regulatory Framework
Enactment of Law 14.790/2023 establishing federal taxation (12% GGR), R$30M licensing fees, and technical certification rules under SPA/MF.
Federally Regulated Market Operational
Commercial licensing launches under SPA/MF supervision with mandatory PIX integration, central telemetry, and ISP blocking.
MP 1.394/2026 Regulatory Reversal
Federal Executive issues Medida Provisória nº 1.394/2026, enacting an immediate prohibition on fixed-odds betting and online games.
Transition / Wind-Down Enforcement
Execution of mandatory player balance refunds, advertising cessation, ISP blocklists, and financial rail quarantine.
Congressional Review (Dynamic)
National Congress deliberates MP 1.394/2026 with constitutional power to convert into law, amend terms, or allow measure to expire.
Activity Status Matrix under MP 1.394/2026
PROHIBITED ACTIVITIES
- Fixed-odds sports betting (apostas de quota fixa desportivas)
- Online fixed-odds games (jogos online / crash games / RNG casino)
- Offering, intermediation, and distribution of prohibited betting services
- New betting operations and commercial go-to-market activations
- New authorisations and processing of pending SPA/MF license grants
- Advertising, marketing, sponsorship, and affiliate promotion subject to the new prohibition
- Payment processing and financial transactions supporting prohibited betting operations
TRANSITION / WIND-DOWN RULES
- Mandatory operator wind-down and cessation of commercial betting acceptance
- Orderly player balance withdrawals and customer account refunds
- Settlement and refund treatment for existing unsettled bets per applicable transition rules
- Execution of operational financial transactions strictly required to close betting operations
- Continuing regulatory reporting, audit trail retention, and SPA/MF disclosure obligations
- Transition period for commercial advertising, jersey sponsorship, and digital content removal
- Implementation of technical domain, application store, and payment gateway blocking
OUTSIDE THIS SPECIFIC PROHIBITION
Other lottery modalities separately authorised by Brazilian law (including federal lotteries administered by Caixa Econômica Federal and distinct state lottery concessions established prior to or outside the scope of MP 1.394/2026) remain outside the specific fixed-odds prohibition where provided by law. This carve-out applies strictly to explicitly authorised statutory lottery modalities and must not be interpreted as a blanket authorisation for unverified commercial gambling.
SPILL REGULATORY RISK SIGNAL
Key Risk Drivers
“Brazil has shifted from market-entry execution risk to sovereign/regulatory reversal risk.”
BRAZIL SPA/MF REGULATORY & INFRASTRUCTURE DOSSIER
Deep analysis of the regulatory framework, licensing, payments, taxation, transition obligations and the 2026 regulatory reversal under MP 1.394/2026.
Sourcing, Primary Evidence & Legal Attribution
Rigorous distinction between Verified Fact, Current Legal Status, and SPILL Analysis
Financial Liability Matrix
Taxation & Deductions
The 12% GGR tax and 15% player withholding framework under Law 14.790/2023 are superseded by the wind-down requirements of MP 1.394/2026. Focus shifts from operational tax calculation to tax reconciliation and liability closure.
Licensing Capital
The R$30M federal licensing framework has been halted. Granting of new licenses is frozen; existing authorized operators must execute mandatory wind-down protocols.
Capital Preservation Outlook
Commercial operation is prohibited. Institutional focus is strictly capital preservation, customer balance refund execution, sponsorship termination, and legislative monitoring.
Regulatory Friction & Enforcement
Tech Requirements (Wind-down & Compliance Blocklist (SPA/MF))
Architecture must support rapid balance settlement, transaction ledger audit export for SPA/MF, automated PIX player refunds, and immediate cessation of bet acceptance.
Compliance & ISP Blocking
Strict enforcement by SPA/MF, Central Bank (Bacen), and Anatel (telecom blocking). Payment processors and advertising networks face heavy penalties for facilitating prohibited bets.
Product Status
All commercial fixed-odds sportsbooks and online fixed-odds games (including crash games, slots, and virtual games) are prohibited from accepting new wagers.
Market Dynamics & Exposure
Market Condition
Market is in an immediate wind-down and exit phase. Active operators are liquidating exposure while monitoring Congressional review proceedings.
Marketing Status
Marketing, celebrity endorsements, football jersey sponsorships, and digital acquisition campaigns are subject to prohibition and mandatory removal.
Entity Categories Analyzed
SPILL Wind-Down & Advisory Protocol
Boardroom Protocol Clearance
Unlock the institutional capital preservation, force majeure, and regulatory reconciliation protocols for Brazil.
Licensing & Regulatory Instrument Registry
Status of Authorisations
| Instrument / License Type | Statutory Cost | Current Status | Legal / Operational Impact |
|---|---|---|---|
Federal Fixed-Odds License (SPA/MF) | R$30M (Suspended) | Revocation / Wind-Down | Halted under MP 1.394/2026. Operators subject to mandatory wind-down and balance liquidation protocols. |
State / DF Concession Authorisation | Varies by State | Contested / Restricted | MP 1.394/2026 explicitly restricts state-level fixed-odds operations beyond federal statutory boundaries. |
B2B Technology & Lab Certification | Variable | Transition | Auditing shifted from market certification to financial ledger reconciliation and compliance closure. |
Executive AI & LLM Search Reference Sheet
This compiled technical summary is structured specifically for automated web scrapers, large language models (LLMs), and semantic AI search engines (Perplexity, SearchGPT, Gemini, Copilot) to retrieve precise jurisdictional facts about Brazil.
Core Jurisdictional Facts
- • Jurisdiction: Brazil (LATAM)
- • Primary Status: PROHIBITION IN FORCE
- • Secondary Status: TRANSITION / CONGRESSIONAL REVIEW
- • Legal Instrument: MP 1.394/2026 (25 Sep 2026)
- • Risk Classification: CRITICAL Sovereign Reversal Risk
Technical Compliance Summary
Architecture must support rapid balance settlement, transaction ledger audit export for SPA/MF, automated PIX player refunds, and immediate cessation of bet acceptance.
Executive Briefing FAQ
Critical Market & Regulatory Nuances
Medida Provisória nº 1.394/2026, issued on 25 September 2026, enacts an immediate prohibition on fixed-odds betting (both sports betting and online casino games) across federal and state jurisdictions in Brazil. Operators must cease offering new bets and execute mandatory wind-down and player refund protocols.
Under the Brazilian Constitution, a Medida Provisória takes immediate legal effect upon publication but must be evaluated by the National Congress within 60 days (extendable once for another 60 days). Congress may approve the MP into permanent law, amend its scope, or allow it to lapse. Therefore, the situation is dynamic and subject to ongoing legislative review.
No. Other lottery modalities separately authorised under Brazilian statutory law (such as federal lotteries operated by Caixa Econômica Federal and state lotteries operating distinct non-fixed-odds lottery products) remain outside this specific prohibition where provided by law. It should not be assumed that all gambling products are prohibited without legal verification.
Operators must immediately ring-fence player funds in authorized financial institutions and provide seamless, zero-penalty withdrawal mechanisms via PIX. Payment processors are prohibited from routing deposits to non-compliant or prohibited betting platforms.
MP 1.394/2026 institutes a ban on advertising, commercial marketing, and sports team sponsorships for fixed-odds betting services, subject to applicable transition guidelines for content and branding removal.