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Secretaria de Prêmios e Apostas / Ministério da Fazenda — Brazil online-gambling standards explorer (Lei 14.790/2023 verified art-by-art against Planalto; Lei 13.756/2018; SPA/MF Portarias 2024 pipeline plus 2025-2026 updates including 566, 754, 787, 1.082, 1.453, 2.217, 2.579; CMN 5.298/2026; LC 224/2025; IN RFB 2.312/2026; STF ADI 7.721 cautelar)
All 171 Brazilian standards, organised by theme
A searchable, filterable index of Brazil's federal online-gambling rulebook, drawn from Lei 14.790/2023 (the Lei das Bets), Lei 13.756/2018, Portaria Normativa MF 1.330/2023, the 2024 Portaria SPA/MF pipeline (561, 615, 722, 827, 1.143, 1.207, 1.225, 1.231 and 1.233), Instrução Normativa RFB 2.299/2025 and the supporting decisions of the Supreme Federal Court. Standards are grouped by theme, tagged editorially and deep-linkable.
Editorial summary, not legal advice. Every card on this page is a plain-English summary of the regulator's own rule, cross-checked against the primary source. Always verify against the published text before filing, launching, or advising.
Brazil's fixed-odds regime sits on top of a long constitutional fight over who may authorise gambling. Lei 13.756/2018 ended the federal lottery monopoly that had stood since 1946; the Supreme Federal Court then opened the door to state and municipal participation, while Lei 14.790/2023 centralised online operator authorisation in the federal Ministry of Finance.
11 standards7 player-flagged
64%
player-flagged
Regulatory risks this theme addresses
Operating under a state or municipal lottery permission that the STF has since restricted
Assuming federal authorisation pre-empts every parallel local rule on advertising or consumer protection
Missing a pending STF ruling that changes the perimeter of permitted activity
Foundational statutes and case law 11
Decreto-Lei 9.215/1946
1946 federal ban on games of chance
Player Rights
Decree-Law 9.215 of 30 April 1946 banned games of chance across Brazil and shut the licensed casino sector that had existed under Decreto-Lei 6.259/1944. The 1946 prohibition has never been formally repealed and continues to outlaw land-based casinos, bingo and similar games; the modern federal regime only authorises specific lottery modalities.
Requirements
Treat land-based casino, bingo and slot operation as prohibited absent a specific federal authorising law
Do not rely on pre-1946 permits or state-level land-based authorisations
Confine activity to the lottery modalities expressly authorised under Leis 13.756 and 14.790
Track STF dockets and SPA/MF positions for changes that affect the perimeter of permitted activity
Bills to legalise integrated resort casinos and physical bingo are pending in Congress but had not been enacted at the cut-off date of this dataset.
Lei 13.756/2018
Creation of the fixed-odds lottery modality
Law 13.756 of 12 December 2018 created the apostas de quota fixa lottery modality and broke the federal lottery monopoly that had been held by Caixa Econômica Federal. It set the framework for a future authorisation regime, distributed lottery proceeds across public funds and authorised the Ministry of Finance to regulate the new modality.
Requirements
Cite Lei 13.756 alongside Lei 14.790 as the originating statute for any operator authorisation
Track changes to the prize-distribution allocations the law mandates
Maintain records to support the lottery prize distribution required by arts. 26 to 32
Brief executive leadership on the constitutional context underpinning the operating authorisation
Lei 14.790/2023
Modern fixed-odds and online-gaming statute
Player Rights
Law 14.790 of 29 December 2023 is the primary statute for online sports betting and online gaming in Brazil. It amends Lei 13.756/2018, vests the Ministry of Finance with authorisation, supervision and sanctioning power and sets out player rights, prohibited bettors, taxation, integrity duties and the sanctions ladder.
Requirements
Read Lei 14.790 as the controlling federal statute for any online betting or online gaming activity
Map every Portaria SPA/MF back to the article of Lei 14.790 it implements
Diarise the entry-into-force milestones that conditioned market launch on 1 January 2025
Maintain a register of constitutional and STF references in the compliance manual
Decreto 11.907/2024
Creation of the Secretaria de Prêmios e Apostas
Decree 11.907 of 30 January 2024 reorganised the Ministry of Finance and created the Secretaria de Prêmios e Apostas (SPA/MF) as the federal regulator for prizes, lotteries and fixed-odds betting. SPA/MF inherited the authorisation and supervision powers previously held by the Secretaria de Avaliação, Planejamento, Energia e Loteria (Secap).
Requirements
Direct all licence applications, certifications and supervisory filings to SPA/MF
Use SPA/MF as the regulator name on all bettor-facing disclosures
Treat any earlier Secap publication as superseded where SPA/MF has issued a Portaria on the same topic
Track STF dockets and SPA/MF positions for changes that affect the perimeter of permitted activity
STF ADPFs 492 e 493
State competence to operate lotteries
Player Rights
In September 2020 the STF judged ADPFs 492 and 493 together with ADI 4.986 and held that the Union's exclusive competence under article 22 of the Constitution covers legislating on lotteries, but not the material exploitation of them. The decision allowed states to operate their own lottery services within their territory, opening the door to state betting permissions parallel to the federal regime.
Requirements
Recognise that some state lotteries (for example Loterj, Loteria Mineira) operate under STF-recognised state competence
Distinguish a state lottery permission from a federal Lei 14.790 authorisation when assessing scope
Do not rely on a state permission to operate nationwide; geo-fence to the issuing state
Brief executive leadership on the constitutional context underpinning the operating authorisation
The STF reaffirmed this position in ADPF 1.103 (2024).
STF ADI 7.721
Federal authority to centralise online betting
ADI 7.721 challenges aspects of Lei 14.790 on federalism grounds. The pending action and parallel suits test whether federal centralisation of online operator authorisation can coexist with the state lottery competence recognised in ADPFs 492 and 493.
Requirements
Monitor the docket for any preliminary injunction that suspends a Lei 14.790 provision
Plan for the possibility that state-level online authorisations may be revived
Keep legal positioning on jurisdictional scope under quarterly review
Maintain a register of constitutional and STF references in the compliance manual
STF ADPF 1.212
Constitutionality of municipal lotteries
ADPF 1.212, filed in March 2025, asks the STF to suspend municipal laws and decrees authorising the operation of fixed-odds betting at the municipal level. A preliminary decision suspended several municipal lottery decrees pending the final judgment.
Requirements
Treat municipal lottery permissions as legally fragile until ADPF 1.212 is resolved
Do not accept a municipal permission as a substitute for SPA/MF authorisation for online activity
Track the rapporteur's progress before relying on any municipal-level licence
Track STF dockets and SPA/MF positions for changes that affect the perimeter of permitted activity
PGR ADI Lei das Bets
PGR challenge to the Lei das Bets
RG Critical
The Procuradoria-Geral da República filed an action at the STF challenging aspects of Lei 14.790, focused on the alleged failure of the statute to safeguard low-income bettors and adequately limit advertising. The action is pending and may force amendments or stricter implementing rules.
Requirements
Track the PGR action and any STF cautelar that could tighten the regime
Build advertising governance with headroom for stricter rules to be ordered
Document responsible-gambling spend and reach in case the STF requires evidence of effectiveness
Brief executive leadership on the constitutional context underpinning the operating authorisation
CMN Resolução 5.298/2026
Prediction markets prohibited as derivatives
Game Design
Resolution 5.298 of the National Monetary Council, in force from 4 May 2026, prohibits derivative contracts whose underlying is a sports event, online game, election or any political, social, cultural or entertainment event. Derivative contracts may only reference economic-financial variables. SPA/MF and the Ministry of Finance treat prediction-market platforms as fixed-odds betting subject to Lei 14.790.
Requirements
Do not present prediction-market or event-derivative products to Brazilian players
Block Brazilian access to any prediction-market platform that lacks SPA/MF authorisation
If offering event-linked contracts, ensure they meet the CVM and CMN definition of a permitted derivative
Maintain a register of constitutional and STF references in the compliance manual
The federal government blocked 27 prediction-market platforms, including Kalshi and Polymarket, on 24 April 2026.
Portaria Mesp 36/2025
Updated list of sports modalities eligible for fixed-odds betting
Game Design
Portaria Mesp nº 36 of 17 April 2025, issued by the Ministério do Esporte under article 5 of Law 14.790/2023, updates the list of sports modalities that may receive fixed-odds bets in Brazil. The instrument adds and removes specific competitions, codifies the criterion of organised competition with a recognised governing body and clarifies the interface with SPA on event-integrity monitoring.
Requirements
Restrict bet offerings to modalities present in the current Mesp list
Reconcile the betting catalogue with the official list at every product release
Maintain controls preventing markets on amateur or unrecognised competitions
Coordinate suspicious-betting reports with the Mesp event-integrity channel
Operators offering bets on modalities outside the official list expose themselves to sanction under Portaria 1.225/2024 and to product blocking by SPA.
Resolução CMN 5.298/2026 (mercados de predição)
Express prohibition on derivatives linked to sports, electoral and entertainment events
Game Design
Resolução CMN nº 5.298 of 24 April 2026 sets the parameters of the Brazilian derivatives market and expressly prohibits offering or trading derivative contracts whose underlying is a sports event, an online game, a political, electoral, social, cultural or entertainment event that is not representative of an economic or financial benchmark. The rule came into force on 4 May 2026 and forms the legal basis on which the CVM, the CMN and SPA blocked Polymarket, Kalshi and twenty-five further prediction-market sites at the end of April 2026.
Requirements
Do not offer or distribute derivative contracts referencing sports, electoral or entertainment outcomes in or into Brazil
Reclassify any product marketed as a prediction market against the Resolução and discontinue immediately if non-compliant
Apply the rule to foreign products distributed to Brazilian residents through any channel
Reconcile any economic-financial benchmark product against the CVM regulation issued in execution of the Resolução
Brokerage products that reference price indices, interest rates, exchange rates, commodities or securities remain permitted; the prohibition is targeted at event-outcome contracts that operate as betting in derivatives clothing.
2
Theme 2
Licensing & authorisations
SPA/MF runs a single federal authorisation regime created by Lei 14.790 and detailed in Portaria SPA/MF 827/2024. Authorisation costs R$ 30 million, lasts five years and permits up to three commercial brands per holder; capital and reserve floors apply throughout the term.
14 standards6 player-flagged
43%
player-flagged
Regulatory risks this theme addresses
Operating before SPA/MF issues the definitive authorisation
Letting capital, reserve or guarantee drop below the floor mid-term
Launching a fourth brand or a brand not declared in the application
Authorisation, fees and corporate eligibility 14
Lei 14.790/2023 art. 5
Federal authorisation required to exploit fixed-odds betting
Player Rights
Article 5 conditions the commercial exploitation of fixed-odds betting on a federal authorisation granted by the Ministry of Finance through SPA/MF. The authorisation is non-transferable, attaches to a specific corporate entity and may not be sublet or franchised.
Requirements
Hold a current SPA/MF authorisation before accepting Brazilian bets
Apply only through the corporate entity that will operate the platform
Do not market or accept bets through a sister company that is not on the authorisation
Retain the licence file, supporting evidence and SPA/MF correspondence for the term of the authorisation
Lei 14.790/2023 art. 7
Five-year authorisation term and brand cap
Article 7 sets the authorisation term at five years, renewable, and limits each authorised operator to a maximum of three commercial brands (marcas comerciais). Brand additions or substitutions must be approved by SPA/MF.
Requirements
Identify up to three brands in the authorisation application
Apply to SPA/MF before launching any additional or substitute brand
Diarise the renewal window at least nine months before expiry
Surface licensing milestones in the board governance calendar
Lei 14.790/2023 art. 6
Eligibility for legal entities incorporated in Brazil
Player Rights
Article 6 limits authorisation to legal entities incorporated under Brazilian law with headquarters and administration in Brazil. At least 20% of the share capital must be held by a Brazilian-resident partner.
Requirements
Incorporate (or domesticate) the licence-holder in Brazil before applying
Maintain at least 20% Brazilian-resident ownership for the life of the authorisation
Keep evidence of headquarters, board residency and effective management on file
Re-test the operator's standing against the eligibility criteria each year
Lei 14.790/2023 art. 12
R$ 30 million authorisation grant fee (statutory ceiling)
Append: 'The R$ 30 million CEILING and the 30-day payment deadline are statutory (Lei 14.790/2023 art. 12 parágrafo único and art. 13 respectively); Portaria SPA/MF 827/2024 fixes the outorga at the statutory ceiling. Each authorisation act covers up to 3 commercial brands; an operator wanting more than 3 brands must obtain additional authorisation acts, each subject to another R$ 30 million.
Requirements
Provision the R$ 30 million grant fee in liquid resources before applying
Pay the fee within 30 days of the authorisation act and send proof to SPA/MF
Treat the fee as a sunk regulatory cost; it is not refundable on early termination
Retain the licence file, supporting evidence and SPA/MF correspondence for the term of the authorisation
The R$ 30 million grant fee is paid per authorisation act, not per brand. One authorisation covers up to three commercial brands, so an operator wanting a fourth brand must obtain a second authorisation and pay a second R$ 30 million fee. Payment is via DARF and must clear before the SPA/MF Despacho Autorizativo is published in the Diário Oficial da União. The 2024 grant fee has not been re-indexed as of May 2026.
Lei 14.790/2023 art. 7
Capital, equity and technical reserve floors
Player Rights
Lei 14.790/2023 art. 7 (VII-VIII) requires authorised operators to maintain minimum integralised share capital of R$ 30 million and minimum net equity of R$ 30 million, plus a technical reserve dedicated to player liabilities and operational continuity. Reserves must be reconstituted whenever drawn down, under parameters set by SPA/MF regulation.
Requirements
Maintain minimum integralised share capital of R$ 30 million
Maintain minimum net equity of R$ 30 million
Constitute and maintain a technical reserve dedicated to player liabilities and operational continuity
Reconstitute the technical reserve whenever drawn down
Three concurrent thresholds: paid-up share capital of R$ 30 million in cash, net worth of R$ 30 million, and a technical reserve of R$ 5 million per authorisation act. The technical reserve must be ring-fenced in a Banco Central authorised institution and reported quarterly through SIGAP. None of these amounts were re-indexed by SPA/MF for 2026.
Portaria SPA/MF 827/2024 art. 10
Fit-and-proper test for directors and qualifying shareholders
Player Rights
Directors, de facto managers and qualifying shareholders must demonstrate honourability, technical competence and absence of disqualifying convictions. Administrators must show at least three years' professional experience in gaming, betting or lotteries, or compatible academic qualifications.
Requirements
Submit criminal-record, civil-record and tax-clearance certificates for every officer and qualifying shareholder
Document the three-year experience or academic qualifications for each administrator
Notify SPA/MF of any change of board, control or qualifying shareholder
Re-test the operator's standing against the eligibility criteria each year
Portaria SPA/MF 827/2024 art. 14
150-day decision deadline and authorisation act
SPA/MF has up to 150 days from receipt of a complete application to grant or reject authorisation. A grant is formalised by an authorisation act published in the Diário Oficial da União; only on payment of the grant fee does the operator become authorised to operate.
Requirements
Plan for at least 150 days between filing a complete application and going live
Monitor the DOU for the authorisation act and act on it within the 30-day fee window
Do not accept bets between the act and confirmation of payment
Retain the licence file, supporting evidence and SPA/MF correspondence for the term of the authorisation
Portaria SPA/MF 827/2024 art. 22
Brand approval, change of control and material change notifications
Material changes; change of control, substitution of qualifying shareholders, modification of brand portfolio, change of platform provider; require prior SPA/MF approval. Failure to obtain approval is a ground for sanction up to revocation.
Requirements
File a prior approval request before any change of control or brand substitution
Do not implement the change before the SPA/MF non-objection or approval is received
Keep a register of all material changes notified, with SPA/MF acknowledgement numbers
Surface licensing milestones in the board governance calendar
Portaria SPA/MF 561/2024
SPA/MF regulatory policy and agenda
Portaria SPA/MF 561/2024 sets the SPA/MF regulatory policy and publishes the regulatory agenda. It commits the regulator to a planned, transparent, consultative rule-making process and lists the priority workstreams that became the 2024-2025 Portaria pipeline.
Requirements
Track the SPA/MF regulatory agenda for upcoming public consultations
Submit operator positions during the consultation windows
Plan implementation budgets around the priorities published in the agenda
Re-test the operator's standing against the eligibility criteria each year
Portaria Normativa MF 1.330/2023
Foundational policy ordinance for fixed-odds betting
Portaria Normativa MF 1.330 of 26 October 2023 set the general conditions for the commercial exploitation of fixed-odds betting under Lei 13.756/2018 and introduced the first cross-cutting duties on operators in the areas of bettor rights, anti-money laundering and responsible gambling. It is the policy ancestor of the 2024 Portaria pipeline.
Requirements
Read Portaria MF 1.330/2023 as the policy framework underlying the more detailed 2024 Portarias
Where Portaria MF 1.330 and a 2024 Portaria conflict, follow the later, more specific instrument
Keep Portaria MF 1.330 in the regulatory inventory as a still-in-force foundational rule
Retain the licence file, supporting evidence and SPA/MF correspondence for the term of the authorisation
Portaria SPA/MF 754/2025
Extended window for image-rights pooling associations
Bonus & Ads
Portaria SPA/MF nº 754 of 8 April 2025 extends by 90 days the deadline for authorised fixed-odds operators that previously expressed interest in forming associations to centralise payment of image rights to athletes and sports entities. The Portaria allows operators to provision the corresponding resources during the extended window and clarifies the interface with Portaria 1.231/2024 article 56 on athlete-image use in advertising.
Requirements
Express interest in joining or forming the image-rights pool within the extended window
Provision the calculated image-rights consideration on the balance sheet and segregate the funds
Disclose participation in the pool to SPA and in marketing materials that depict athletes
Reconcile pool contributions with the advertising approvals granted under Portaria 1.231/2024
The Portaria responds to the friction created when the 2024 regime began enforcing the prohibition on unauthorised use of athletes' image in betting ads.
Portaria SPA/MF 817/2025
Regulatory agenda 2025-2026 for fixed-odds betting
Portaria SPA/MF nº 817 of 15 April 2025 publishes the formal regulatory agenda of the Secretariat for the biennium 2025-2026. It lists the priority normative acts the SPA intends to issue, including the consolidated self-exclusion register, the prediction-market position, the certifier homologation roadmap, the responsible-gambling enforcement template and the public-consultation calendar. The agenda forms the planning baseline against which subsequent 2025 acts (the 2.217, 2.219 and 2.579 Portarias and IN 22, 24, 31 and 35) were issued.
Requirements
Track every priority item against the agenda calendar published by SPA
Submit comments during the public-consultation windows referenced in the agenda
Align internal compliance roadmaps with the agenda milestones
Refresh the regulatory horizon analysis quarterly using the updated agenda
The agenda is a planning instrument, not a binding rule on operators; it nevertheless signals the supervisory priorities used by SPA when allocating inspection capacity.
Instrução Normativa SPA/MF 35/2025
Procedure for communicating changes to the authorisation conditions
Instrução Normativa SPA/MF nº 35 of 3 December 2025 sets the procedure operators must follow to notify SPA of any change in the conditions that justified the deferment of their authorisation under articles 6 and 22 of Portaria 827/2024, and of the start of their operational activities. It distinguishes between changes that require prior approval and changes that produce immediate effects subject to subsequent confirmation.
Requirements
Map every authorisation condition (shareholders, controllers, capital, infrastructure, certifiers) to the IN 35/2025 notification matrix
Submit prior-approval requests through SIGAP and refrain from implementing the change until the decision is issued
Notify immediate-effect changes within the statutory window and reconcile with the SIGAP file
Update the corporate governance file and the AML risk assessment after any approved change
Notify the start of operational activities through SIGAP within the deadline fixed by the IN
Failure to notify is treated as a breach of the authorisation conditions and can trigger suspension under Portaria 1.225/2024 and revocation under the Portaria 2.217/2025 template.
Planilha de Autorizações SPA/MF (13 May 2026)
Official register of authorised .bet.br operators
Player Rights
The Ministry of Finance maintains a live register of every legal entity holding a Despacho Autorizativo SPA/MF, updated as Despachos are published in the Diário Oficial da União. The 13 May 2026 cut lists approximately 85 administratively authorised entities; including operators running under judicial determination, the universe of active .bet.br brands sits at around 187. The register publishes the Portaria number, razão social, CNPJ, commercial brands and .bet.br domains for each entity.
Requirements
Validate every counterparty (affiliate, payment partner, B2B supplier) against the latest Planilha de Autorizações before going live
Confirm the exact .bet.br domain string against the register; any deviation is a marketing breach under Portaria SPA/MF 1.231/2024
Track Despachos in the Diário Oficial da União for new authorisations, material changes and revocations
Mirror the register internally with a weekly diff so compliance can spot revocations or brand additions
The register is the single source of truth. Third-party trackers can lag the official spreadsheet by several days, especially around Friday Despacho publications. Always confirm against gov.br/fazenda before contracting.
3
Theme 3
Player accounts & identity
Brazil ties every bettor to a single, biometrically verified identity tied to a Brazilian CPF and to a single payment account in the bettor's own name. Portaria SPA/MF 722/2024 sets out the technical mechanics of identity verification and the bettor-account architecture.
11 standards11 player-flagged
100%
player-flagged
Regulatory risks this theme addresses
Allowing duplicate or proxy accounts to bypass limits, prohibited-bettor rules and self-exclusion
Accepting deposits from a payment account that is not in the bettor's name
Letting biometric re-authentication lapse
Account opening, identity and integrity 11
Lei 14.790/2023 art. 8
Bettor identification and registration data
Player Rights
Article 8 requires full and accurate registration of every bettor before any wager is accepted. Mandatory fields include full name, date of birth, CPF, residential address, contact data and a payment account held in the bettor's own name.
Requirements
Capture all mandatory registration fields before activating the account
Reject registrations where the CPF or address cannot be validated
Refresh registration data periodically and on triggering events
Audit registration flows for compliance and bettor-experience quality each quarter
Lei 14.790/2023 art. 9
Single-account rule per brand
Player Rights
Article 9 limits each bettor to a single active account per authorised brand. Operators must reconcile registration data centrally to detect and close duplicates.
Requirements
Block account creation where a live account already exists for the same CPF and brand
Run periodic duplicate-detection sweeps using both CPF and biometric matching
Close duplicates promptly and migrate balances back to the original account
Brief customer-facing staff on the identity rules and the prohibited-bettor categories
Portaria SPA/MF 722/2024 art. 7
Facial biometric verification at onboarding
Player Rights
Portaria 722 requires facial-biometric verification with liveness detection at account opening, before the first deposit may be processed. The biometric template must be retained and used for ongoing re-authentication.
Requirements
Capture a live selfie with active or passive liveness on every account opening
Validate the biometric against the CPF holder's reference image (where available) or against a deduplication database
Block the first deposit until the biometric check passes
Retain identity-verification evidence for the full retention period
Portaria SPA/MF 722/2024 art. 6
Periodic biometric re-authentication
RG CriticalPlayer Rights
Portaria SPA/MF 722/2024 requires multifactor and biometric re-authentication of the bettor at defined intervals and after extended inactivity, as well as at registration-data changes and at cash-out events meeting risk-based thresholds. The cited art. 8 instead governs the 90-day post-authorisation technical certification report, so the obligation is mapped to the authentication provisions of the same Portaria (art. 6 area on identity verification / authentication controls).
Requirements
Trigger multifactor re-authentication on every seventh-day rolling window
Re-run liveness on cash-out or change of registration triggers
Log every authentication event for the regulator audit trail
Audit registration flows for compliance and bettor-experience quality each quarter
Portaria SPA/MF 1.231/2024 art. 31
CPF validity check against Receita Federal
Player Rights
Identity verification at account opening must include a real-time CPF validity and name-match check against Receita Federal data. Accounts opened with invalid, suspended or third-party CPFs must be refused or closed.
Requirements
Integrate a CPF-status check with Receita Federal at every account opening
Re-run the CPF check on a periodic basis (at least annually) and on any name-change event
Close accounts where the CPF becomes invalid or is transferred
Brief customer-facing staff on the identity rules and the prohibited-bettor categories
Portaria SPA/MF 722/2024 art. 35
Geolocation and anti-circumvention controls
Player RightsGame Design
The platform must detect and block VPN, remote-desktop, virtualisation and rootkit tools that mask bettor geolocation. Detection must occur and the bet must be refused before settlement.
Requirements
Run geolocation and anti-circumvention checks on every session and every bet
Refuse the bet (not merely flag it) when circumvention is detected
Log refusals with the technical evidence and retain for SPA/MF inspection
Retain identity-verification evidence for the full retention period
Lei 14.790/2023 art. 26
Prohibited bettors
RG CriticalPlayer Rights
Article 26 prohibits a series of categories from betting: minors under 18, persons declared judicially incapable, owners and qualifying staff of the operator, public officials with regulatory duties over the sector and persons listed on the centralised self-exclusion register. Operators must implement controls to detect and refuse prohibited bettors.
Requirements
Block account opening for any user under 18 years of age
Screen new and existing players against the prohibited-bettor categories
Refuse and refund any bet placed by a person subsequently identified as prohibited
Audit registration flows for compliance and bettor-experience quality each quarter
Lei 14.790/2023 art. 27
Athlete, coach and integrity-stakeholder bans
Player Rights
Article 27 prohibits athletes, coaches, referees and other integrity stakeholders from betting on competitions in which they participate or have privileged information. Operators must implement screening against confederations' lists.
Requirements
Screen registration and ongoing activity against athlete and integrity-stakeholder lists
Block bets on events where the bettor has a declared integrity-stakeholder relationship
Report attempted integrity-stakeholder bets to the relevant confederation and SPA/MF
Brief customer-facing staff on the identity rules and the prohibited-bettor categories
Portaria SPA/MF 722/2024 art. 22
Suspicious account detection
Player Rights
Article 22 requires the operator to implement procedures to identify suspicious accounts; patterns such as duplicate biometric matches across different CPFs, coordinated transaction patterns or shared devices. Suspicious accounts must be reviewed and, where confirmed, closed.
Requirements
Run biometric deduplication and device-fingerprint analysis routinely
Review suspicious accounts within a defined SLA and document the outcome
Close confirmed bad accounts and report patterns relevant to AML to compliance
Retain identity-verification evidence for the full retention period
Portaria SPA/MF 1.231/2024 art. 46
Bettor contract and terms of use
Player Rights
Operators must publish a bettor contract / terms of use in Portuguese covering registration, deposits and withdrawals, RG controls, complaints, bonuses and dispute resolution. Material changes require advance notice and an option to close the account without penalty.
Requirements
Publish the contract in plain Portuguese and link it from every bettor touchpoint
Notify bettors at least the regulator-required period before any material change
Allow free, no-penalty account closure on any material change
Audit registration flows for compliance and bettor-experience quality each quarter
Portaria SPA/MF 722/2024 art. 25
Bettor account ledger and balance integrity
Player Rights
Operators must maintain a bettor-account ledger that records every credit, debit, bet, win, bonus and adjustment. The ledger must reconcile to the bettor-funds account at all times and be available for SPA/MF inspection.
Requirements
Record every account movement in an immutable ledger
Reconcile bettor balances to segregated bettor funds daily
Provide ledger extracts to SPA/MF on demand within the regulatory deadline
Brief customer-facing staff on the identity rules and the prohibited-bettor categories
4
Theme 4
Responsible gambling & player protection
Portaria SPA/MF 1.231/2024 sets out the responsible-gambling regime: mandatory prudential limits on deposits and time, customer-interaction triggers, harm-marker monitoring and a duty to design every customer journey to discourage harmful play.
14 standards14 player-flagged
100%
player-flagged
Regulatory risks this theme addresses
Allowing a high-spend bettor to remain unattended past the customer-interaction threshold
Defaulting to no deposit limit at registration
Letting reality checks or session limits be silently dismissed
Player protection duties 14
Portaria SPA/MF 1.231/2024 art. 5
Mandatory responsible-gambling policy
RG Critical
Article 5 obliges every operator to adopt a formal responsible-gambling policy covering risk identification, monitoring, customer interaction, training, governance and reporting. The policy must be approved by the board, reviewed annually and published in summary form on the operator's website.
Requirements
Adopt a board-approved responsible-gambling policy before launch
Review the policy at least annually and after any material incident
Publish a plain-language summary in the bet.br portal footer
Retain bettor-interaction and limit-setting evidence for at least five years
Portaria SPA/MF 1.231/2024 art. 32
Prudential limits at registration
RG CriticalPlayer Rights
Article 9 requires operators to offer prudential limits on deposit value, loss value, time spent and session length at the moment of registration. Limits must be configurable by the bettor and must be effective in real time.
Requirements
Present prudential limit options during the registration flow
Enforce the chosen limits in real time across all channels
Block bets that would breach a limit, even partially
Benchmark intervention rates and outcomes against peer operators and the SPA/MF baseline
Portaria SPA/MF 1.231/2024 art. 35
Cooling-off when limits are increased
RG Critical
Increases to deposit, loss or time limits take effect only after a cooling-off period. Decreases take effect immediately. Operators must record the bettor's choice and the timing of each limit change.
Requirements
Apply a cooling-off period of at least the regulatory minimum to all limit increases
Apply limit reductions immediately on request
Log every limit change with timestamp and channel
Surface responsible-gambling metrics in board reporting at least quarterly
Portaria SPA/MF 1.231/2024 art. 9
Reality checks and session messaging
RG CriticalGame Design
Operators must deliver periodic reality-check messages displaying elapsed session time and net win or loss, with bettor acknowledgement required before continuing play, as part of the mandatory responsible-gaming educational and preventive measures.
Requirements
Display periodic reality-check messages showing elapsed session time
Display net win or loss during the session
Require bettor acknowledgement before continued play
Portaria SPA/MF 1.231/2024 art. 35
Customer-interaction triggers
RG Critical
Operators must monitor each bettor for harm markers (rapid stake escalation, chasing losses, prolonged sessions, deposit-decline patterns, age-of-account vs spend) and trigger a documented customer-interaction protocol when thresholds are reached.
Requirements
Implement a documented harm-marker model with auditable thresholds
Trigger a tiered intervention (message, restriction, contact) on each threshold breach
Log every intervention and outcome for inspection
Benchmark intervention rates and outcomes against peer operators and the SPA/MF baseline
Portaria SPA/MF 1.231/2024 art. 9
Educational campaigns against chasing losses
RG CriticalBonus & Ads
Operators must conduct educational campaigns warning bettors against chasing losses and must not deploy bonuses, free bets, or messaging that encourages a losing bettor to continue playing.
Requirements
Suppress targeted bonuses and messaging to bettors during loss streaks
Exclude in-session loss-chasing offers from the marketing engine
Document the marketing exclusion rules and audit them quarterly
Surface responsible-gambling metrics in board reporting at least quarterly
Portaria SPA/MF 1.231/2024 art. 32
Take-a-break and panic-button
RG CriticalPlayer Rights
Bettors must be able to suspend their account immediately (take-a-break) for periods between 24 hours and six months without contacting customer service. A one-click access path must be present in the bettor account.
Requirements
Implement a self-service take-a-break tool reachable in one click from the account home
Honour the suspension immediately and bar logins for the chosen period
Prevent marketing communications during the take-a-break window
Retain bettor-interaction and limit-setting evidence for at least five years
Portaria SPA/MF 1.231/2024 art. 20
Mandatory training of customer-facing staff
RG Critical
All customer-facing and risk staff must complete responsible-gambling training before going live and refresh it annually. Training records must be retained for SPA/MF inspection.
Requirements
Train customer-facing and risk staff before access is granted
Refresh training annually and on policy updates
Retain attendance and assessment records for at least five years
Benchmark intervention rates and outcomes against peer operators and the SPA/MF baseline
Portaria SPA/MF 1.231/2024 art. 22
Loss and win disclosures on the bettor portal
RG CriticalPlayer Rights
The bettor portal must provide each bettor with real-time, downloadable access to their deposits, withdrawals, stakes, winnings and net losses over rolling periods, in a machine-readable format.
Requirements
Expose a real-time spend and outcome dashboard in the bettor account
Offer a downloadable history covering at least the last 12 months
Show net position alongside gross stakes and wins, not in place of them
Surface responsible-gambling metrics in board reporting at least quarterly
Portaria SPA/MF 1.231/2024 art. 9
Educational campaigns and helpline referral
RG Critical
Operators must conduct educational campaigns on responsible gambling and prominently display the public helpline / problem-gambling support contact across bet.br touchpoints, including footer placement and customer-interaction messaging.
Requirements
Display public problem-gambling helpline in the footer of every bet.br page
Reference external problem-gambling support service in customer-interaction messaging
Conduct ongoing educational campaigns on responsible gambling
Portaria SPA/MF 1.231/2024 art. 27
Annual responsible-gambling report
RG Critical
Operators must file an annual responsible-gambling report with SPA/MF summarising harm-marker performance, intervention volumes, self-exclusion uptake and helpline referrals. The report must be retained for at least five years.
Requirements
Build an annual responsible-gambling report aligned to SPA/MF's template
File the report within the SPA/MF deadline (typically 31 March)
Retain underlying data and the report itself for at least five years
Benchmark intervention rates and outcomes against peer operators and the SPA/MF baseline
Instrução Normativa SPA/MF 22/2025
Block on Bolsa Família and BPC beneficiaries
RG CriticalPlayer Rights
Instrução Normativa SPA/MF nº 22 of 30 September 2025 sets the procedure operators must follow to prevent registration or use of betting systems by beneficiaries of the Bolsa Família Programme and the Benefício de Prestação Continuada (BPC). Operators must query the Bolsa Família and BPC base inside SIGAP at registration and every fifteen days for the entire active user base, and block any positive match.
Requirements
Query the Bolsa Família and BPC base inside SIGAP at every account opening before allowing the first deposit
Re-query the entire active user base at least every fifteen days and block any user newly identified as a beneficiary
Communicate the block to the user with a plain-language notice and return any pending balance
Document the query and matching procedure in the AML and RG manuals
Retain the query and block logs for at least five years
The instrument implements the cautionary order issued by Min. Luiz Fux in ADI 7.721/7.723 (13 November 2024) and the corresponding rule in Portaria 1.231/2024.
Instrução Normativa SPA/MF 24/2025
Extension of the Bolsa Família and BPC block implementation deadline
RG Critical
Instrução Normativa SPA/MF nº 24 of 29 October 2025 amends IN 22/2025 by extending the implementation deadline by thirty days. Operators that had not yet wired their systems to the SIGAP query for Bolsa Família and BPC beneficiaries received additional time to complete the integration, after representations that the API specification had only stabilised in mid-October.
Requirements
Treat the extended deadline as the final cut-off; SPA has signalled no further extension
Run a parallel manual screening procedure during the extension period
Document the integration testing and certify completion through SIGAP
Roll back any commercial campaign targeted at users whose beneficiary status is undergoing verification
The extension does not weaken the substantive duty; supervisory action under Portaria 1.225/2024 remains available after the new deadline.
STF ADI 7.721 / 7.723 (cautelar Min. Fux)
STF cautionary order requiring immediate block of welfare-funded betting
RG CriticalPlayer Rights
On 13 November 2024 Min. Luiz Fux, rapporteur of ADIs 7.721 (proposed by CNC) and 7.723 (proposed by Solidariedade), granted a partial cautelar determining the immediate application of measures preventing participation in fixed-odds betting with resources originating in social and welfare programmes such as Bolsa Família. The cautionary order remained in force throughout 2025 and the merit judgment was pending as of May 2026. The decision is the direct trigger for Portaria 1.231/2024 article 14, for IN SPA/MF 22/2025 and for the SISCOAF reporting practice on welfare-funded flows.
Requirements
Treat any user identified as a Bolsa Família or BPC beneficiary as blocked from depositing and betting
Reconcile the SPA SIGAP screening with internal AML monitoring of welfare-tagged inflows
Reflect the cautelar in the AML risk assessment and the RG manual
Track the merit judgment and adjust the procedure as soon as the STF rules
The cautelar is monocratic but actively enforced; an eventual confirmation by the plenary will extend its weight and may broaden the categories of restricted users.
5
Theme 5
Self-exclusion
Brazil operates a two-track self-exclusion regime: operator-specific exclusions inside a single bet.br brand and a centralised cross-operator self-exclusion register that binds every authorised operator. The cross-operator register is the equivalent of Spain's RGIAJ and is administered through SPA/MF.
10 standards10 player-flagged
100%
player-flagged
Regulatory risks this theme addresses
Failing to reconcile against the centralised register before opening or activating an account
Re-marketing to a self-excluded bettor when the exclusion expires
Mismatch between the operator's internal exclusion and the cross-operator register
Self-exclusion mechanics 10
Lei 14.790/2023 art. 9, parágrafo único
Statutory basis for self-exclusion
RG CriticalPlayer Rights
Article 9 of Lei 14.790/2023, in its parágrafo único, establishes the statutory obligation that operators make self-exclusion available to bettors and honour exclusions registered with other authorised operators. This is the legal anchor for the centralised cross-operator self-exclusion register subsequently implemented by SPA/MF.
Requirements
Offer self-exclusion as a free, accessible, self-service option
Honour exclusions registered with any other authorised operator from the moment they take effect
Treat the cross-operator register as authoritative
Retain self-exclusion records for at least five years from the end of the exclusion
Portaria SPA/MF 1.231/2024 art. 36
Operator-specific self-exclusion
RG Critical
Operator-specific (autoexclusão específica) self-exclusion blocks the bettor from the operator's platform only. The bettor can choose a fixed term or an indefinite term; reactivation requires an explicit request after a minimum reflection period.
Requirements
Provide a self-service flow for operator-specific self-exclusion in the bettor account
Honour the chosen term and reflect it across all brands the operator holds
Require an explicit, post-reflection-period request before reactivation
Audit self-exclusion register integrations annually and after any technical change
Portaria SPA/MF 2.579/2025 establishes the centralised self-exclusion register (autoexclusão centralizada). Once a CPF is listed, the bettor is blocked from every authorised operator in Brazil. Operators must consume the register in real time and refuse account opening or login for any listed CPF.
Requirements
Integrate the centralised self-exclusion register in real time
Block account opening and login for any CPF on the register
Suppress marketing and bonuses to listed CPFs even if the bettor previously consented
Brief marketing, CRM and customer-service teams on the absolute nature of self-exclusion
Portaria SPA/MF 1.231/2024 art. 34
Real-time check before each session
RG Critical
Every login and every bet acceptance must include a real-time check against the centralised register. Cached or stale data is not acceptable; the system must fail safe if the register is unreachable.
Requirements
Call the centralised register on every login and bet acceptance
Refuse the bet if the call fails and cannot be retried within a safe window
Log every check, success and failure, for SPA/MF inspection
Retain self-exclusion records for at least five years from the end of the exclusion
Portaria SPA/MF 1.231/2024 art. 35
Self-exclusion reactivation and reflection periods
RG Critical
Reactivation from a fixed-term self-exclusion requires an explicit request from the bettor after the term has elapsed plus a regulator-defined reflection period. Indefinite-term self-exclusion may only be lifted on a documented request with at least the same reflection period.
Requirements
Do not reactivate automatically; require a positive, post-period request
Apply the reflection period after the term ends before reactivation is processed
Document the reactivation request, identity check and reflection-period compliance
Audit self-exclusion register integrations annually and after any technical change
Portaria SPA/MF 1.231/2024 art. 12
Marketing suppression for self-excluded bettors
RG CriticalBonus & Ads
Operators must suppress all marketing, bonus offers, push notifications and email contact directed at self-excluded bettors for the duration of the exclusion, including by ceasing prohibited advertising directed to vulnerable persons.
Requirements
Treat the self-exclusion list as an absolute exclusion in the marketing engine
Suppress contact across email, SMS, push, in-app and affiliate channels
Maintain suppression even where the bettor later resets marketing consent
Brief marketing, CRM and customer-service teams on the absolute nature of self-exclusion
Portaria SPA/MF 2.579/2025
Mandatory prudential autolimits at registration
RG CriticalPlayer Rights
Portaria SPA/MF 2.579/2025 amended the RG rules to require operators to implement mandatory prudential autolimits on time and value at the moment of registration. Operators had 90 days from publication to adapt their registration flows.
Requirements
Enforce mandatory autolimits on time and value at registration, not only on request
Surface the autolimits prominently in the bettor account and allow downward adjustment
Document deployment in the change-management log within the 90-day deadline
Retain self-exclusion records for at least five years from the end of the exclusion
Effective from February 2026 after a 90-day adaptation window from publication on 7 November 2025. Bettors must be presented with mandatory limit options (value or number of bets per day, week or month), session-time blocks, pause periods and centralised or operator-specific self-exclusion at registration. Centralised self-exclusion is enforced cross-operator through the SPA/MF infrastructure; operator-level limits feed the SIGAP daily files. The portaria works alongside IN SPA/MF 31/2025 which sets the technical fields.
Portaria SPA/MF 1.231/2024 art. 38
Withdrawal of balances on self-exclusion
RG CriticalPlayer Rights
When a bettor self-excludes, the operator must return all available balance promptly via the registered payment account, net of any pending settled obligations. Pending wagers settle in the normal way; new wagers are refused.
Requirements
Process the return of balance promptly on self-exclusion, by Pix to the named account
Settle pending wagers in the normal cycle without offering new wagers
Document the balance return and retain the proof
Audit self-exclusion register integrations annually and after any technical change
Portaria SPA/MF 2.579/2025
Centralised self-exclusion register and mandatory prudential autolimits
RG CriticalPlayer Rights
Portaria SPA/MF nº 2.579 of 7 November 2025 amends Portaria 1.231/2024 and creates two parallel mechanisms. The first is a centralised self-exclusion register, operated by Serpro and integrated to SIGAP, which blocks an excluded user from every authorised operator simultaneously; operator-specific self-exclusion continues to coexist. The second is a mandatory prudential autolimit set at account opening, covering time spent, total stake, number of bets per period, session alerts and pause windows.
Requirements
Integrate with the Serpro centralised self-exclusion API and block any positively matched user within the deadlines fixed by IN 31/2025
Force a mandatory prudential autolimit setting at registration covering time, stake and session
Honour the bettor's request to lower or extend autolimits in real time and apply any increase only after a cooling-off period
Display autolimit status and remaining capacity on the account dashboard
Keep audit logs of self-exclusion and autolimit events for at least five years
The instrument is the single most significant 2025 expansion of player-protection duties; firms had 30 days to wire to the centralised register and 90 days to implement the autolimits.
Instrução Normativa SPA/MF 31/2025
Operational procedure for the centralised self-exclusion register
RG CriticalPlayer Rights
Instrução Normativa SPA/MF nº 31 of 7 November 2025 sets the operational procedure for the centralised self-exclusion register created by Portaria 2.579/2025. It defines the API contract with Serpro, the matching logic, the deadlines for inbound and outbound synchronisation, the user-facing communications and the audit-log retention rules.
Requirements
Implement the Serpro API in production within 30 days of the IN coming into force
Synchronise the centralised register at every login attempt and every new bet placement
Communicate the centralised-exclusion event to the affected user using the form set in the annex
Retain the synchronisation logs for at least five years and produce them to SPA on demand
Block re-registration attempts and integrate with the operator's KYC pipeline
The Serpro platform is the single source of truth for centralised exclusion; any deviation between the operator's local copy and the central register is treated as a compliance failure.
6
Theme 6
Advertising, marketing & affiliates
Lei 14.790 art. 22 sets the statutory advertising principles; Portaria SPA/MF 1.231/2024 fills them in, banning targeting of minors, restricting celebrities and athletes, requiring 18+ warnings and making operators jointly liable for affiliate and influencer content.
11 standards11 player-flagged
100%
player-flagged
Regulatory risks this theme addresses
Influencer or affiliate content that strays into the under-18 audience or implies easy winnings
Bonus advertising that does not surface key conditions
Sponsoring competitions or kit aimed at youth audiences
Marketing principles and channels 11
Lei 14.790/2023 art. 22
Statutory principles of betting advertising
Bonus & AdsAffiliate Rules
Article 22 sets the principles: social responsibility, protection of minors, transparency, prohibition of suggestions of easy enrichment, mandatory responsible-gambling messaging. Every advertising or marketing action by the operator or its affiliates is attributable to the operator.
Requirements
Embed the article 22 principles in the marketing approval workflow
Audit every campaign against the principles before going live
Hold affiliates to the same principles by contract
Audit affiliate and influencer compliance with the rules at least quarterly
Lei 14.790/2023 art. 23
18+ warning and responsible-gambling disclosure
Bonus & AdsRG Critical
Article 23 requires every commercial communication to display the 18+ restriction and a responsible-gambling warning. The warning must be visible and audible in audiovisual content.
Requirements
Include the 18+ symbol or wording on every creative asset
Include an audible and visible responsible-gambling message in audiovisual content
Apply the same rule to in-app and on-platform promotions
Brief media-buying and creative agencies on the prohibited-content and audience rules
Lei 14.790/2023 art. 24
Prohibited content and audiences
Bonus & Ads
Article 24 prohibits content directed at children or adolescents, the use of child or adolescent images and any element particularly appealing to under-18s. It also prohibits suggesting that betting is a means of easy enrichment, financial independence or social belonging.
Requirements
Reject creative that depicts under-18s or uses child-appealing iconography
Reject messaging that frames betting as a path to financial freedom
Train creative and approval staff on the prohibited-content list
Retain creative-approval evidence and the CONAR-aligned review trail for at least five years
Portaria SPA/MF 1.231/2024 art. 31
Celebrities, athletes and age-of-talent rule
Bonus & Ads
Talent featured in betting advertising must be at least 21 years old and must appear to be at least 21. Active athletes, coaches and referees may not endorse betting operators, and celebrities may not present betting as part of an everyday lifestyle.
Requirements
Verify the age of every featured talent and document the evidence
Refuse to engage active athletes, coaches or referees as endorsers
Avoid lifestyle framing that normalises constant betting
Audit affiliate and influencer compliance with the rules at least quarterly
Portaria SPA/MF 1.231/2024 art. 35
Influencer and affiliate liability
Affiliate RulesBonus & Ads
Operators are jointly and severally liable for advertising and promotional conduct carried out by influencers, affiliates and other third parties acting in their commercial interest. The Portaria defines affiliates broadly to capture any third party compensated by reference to traffic, registrations or revenue generated for the operator.
Requirements
Operator bears joint and several liability for influencer and affiliate advertising
Broad definition of affiliate captures any traffic/registration/revenue-based compensation
Operator must monitor and control third-party marketing conduct
Portaria SPA/MF 1.231/2024 art. 30
Bonus, free-bet and welcome-offer rules
Bonus & Ads
Promotional bonuses, free bets and welcome offers must be presented with complete and prominent terms (wagering requirements, expiry, eligibility and withdrawal conditions). Advertising may not obscure these conditions and the grant of a bonus may not be conditioned on the bettor's acceptance of marketing communications.
Requirements
Surface wagering, expiry and withdrawal conditions alongside the headline offer
Do not gate bonuses on broader marketing consent
Apply the same disclosure standard to influencer and affiliate posts
Retain creative-approval evidence and the CONAR-aligned review trail for at least five years
Portaria SPA/MF 1.231/2024 art. 12
Time-of-day and audience restrictions
Bonus & Ads
Betting advertising on broadcast and audiovisual media is restricted from programming targeted at minors and within scheduling windows defined by the regulator. Advertising on platforms with a predominantly under-18 audience is prohibited.
Requirements
Restrict broadcast placements to compliant scheduling windows
Exclude platforms with a predominantly under-18 audience from the media plan
Document the audience composition of each platform booked
Audit affiliate and influencer compliance with the rules at least quarterly
Portaria SPA/MF 1.231/2024 art. 30
Youth sponsorship and category prohibitions
Bonus & Ads
Operators may not sponsor children's or adolescents' teams, junior categories, or events directed at minors. Sponsorship of senior competitions remains subject to the responsible-gambling and advertising principles set out elsewhere in the Portaria.
Requirements
Refuse sponsorship of any junior or youth category or kit
Review existing senior-team sponsorships against article 22 each renewal
Document the age-category screening of every sponsorship
Brief media-buying and creative agencies on the prohibited-content and audience rules
Portaria SPA/MF 1.231/2024 art. 54
Brand-protection against use by unauthorised sites
Affiliate Rules
Authorised operators must monitor and act against unauthorised use of their brand by illegal sites, including misleading imitations and affiliate links that direct to non-bet.br destinations.
Requirements
Monitor brand abuse and impersonation across the open web
Send take-down requests to hosts and registries; cooperate with SPA/MF and ANATEL on blocking
Cut affiliates that direct traffic to non-authorised sites
Retain creative-approval evidence and the CONAR-aligned review trail for at least five years
Portaria SPA/MF 1.231/2024 art. 12
Mandatory responsible-gambling messaging in advertising
Bonus & AdsRG Critical
Every betting commercial communication must include a responsible-gambling message in clear language. The message must be displayed for a regulator-defined minimum duration in audiovisual content and be legible in static formats.
Requirements
Include responsible-gambling warning message in every betting advertisement
Use clear and accessible language
Meet minimum display duration in audiovisual content
Ensure legibility in static advertising formats
Anexo X CONAR
Self-regulatory advertising code (Anexo X)
Bonus & Ads
The Brazilian advertising self-regulatory body CONAR adopted Anexo X to its code in 2023 specifically for betting. It mirrors and complements Lei 14.790 and the Portarias and is the basis for CONAR's complaint-driven enforcement.
Requirements
Align creative approval with CONAR Anexo X in addition to statutory rules
Treat CONAR rulings as a binding self-regulatory layer on top of SPA/MF rules
Brief agencies and influencers on Anexo X content restrictions
Brief media-buying and creative agencies on the prohibited-content and audience rules
Anexo X was last updated in 2024 to align with the Portaria pipeline.
7
Theme 7
Technical standards & system security
Portaria SPA/MF 722/2024 is the central technical rulebook: it sets data-localisation, the mandatory bet.br domain, ISO 27001-certified data centres, multifactor authentication, fraud detection, audit-log requirements and the SIGAP regulatory data feed.
11 standards8 player-flagged
73%
player-flagged
Regulatory risks this theme addresses
Hosting data outside Brazil without the required international cooperation conditions
Operating without the bet.br domain or without ISO 27001 certification
Failing to detect circumvention tooling or to feed SIGAP correctly
System architecture and security 11
Portaria SPA/MF 1.231/2024 art. 20 §1
bet.br domain mandate
Player Rights
Article 4 requires every electronic channel offering authorised betting in Brazil to use a domain under the .bet.br second-level domain. The use of .com, .com.br or any other domain for the authorised activity is prohibited.
Requirements
Operate under a .bet.br domain exclusively for the authorised channels
Redirect legacy domains to the .bet.br destination during the authorisation period
Coordinate with Registro.br on the .bet.br registration before launch
Document the control in the information-security policy and audit annually
Domain registration runs through NIC.br (registro.br) after SPA/MF issues the authorisation notification. DNSSEC is mandatory. Operators have 5 days from registration to notify SIGAP. Each authorised brand maps to one .bet.br second-level label; disputes between operators over the same label go to SACI-Adm. Operating from .com, .net or any other TLD is grounds for SPA/MF sanctions and Anatel blocking. The 1 October 2024 transitional grace expired with the start of administrative authorisation operations on 1 January 2025.
Portaria SPA/MF 722/2024 art. 4
Data localisation in Brazil
Player Rights
The betting system and bettor data must be hosted in data centres located in Brazil. Hosting outside Brazil is exceptionally permitted only in countries with bilateral civil and criminal cooperation treaties with Brazil and only where LGPD obligations are observed.
Requirements
Host the production betting system and bettor data in Brazilian data centres
Evidence any cross-border replication against the cooperation-treaty exception
Demonstrate LGPD compliance for any cross-border transfer
Test the control as part of the annual penetration-testing programme
Portaria SPA/MF 722/2024 art. 16
ISO 27001 certification of the data centre
The data centre or centres hosting the betting system must hold a current ISO 27001 certification. The operator must monitor the certification status and act on any lapse.
Requirements
Contract only with data centres holding current ISO 27001 certification
Monitor the certification status and prepare a contingency plan for any lapse
Retain the certificate and audit report for SPA/MF inspection
Retain evidence of operation of the control for at least five years
Portaria SPA/MF 722/2024 art. 18
Physical and logical access controls
Article 18 sets minimum physical and logical access controls: dual-zone physical protection, role-based logical access, strong authentication for administrators, segregation of duties for security and operations roles.
Requirements
Implement role-based access with least privilege for all production access
Require strong (multifactor, hardware-token-class) authentication for administrators
Segregate security from operations and audit on a quarterly basis
Document the control in the information-security policy and audit annually
Portaria SPA/MF 722/2024 art. 20
Encryption of data at rest and in transit
All bettor data, transactional records and audit logs must be encrypted at rest and in transit. Encryption keys must be managed in a hardware security module or equivalent.
Requirements
Encrypt all bettor data at rest and in transit using recognised algorithms
Manage keys in an HSM or equivalent and rotate per industry standard
Document the encryption architecture for SPA/MF inspection
Test the control as part of the annual penetration-testing programme
Portaria SPA/MF 722/2024 art. 28
Audit log of every bet and account event
Player Rights
Every bet placed, every account event and every administrator action must be recorded in an immutable, time-synchronised audit log. The log must be retained for at least five years and made available to SPA/MF on demand.
Requirements
Capture every bet, account and admin event in an immutable log
Time-synchronise all log sources against an authoritative source
Retain logs for at least five years and provide on regulator request
Retain evidence of operation of the control for at least five years
Portaria SPA/MF 722/2024 art. 30
SIGAP regulatory data feed
Player Rights
Operators must feed the SIGAP (Sistema de Gestão de Apostas) regulatory data system in near real time with bet, account and integrity data. The feed must meet SPA/MF technical specifications and be available 24/7.
Requirements
Implement the SIGAP feed in accordance with the SPA/MF technical specification
Monitor feed availability and remediate any interruption promptly
Reconcile SIGAP submissions to the bettor ledger daily
Document the control in the information-security policy and audit annually
Operators transmit three daily files (operator aggregate, sports bets per bettor, online-game bets per bettor) within 6 hours of the start of the day following the reference day. A fourth file with legal obligations is monthly. Files use the layout in the SIGAP Manual de Envio e Validação dos Dados (rev. 03, gov.br/fazenda). Failed validations must be re-sent within the SLA or the operator is treated as in default for that calendar day, which feeds the supervisory risk score under Portaria SPA/MF 1.225/2024.
Portaria SPA/MF 722/2024 art. 32
Change-management for material system changes
Game Design
Material changes to the betting system, RNG, payment integration or RG controls require a documented change-management process and re-certification by an accredited laboratory before deployment.
Requirements
Operate a documented change-management process for the production environment
Re-certify material changes through an accredited laboratory before deployment
Notify SPA/MF of changes that affect bettor experience or controls
Test the control as part of the annual penetration-testing programme
Portaria SPA/MF 722/2024 art. 40
Incident response and notification
Player Rights
Information-security incidents that affect bettor data, bettor funds or system integrity must be notified to SPA/MF promptly with a documented incident report. ANPD notification under LGPD remains required in parallel.
Requirements
Operate a documented incident-response capability with 24/7 escalation
Notify SPA/MF promptly and follow up with a written incident report
Notify ANPD under LGPD where personal data is implicated
Retain evidence of operation of the control for at least five years
Lei 13.709/2018
LGPD overlay on bettor data processing
Player Rights
The Lei Geral de Proteção de Dados applies in full to bettor data. Lawful bases, minimisation, retention, data-subject rights, breach notification and international-transfer rules apply alongside Portaria 722.
Requirements
Map all bettor data flows and identify lawful bases
Operationalise data-subject rights, including access, correction and erasure within statutory deadlines
Apply ANPD breach-notification timelines in parallel with the SPA/MF report
Document the control in the information-security policy and audit annually
SIGAP daily file submission cadence
SIGAP daily file submission cadence and SLA
Player Rights
Under Portaria SPA/MF 722/2024 art. 30 and the SIGAP Manual de Envio e Validação dos Dados (rev. 03), each authorised operator must transmit three daily files (operator aggregate, sports bets per bettor, online-game bets per bettor) within six hours of the start of the day following the reference day, plus a monthly legal-obligations file. SIGAP is operated by Serpro for SPA/MF.
Requirements
Schedule the SIGAP submission job so the three daily files clear validation before 06:00 BRT of the day following the reference day
Monitor SIGAP validation responses and re-submit corrected files within the SLA
Reconcile each daily file against the operator's internal ledger before transmission to prevent rejections that count as missed filings
Retain SIGAP receipts and validation reports for the full record-keeping period under Portaria SPA/MF 1.143/2024 art. 22
Repeated SIGAP rejections feed the supervisory risk score under Portaria SPA/MF 1.225/2024 and can trigger an inspection. The SIGAP Manual is the binding technical specification; updates are published on gov.br/fazenda without notice and must be tracked weekly.
8
Theme 8
Game certification & RNG
Portaria Normativa SPA/MF 300/2024 sets the accreditation regime for testing laboratories; Portaria SPA/MF 1.207/2024 sets the technical standard for online games, RNG and live-game studios; minimum RTP, change-control and re-certification deadlines all apply.
15 standards15 player-flagged
100%
player-flagged
Regulatory risks this theme addresses
Launching a game variant or a live studio that has not been certified by an SPA/MF-recognised lab
Operating an RNG that adjusts RTP based on prior payouts
Falling below the 85% minimum RTP floor
Certification and game standards 15
Portaria Normativa SPA/MF 300/2024
Accreditation of testing laboratories
Game Design
Portaria Normativa 300 of 23 February 2024 sets the procedure for recognising the operational capacity of certification laboratories for betting systems, live game studios and online games. Only labs recognised by SPA/MF may issue certifications used in the authorisation regime.
Requirements
Engage only laboratories listed by SPA/MF as recognised
Verify the lab's scope of recognition before commissioning a certification
Retain the SPA/MF recognition act with each certification report
Reconcile the live game configuration to the certified configuration at every release
Five certifying entities have been recognised by SPA/MF as of May 2026: eCogra Limited (Portaria SPA/MF 588 of 11 April 2024), BMM Spain Testlabs (Portaria SPA/MF 603 of 15 April 2024), Gaming Associates Europe Ltd (Portaria SPA/MF 749 of 9 May 2024), Quinel Limited (Portaria SPA/MF 1.132 of 9 July 2024) and Trisigma B.V. (Portaria SPA/MF 1.775 of 8 November 2024). Gaming Laboratories International (GLI) is also commonly reported as recognised; operators should confirm the latest list at the SPA/MF Entidades Certificadoras page before contracting. Each recognition act sets the scope (platform, RNG, live studio, geolocation, SIGAP integration) and the renewal triggers.
Portaria SPA/MF 1.207/2024 art. 5
Game certification scope
Game Design
Every online game, live studio, RNG instance and material variant must be certified by an accredited laboratory, with re-certification required at each material change.
Requirements
Certify every online game, every live studio and every RNG instance before launch
Re-certify on every material change (RTP, rules, paytable, RNG)
Maintain a current certification register accessible to SPA/MF
Re-test on every material RNG, paytable or feature change
Portaria SPA/MF 1.207/2024 Anexo I
Minimum 85% RTP
Game DesignPlayer Rights
Each game must offer a theoretical RTP of at least 85% over its expected useful life. The theoretical RTP must be published or made available to bettors on request.
Requirements
Tune game maths to deliver at least 85% theoretical RTP
Document the RTP analysis in the certification report
Surface the theoretical RTP in the bettor account on request
Retain the certification report and supporting evidence for the life of the game
Portaria SPA/MF 1.207/2024 art. 11
RNG independence from past results
Game Design
An RNG must not adjust its theoretical RTP based on prior payouts. Outcome generation must be statistically independent of the player, the time of day and the session history.
Requirements
Demonstrate RNG independence from past results in the certification report
Forbid any dynamic RTP-adjustment feature in the game configuration
Re-certify after any RNG library or seed-source change
Reconcile the live game configuration to the certified configuration at every release
Portaria SPA/MF 1.207/2024 art. 13
Separate evaluation of multiple RNGs
Game Design
Where more than one RNG is used to determine different outcomes in the same game, each RNG must be evaluated separately. Each implementation of a generic RNG inside a game must be evaluated separately.
Requirements
List every RNG instance in the certification scope
Evaluate each implementation, not only the RNG library
Re-test on every implementation change
Re-test on every material RNG, paytable or feature change
Portaria SPA/MF 1.207/2024 art. 18
Live game studio certification
Game Design
Live game studios (casino studios delivering live dealer content to Brazilian players) must be certified for room layout, dealer training, equipment, camera positioning and outcome capture. Studios outside Brazil must satisfy data-localisation conditions for the bettor data feed.
Requirements
Certify live studios end-to-end before serving Brazilian bettors
Document dealer training, equipment calibration and outcome-capture controls
Confirm the bettor-data feed meets Portaria 722 data-localisation rules
Retain the certification report and supporting evidence for the life of the game
Portaria SPA/MF 1.207/2024 art. 21
Game logs and integrity reconstruction
Game DesignPlayer Rights
Every game session must be logged in sufficient detail to reconstruct the bet, the RNG outputs and the outcome. Logs must be retained for at least five years and accessible to SPA/MF.
Requirements
Log every game session in reconstructable detail
Retain logs for at least five years
Provide logs to SPA/MF or the certification lab on request
Reconcile the live game configuration to the certified configuration at every release
Instrução Normativa SPA/MF 3/2025
Updated technical requirements for online games
Game DesignRG Critical
Instrução Normativa 3 of 2025 updated and clarified technical requirements for online games, including stake displays, spin durations and the implementation of in-game responsible-gambling tools.
Requirements
Apply the IN 3/2025 updates to all certified games on or before the implementation deadline
Re-test affected games through the certification lab
Document the upgrade in the change-management log
Re-test on every material RNG, paytable or feature change
Portaria SPA/MF 1.207/2024 art. 25
Stake, autoplay and time-based controls
Game DesignRG Critical
Online slot-style games must surface clear stake displays, allow the bettor to set a maximum-loss stop and provide visible session timers. Autoplay must be configurable to stop on configurable triggers.
Requirements
Surface stake, time and net-position information in every game UI
Offer a configurable autoplay stop and enforce it client-side and server-side
Default autoplay to off where the regulator requires explicit opt-in
Retain the certification report and supporting evidence for the life of the game
Portaria SPA/MF 1.207/2024 art. 30
Bonus-round and feature integrity
Game Design
Article 30 requires bonus rounds, free-spin features and other RTP-affecting mechanics to be evaluated as part of the certification. Any change to feature mathematics is a material change requiring re-certification.
Requirements
Include bonus and feature mathematics in the certification scope
Re-certify any change to feature behaviour or contribution to RTP
Surface the all-in RTP (base plus features) in the certification report
Reconcile the live game configuration to the certified configuration at every release
Portaria SPA/MF 1.207/2024 art. 28
Time-source and clock-skew integrity
Game Design
Every game and platform component must synchronise to an authoritative time source. Clock skew must be monitored; any skew beyond the regulator-set tolerance must trigger an incident.
Requirements
Synchronise platform components to an authoritative NTP source
Monitor clock skew and trigger an incident on tolerance breach
Document the time-source architecture in the certification report
Re-test on every material RNG, paytable or feature change
Instrução Normativa SPA/MF 3/2025
Standardised submission of certifications via SIGAP
Game Design
Instrução Normativa SPA/MF nº 3 of 10 January 2025 standardises how authorised operators submit technical certifications through SIGAP. Provisionally authorised operators had until 30 January 2025 to upload certificates for the Betting System, the Sportsbook server, the Remote Game Server and the integration layer. Definitively authorised operators must thereafter file a monthly refresh of the General Index Document and the Online Games Index Document whenever any certificate is updated.
Requirements
Submit Sistema de Apostas, Sportsbook, RGS and integration certificates through SIGAP within the fixed window
File monthly refreshes of the General Index Document and the Online Games Index Document whenever a certificate changes
Use only certifiers homologated by SPA/MF under Portaria Normativa 300/2024
Reconcile every game and platform component listed in the Index against the live production environment
Failure to submit the certificate set within 60 days triggers a 90-day suspension and, on persistence, definitive revocation of the authorisation.
Portaria SPA/MF 1.082/2025
Homologation of Lean Lab Company (RiskCherry) as certifying entity
Game Design
Portaria SPA/MF nº 1.082 of 16 May 2025 homologates Lean Lab Company Limited, trading as RiskCherry, as a certifying entity for fixed-odds betting systems, online game platforms and live-game studios, under the requirements set by Portaria Normativa SPA/MF nº 300/2024. The instrument is part of the rolling 2025-2026 homologation pipeline that progressively expanded the panel of accredited certifiers beyond GLI, BMM and eCOGRA.
Requirements
Verify the certifier's homologation status in the SPA panel before contracting
Match the scope of the certifier's homologation against the components requiring certification
Retain the certifier engagement letter and homologation reference in the compliance file
Notify SPA of any change of certifier within the deadlines fixed by IN 35/2025
Operators are responsible for ensuring that every component of the platform is covered by a homologated certifier; the scope of accreditation is published in the SPA panel.
Portaria SPA/MF 1.453/2025
Homologation of BMM North America as certifying entity
Game Design
Portaria SPA/MF nº 1.453 of 3 July 2025 homologates BMM North America Inc. as a certifying entity for fixed-odds betting systems, online game platforms and live-game studios in Brazil. BMM joins the panel of accredited certifiers and is permitted to issue the technical certifications required by Portaria 1.207/2024 and Instrução Normativa 3/2025.
Requirements
Confirm BMM's accreditation scope against the components being certified
Use only the homologated legal entity (BMM North America Inc.) in the SIGAP submission
Coordinate with BMM on the integration testing that closes the certification cycle
Refresh certifier-engagement documentation within the Index Document monthly refresh
Multiple certifier homologations across 2025 (RiskCherry, BMM, GLI, eCOGRA, others) addressed the lab-capacity bottleneck that delayed many provisional operators during early 2025.
Recognised certifying entities (SPA/MF)
Recognised certifying entities under Portaria SPA/MF 300/2024
Game Design
As of May 2026 the SPA/MF has issued recognition Despachos to a small set of certifying entities: eCogra Limited (Portaria 588/2024), BMM Spain Testlabs (Portaria 603/2024), Gaming Associates Europe Ltd (Portaria 749/2024), Quinel Limited (Portaria 1.132/2024) and Trisigma B.V. (Portaria 1.775/2024). Gaming Laboratories International (GLI) is also commonly reported as recognised. The SPA/MF maintains the live list on its Entidades Certificadoras page.
Requirements
Engage only entities listed on the SPA/MF Entidades Certificadoras page for any platform, RNG, live-studio or geolocation certification
Confirm the scope of each recognition Despacho - not every entity is recognised for every product line
Track new recognition Despachos in the Diário Oficial da União; the list expands as SPA/MF processes applications
Keep certificates current; material system changes trigger a re-certification obligation under Portaria SPA/MF 722/2024 art. 32
Certificates from non-recognised entities are not accepted by SPA/MF and will block authorisation or trigger sanctions. Verify the recognition Despacho number on the SPA/MF page before contracting; private databases lag.
9
Theme 9
Payments: Pix, deposits & withdrawals
Portarias SPA/MF 615/2024 and 1.231/2024 set the payment perimeter: Pix-led, named-account matching, no credit cards, no cash, no boleto and no crypto. Every flow runs through Brazilian-licensed payment institutions and is identified by the bettor's CPF.
13 standards11 player-flagged
85%
player-flagged
Regulatory risks this theme addresses
Accepting a deposit from a payment account whose CPF does not match the bettor's CPF
Permitting credit-card or crypto top-ups, whether directly or via a wallet intermediary
Failing to identify the originating institution and CPF on every flow
Payment perimeter and rails 13
Portaria Normativa SPA/MF 615/2024 art. 3
Authorised payment instruments
Player Rights
Article 3 limits payment instruments to Pix, TED, debit or pre-paid card and book transfer (where both accounts are in the same institution). Every other instrument is prohibited.
Requirements
Restrict deposit and withdrawal options to Pix, TED, debit/pre-paid card and book transfer
Remove every other instrument from the cashier
Block third-party wallets that aggregate prohibited instruments
Reconcile payment events to the bettor ledger and to bank statements daily
Portaria Normativa SPA/MF 615/2024 art. 3 §2
Prohibition of credit cards, cash, boleto and crypto for betting transactions
Player Rights
Article 3 §2 of Portaria Normativa SPA/MF 615/2024 expressly prohibits the use of cash, boleto bancário, credit cards, any post-paid payment instrument and crypto-assets (including virtual assets covered by Lei 14.478/2022) as channels for deposits or withdrawals between bettors and licensed operators.
Requirements
Refuse credit-card BIN ranges at the cashier
Refuse any deposit traced to a crypto-asset rail or a stablecoin off-ramp
Refuse cash and boleto deposits even at affiliated retail points
Document the payments perimeter in the AML and bettor-funds policies
Portaria SPA/MF 1.231/2024 art. 38
Named-account matching (CPF integrity)
Player Rights
Deposit and withdrawal accounts must be held in the bettor's own name; the CPF of the originating or receiving account must match the bettor's CPF. Third-party deposits are prohibited.
Requirements
Enforce CPF-match on every deposit and withdrawal
Refuse any flow originating from or directed to a third-party CPF
Reconcile mismatches into a hold queue and require evidence before processing
Audit payment-service-provider relationships at least annually
Portaria SPA/MF 1.231/2024 art. 61
Use of Banco Central-authorised institutions only
Player Rights
Operator transactional accounts and bettor counterparts must be held in financial or payment institutions authorised by the Banco Central do Brasil. Unlicensed intermediaries may not interpose themselves in the bettor flow.
Requirements
Maintain operator transactional accounts at BCB-authorised institutions
Refuse counterpart flows from unlicensed PSPs or aggregators
Document the BCB licence status of every counterparty in the payment chain
Reconcile payment events to the bettor ledger and to bank statements daily
Portaria SPA/MF 1.231/2024 art. 62
Withdrawal SLA and free withdrawals
Player Rights
Withdrawals to the bettor's named account must be processed promptly within the regulator-set service level. The bettor must be entitled to at least one free withdrawal per period and must not be charged fees that effectively block low-value withdrawals.
Requirements
Process withdrawals within the regulatory SLA, ideally same-day via Pix
Honour the free-withdrawal allowance and surface it in the bettor account
Justify any fee with documented cost and ensure it does not block small withdrawals
Document the payments perimeter in the AML and bettor-funds policies
Portaria SPA/MF 1.231/2024 art. 64
Bolsa Família and social-benefit account ban
RG CriticalPlayer Rights
Operators must block deposits originating from accounts that receive social-benefit programmes (notably Bolsa Família) where the regulator publishes the blocked-account markers. The aim is to keep social-benefit cash out of the betting flow.
Requirements
Implement BCB and regulator-published markers to detect social-benefit accounts
Refuse deposits from accounts flagged as social-benefit
Maintain a documented detection and audit process
Audit payment-service-provider relationships at least annually
Portaria SPA/MF 1.231/2024 art. 66
Bettor-fund segregation
Player Rights
Bettor funds must be segregated from operator working capital, held in an identified account with a BCB-authorised institution and reconciled daily to the bettor ledger.
Requirements
Hold bettor funds in a segregated identified account
Reconcile bettor balances daily to the segregated account
Document the segregation arrangement in the authorisation file
Reconcile payment events to the bettor ledger and to bank statements daily
Portaria SPA/MF 1.231/2024 art. 68
Pix originator and receiver data
Player Rights
Every Pix transaction in the bettor flow must carry the originator CPF and the receiver CPF on the SPB message. Operators must reject or hold transactions where the data is missing or inconsistent.
Requirements
Validate Pix message metadata for originator and receiver CPF on each flow
Reject or hold transactions with missing or inconsistent CPF data
Log validations and rejections for inspection
Document the payments perimeter in the AML and bettor-funds policies
Portaria SPA/MF 1.231/2024 art. 70
Deposit and withdrawal limits
RG CriticalPlayer Rights
Operators must implement maximum-deposit and maximum-withdrawal limits per period, configurable by the bettor inside the responsible-gambling controls. Default limits, where the bettor has not configured a value, follow the regulator's safe defaults.
Requirements
Implement maximum-deposit and maximum-withdrawal limits per period
Apply the regulator's safe defaults at registration
Enforce limits in real time and on every payment channel
Audit payment-service-provider relationships at least annually
Portaria SPA/MF 1.231/2024 art. 72
Settlement of pending bets and account closure
Player Rights
On account closure, the operator must settle pending wagers in the normal cycle, refund any unutilised bonus subject to terms, and return the available balance via Pix to the bettor's named account within the regulatory deadline.
Requirements
Settle pending wagers in the normal cycle on account closure
Return the available balance via Pix to the named account within the deadline
Document the closure flow for SPA/MF inspection
Reconcile payment events to the bettor ledger and to bank statements daily
Portaria SPA/MF 566/2025
Duty of banks and payment institutions to refuse accounts of illegal betting operators
Player Rights
Portaria SPA/MF nº 566 of 20 March 2025 operationalises article 21 of Law 14.790/2023 by setting the procedures that financial institutions, payment institutions and payment arrangement instituters must follow when SPA/MF formally notifies them that an operator is unauthorised. The institutions cannot keep transactional accounts of illegal operators and cannot execute deposit or prize-payment operations on their behalf.
Requirements
Close or refuse to open transactional accounts of operators identified by SPA/MF as illegal once notified
Communicate to SPA within 24 hours any suspected case of unauthorised fixed-odds operation
Document the screening procedure and retain evidence for five years
Apply restrictive measures across all linked PSPs, sub-acquirers and payment arrangements
Failure to act triggers supervisory and sanctioning proceedings and, under LC 224/2025, joint and several liability for the taxes owed by the illegal operator.
Resolução BCB 506/2025
BCB tightening of Pix controls applicable to betting operators
Resolução BCB nº 506 of 26 September 2025 reinforces the security and operational requirements applicable to Pix participants when they interact with betting operators. It refines the obligations on monitoring of atypical flows, mandatory blocking of accounts identified as belonging to unauthorised operators and information sharing with SPA under Portaria 566/2025.
Requirements
Tighten transaction-monitoring rules on Pix flows to and from accounts identified by SPA as unauthorised
Block instant-payment movements involving operators on the SPA Módulo de Impedidos list
Share fraud and unauthorised-operator markers across the Pix ecosystem within the BCB timetable
Reconcile the rules with the Resolução BCB nº 569/2026 fraud-marker scheme
The Resolução is the Pix-specific complement to Portaria SPA/MF 566/2025 and to the LC 224/2025 joint-liability rule.
Resolução BCB 561/2026
Dedicated transaction classification code 34045 for betting
Resolução BCB nº 561 of 2026, published in early May 2026, classifies online betting transactions under the dedicated code 34045 in the BCB taxonomy. Acquirers and payment institutions must use this code from 1 October 2026, enabling more accurate tracking of betting flows and improving the data set used by the BCB and the Receita Federal in supervision and tax enforcement.
Requirements
Reconfigure routing tables to apply code 34045 to all transactions originating from or directed to authorised betting operators
Coordinate with sub-acquirers and PSPs to ensure consistent code adoption from 1 October 2026
Reconcile the code with the COSIF chart of accounts and the SCR submission
Document the migration in the operational risk file
Code 34045 is the first explicit BCB-level taxonomy for online betting and feeds the BCB-SPA cooperation work, the BCB-RFB tax-enforcement track and the foreign-exchange monitoring of international betting flows.
10
Theme 10
AML / CFT
Brazilian betting operators are designated obliged entities under Lei 9.613/1998 and Portaria SPA/MF 1.143/2024. They must run a risk-based AML programme, screen against PEPs and sanctions lists, and file suspicious-activity reports to COAF through the SISCOAF system.
13 standards
0%
player-flagged
Regulatory risks this theme addresses
Failing to detect a structured pattern of deposits below the reporting threshold
Tipping off a bettor about a SISCOAF communication
Inadequate enhanced due diligence on high-spend or PEP bettors
AML programme 13
Lei 9.613/1998
Brazilian anti-money-laundering statute
Law 9.613 of 3 March 1998 (as amended by Lei 12.683/2012) is Brazil's anti-money-laundering statute. It defines money-laundering offences, designates obliged entities, sets reporting duties to COAF and underpins the SPA/MF AML rules.
Requirements
Build the AML programme on Lei 9.613 obligations, not only on Portaria 1.143
Treat the betting operator as a designated obliged entity (APNFD)
Apply the Lei 9.613 criminal offences as the bright-line conduct rules
Test the control through periodic internal audit and external assurance
Portaria SPA/MF 1.143/2024 art. 5
Risk-based AML / CFT programme
Portaria SPA/MF 1.143/2024 art. 5 requires operators to implement a documented, risk-based AML/CFT programme (PLD/FTP) covering risk assessment, customer due diligence, transaction monitoring, enhanced due diligence, training, governance and reporting, formally approved at board level.
Requirements
Adopt a written, risk-based AML/CFT programme covering the article 4 elements
Document the risk assessment and review it at least annually
Obtain board approval and document the approval cycle
Train relevant staff on the control on hire and annually thereafter
Portaria SPA/MF 1.143/2024 art. 16
Bettor risk classification (qualificação do apostador)
Operators must classify bettors into risk categories using registration data and transactional behaviour, with enhanced due diligence applied to higher-risk profiles.
Requirements
Classify all bettors into AML/CFT risk categories
Base classification on registration data and transactional behaviour
Apply enhanced due diligence to higher-risk bettors
Maintain qualification on an ongoing basis
Portaria SPA/MF 1.143/2024 art. 22
Politically Exposed Person screening
Operators must screen bettors against PEP lists at onboarding and on an ongoing basis. PEP status applies to the bettor, family up to the second degree and close associates and requires enhanced due diligence.
Requirements
Screen bettors against PEP lists at onboarding
Maintain ongoing PEP monitoring
Extend PEP status to family up to second degree and close associates
Apply enhanced due diligence to PEP-classified accounts
Lei 13.810/2019 art. 11
Sanctions screening
Bettors must be screened against UN, OFAC and Brazilian sanctions lists (Lei 13.810/2019) at onboarding and on an ongoing basis. Hits must be escalated to compliance and the account frozen pending review.
Operators must monitor bettor transactions for suspicious patterns (structuring, large in-out flows, third-party indicators, integrity-event correlations) and escalate alerts for review.
Requirements
Operate a documented transaction-monitoring engine with calibrated scenarios
Review alerts within the SLA defined by the AML programme
Retain alert closures, escalations and SAR rationales
Document the control in the AML manual and review at least annually
Portaria SPA/MF 1.143/2024 art. 19
SISCOAF reporting to COAF
Suspicious activity must be reported to COAF through SISCOAF within the regulatory deadline (24 hours from suspicion in most cases). Reports may be filed individually, in batch or via webservice.
Requirements
Register and maintain access to SISCOAF
File suspicious activity reports within the regulatory deadline (24h from suspicion)
Support individual, batch and webservice submission channels
Retain evidence of all communications transmitted to COAF
COES (Comunicação de Operação Suspeita) are filed through SISCOAF by the next working day after the operator concludes its analysis. The analysis itself must conclude within 30 days of the underlying bet or associated operation. Operators must be habilitados in SISCOAF under IN MF/SPA 4/2024 before going live and must file the annual negative declaration if no COES were sent in the calendar year. Tipping-off the bettor is prohibited under art. 18.
Portaria SPA/MF 1.143/2024 art. 30
Tipping-off prohibition
Operators may not disclose to the bettor or any third party that a SISCOAF communication has been made, except to COAF or SPA/MF. Tipping off is a sanctionable infraction.
Requirements
Forbid disclosure of SISCOAF filings to bettors or third parties
Train customer-facing staff on the tipping-off prohibition
Restrict access to SAR records to authorised compliance staff only
Train relevant staff on the control on hire and annually thereafter
Portaria SPA/MF 1.143/2024 art. 20
KYC manual: identification, qualification and risk classification procedures
Article 20 of Portaria SPA/MF 1.143/2024 requires operators to formalise their KYC procedures — bettor identification, qualification and risk classification — in a specific manual that must be approved by the board and updated at least annually.
Requirements
Formalise KYC procedures (identification, qualification, risk classification) in a dedicated manual
Obtain board/senior management approval of the manual
Review and update the manual at least annually
Portaria SPA/MF 1.143/2024 art. 22
Record-keeping
AML records, including bettor due diligence, transactions, alerts, internal reviews and SISCOAF filings, must be retained for at least five years from the end of the relationship or from the date of the operation.
Requirements
Retain AML records for at least five years from end of relationship or operation date
Store records in a form accessible to SPA/MF and COAF
Document the retention policy and review it annually
Test the control through periodic internal audit and external assurance
COAF Resolução 36/2021
COAF general reporting standard
Resolução COAF 36/2021 (as updated) sets the cross-sectoral standard for SISCOAF communications, including the structure of the communication, automatic-communications triggers and the protection of communicants. Operators must align their SISCOAF integration with this resolution.
Requirements
Align SISCOAF integration with the current Resolução COAF 36 specification
Implement automatic-communications triggers where applicable
Document the integration in the AML manual
Train relevant staff on the control on hire and annually thereafter
Comunicado SISCOAF 101
Lotep / Apostas de quota fixa SISCOAF configuration
Comunicado SISCOAF 101 documents the configuration of the Lotep / Apostas de quota fixa segment in SISCOAF, including the codes and fields to use when filing communications related to fixed-odds betting.
Requirements
Use the Lotep / Apostas de quota fixa segment when filing SISCOAF communications
Map internal alert types to the Comunicado 101 code list
Update the configuration when COAF issues a new Comunicado
Document the control in the AML manual and review at least annually
Operators register in SISCOAF using setor 'Apostas de quota fixa', subsector code from Comunicado SISCOAF 101, after habilitação under IN MF/SPA 4/2024. The Compliance Officer must be designated in writing to SPA/MF and COAF before the first COES can be filed.
Portaria Lottopar 28/2025
Lottopar internal AML/CFT controls and SISCOAF reporting tables
Portaria Lottopar nº 28 of April 2025 sets the policies, procedures and internal controls for prevention of money laundering and terrorist financing applicable to operators under the Lottopar Paraná state regime. The act extended the reporting taxonomy used in SISCOAF and made the SISCOAF occurrence tables available to operators from 2 June 2025, allowing harmonised submission across the federal and state regimes.
Requirements
Align the AML/CFT manual with the Lottopar 28/2025 control template and the Comunicado SISCOAF 101 taxonomy
Use the SISCOAF occurrence tables from 2 June 2025 for every suspicious-activity report
Maintain the AML risk assessment refreshed annually and after material business changes
Document training of AML officers and front-line staff at least annually
Operators authorised by both SPA federally and a state lottery (Lottopar, Loterj, Loteminas) must reconcile both regimes; the SISCOAF occurrence taxonomy is now a common spine.
11
Theme 11
Taxation & financial reporting
Lei 14.790 sets a 12% GGR levy on operators with detailed earmarking and a 15% personal income tax on bettor net prizes above the IRPF exemption band; Receita Federal Instruction 2.299/2025 sets the mechanics for the prize tax.
17 standards9 player-flagged
53%
player-flagged
Regulatory risks this theme addresses
Mis-stating GGR by excluding payable but unsettled bonuses or by netting bonuses incorrectly
Failing to withhold or report the bettor's IRPF on prizes above the threshold
Missing the monthly GGR-tax filing deadline
Taxes and allocations 17
Lei 13.756/2018 art. 30 (com redação dada pela Lei 14.790/2023)
12% GGR tax and earmarking
Article 30 of Lei 13.756/2018 (as amended by Lei 14.790/2023) imposes a 12% levy on Gross Gaming Revenue (total bets less prizes paid and less the bettor's income tax). The proceeds are earmarked across social security, education, sport, tourism, health and public security in the proportions fixed by the statute.
Requirements
Compute GGR as bets less prizes less bettor IRPF, per the statutory formula
File and pay the 12% levy monthly within the Receita Federal deadline
Reconcile the levy to the SIGAP-reported volumes
Retain tax filings, DARFs and supporting workings for the statutory period
The 12% GGR contribution is collected monthly via DARF 5862, due by the 20th of the month following the apuração period. The base is GGR net of prizes paid out; bonuses follow the specific fiscal accounting rules set by the Ministry of Finance in February 2025. The 75/25 split between DARF 5862 (operator-borne portion) and the earmarked allocations under art. 32 is settled internally by Receita Federal; operators only see DARF 5862.
Lei 14.790/2023 art. 31
15% IRPF on bettor net prizes
Player Rights
Article 31 subjects bettor net prizes; annual net winnings above the IRPF exemption band; to a 15% income tax. The exemption band is the first bracket of the annual IRPF progressive table (R$ 2,824 per month / approx. R$ 33,888 per year at the cut-off date).
Requirements
Calculate the bettor's net annual result and apply the 15% rate above the exemption band
Surface the tax position in the bettor account dashboard
Report annual results to Receita Federal for inclusion in the bettor's DIRPF
Document the tax-controls framework and review with external counsel annually
The 15% rate applies to net annual winnings exceeding the first IRPF progressive bracket, currently R$ 28.467,20 for tax year 2025 (declared in 2026). The threshold is annual, not monthly; the prior dataset language of R$ 2.824 monthly conflated the IRPF general monthly exemption with the prize-tax floor. The operator does not withhold; the bettor self-assesses in the annual IRPF return. The general IRPF reform under Lei 15.270/2025 (full exemption up to R$ 5.000 monthly from January 2026) does not change the prize-tax floor.
Instrução Normativa RFB 2.299/2025
Mechanics of the prize tax
Player Rights
Instrução Normativa RFB 2.299/2025 sets the operational mechanics of the 15% prize tax, including reporting cycles, the calculation period and the duty to issue a tax statement to the bettor. It is the Receita Federal companion to Lei 14.790 art. 31.
Requirements
Apply the IN 2.299/2025 calculation period and reporting cycles
Issue an annual tax statement to each bettor for use in their DIRPF
Reconcile the statements to the bettor ledger and to Receita Federal filings
Reconcile tax filings to the GGR ledger, the SIGAP feed and the bettor account ledger
Operators must issue the ComprovaBet (Comprovante de Resultados em Apostas em Loterias de Quota Fixa) to each bettor by the last working day of February of the year following the apuração. The bettor self-computes IRRF in March and pays via DARF 6313-01 by the last working day of April. The 2025 deadline therefore lands on 30 April 2026. The operator's obligation is documentary; it does not withhold at source.
Lei 14.790/2023 art. 32
Earmarked allocation of the GGR tax
Article 32 allocates the 12% GGR levy across designated public funds. Indicative shares are 36% to sport, 28% to tourism, 12.6% to public security, 10% to social security, 10% to education and remaining shares across health and other funds set by the statute.
Requirements
Maintain records that support the allocation by destination fund
Reconcile monthly to the Receita Federal allocation report
Surface the allocation in stakeholder reporting and corporate ESG disclosure
Retain tax filings, DARFs and supporting workings for the statutory period
Lei 14.790/2023 art. 34
Withholding obligations on bettor prizes
Player Rights
Article 34 requires the operator to retain and remit the bettor's IRPF on prizes above the exemption band where the operator is the source. Withholding is a defence to the bettor's later DIRPF position only to the extent of the amount withheld.
Requirements
Implement withholding logic on prize crediting where required
Remit withheld IRPF to Receita Federal on the regulator-set cycle
Issue the bettor a withholding statement that maps to the annual DIRPF
Document the tax-controls framework and review with external counsel annually
Lei 14.790/2023 art. 33
Monthly tax filings and DARF payment
Operators must file the GGR tax monthly using the Receita Federal DARF mechanism on or before the regulator-set day of the following month. Late payment attracts interest at SELIC and a fine.
Requirements
Diarise the monthly DARF deadline and run a documented filing process
Reconcile DARF payments to GGR and to SIGAP volumes
Document late-payment exceptions and remedy them promptly
Reconcile tax filings to the GGR ledger, the SIGAP feed and the bettor account ledger
Monthly cycle: SIGAP daily feeds during the month, GGR apuração closes on the last calendar day, DARF 5862 settles by the 20th of the following month, supporting EFD-Contribuições and DCTFWeb declarations follow the standard Receita Federal calendar. Late payment triggers the SELIC plus 1% per month penalty under standard tributário rules and an additional infração under Portaria SPA/MF 1.233/2024.
Portaria SPA/MF 827/2024 art. 28
Annual audited financial statements
Authorisation holders must file annual audited financial statements with SPA/MF, prepared under Brazilian accounting standards by a CVM-registered or CRC-accredited independent auditor.
Requirements
Engage an independent auditor that meets the SPA/MF eligibility criteria
File audited statements with SPA/MF within the regulator deadline
Cross-reference the statements to the bettor-funds segregation report
Retain tax filings, DARFs and supporting workings for the statutory period
Portaria SPA/MF 827/2024 art. 30
Solvency monitoring and capital top-up
If capital, net equity or the technical reserve falls below the regulatory floor, the operator must notify SPA/MF and top up within the regulator-set deadline. Failure is grounds for suspension.
Requirements
Monitor capital, equity and reserve continuously
Notify SPA/MF and top up within the deadline on any shortfall
Treat any unremedied shortfall as a triggering event for the contingency plan
Document the tax-controls framework and review with external counsel annually
Lei 14.790/2023 art. 4
Authorised modalities and the prohibition on under-18 events
Game Design
Article 4 limits the authorised perimeter to fixed-odds bets on real sports events, online games and virtual events. The single paragraph prohibits offering bets on competitions or categories that involve exclusively athletes under 18 years of age.
Requirements
Restrict the event catalogue to fixed-odds bets on the authorised event types
Reject any market based exclusively on under-18 athletes
Audit the catalogue on every new event onboarding
Reconcile tax filings to the GGR ledger, the SIGAP feed and the bettor account ledger
Lei 14.790/2023 art. 28
Integrity of sporting events
Game Design
Article 28 requires operators to cooperate with the integrity bodies of sports federations, to report suspicious betting patterns and to suspend markets where the integrity of an event is in doubt.
Requirements
Operate a documented integrity-monitoring capability across pre-match and in-play markets
Report suspicious patterns to the relevant federation and SPA/MF
Suspend or void markets where event integrity is materially in doubt
Retain tax filings, DARFs and supporting workings for the statutory period
Portaria SPA/MF 1.231/2024 art. 75
Bettor-funds reporting
Player Rights
Operators must report bettor-funds positions to SPA/MF at the cadence and in the format the regulator publishes, alongside reconciliations to segregated accounts.
Requirements
Build a bettor-funds report aligned to the SPA/MF template
File on the regulator-set cadence (typically monthly)
Reconcile bettor balances to segregated accounts in the same submission
Document the tax-controls framework and review with external counsel annually
Portaria SPA/MF 41/2025
Procedures for transferring fixed-odds lottery revenue to legal beneficiaries
Portaria SPA/MF nº 41 of 10 January 2025 renumbers and supersedes Portaria 1.902 of December 2024 and establishes the operational procedure by which authorised fixed-odds operators must transfer the allocated share of GGR to the beneficiaries listed in article 30, §1º-A of Law 13.756/2018. The transfers cover social security, sport, public security, basic education and the National Public Security Fund and must be executed through GRU-Cobrança issued via SIGAP.
Requirements
Compute the destination shares of GGR per the allocations in article 30 of Law 13.756/2018
Settle every allocation through GRU-Cobrança generated inside SIGAP within the deadlines fixed by the Portaria
Reconcile transferred amounts against the monthly GGR report and retain evidence for five years
Notify SPA of any failed or returned transfer within the next business day
Operators that miss the transfer deadlines accumulate Selic-indexed surcharges and may be subject to suspension under Portaria 1.225/2024.
Portaria SPA/MF 2.219/2025
Revenue code for the 6 percent social-security allocation
Portaria SPA/MF nº 2.219 of 30 September 2025 amends Portaria 1.212/2024 and creates a dedicated federal revenue code used by fixed-odds operators to collect and remit the 6 percent of GGR earmarked for Social Security under article 30, §1º-A, II of Law 13.756/2018. The new code allows the National Treasury and INSS to reconcile collections without manual intervention.
Requirements
Use the new revenue code on every GRU-Cobrança that settles the 6 percent social-security share
Reconcile the monthly collection with the GGR figure reported through SIGAP
Migrate any legacy payment template to the new code from the effective date
Document the code mapping in the tax-compliance manual
Misallocation between revenue codes does not extinguish the liability and triggers Selic-indexed surcharges; treasury teams should validate the mapping with their banking partner before the first cycle.
Lei Complementar 224/2025
Joint and several tax liability for facilitators of illegal betting
Affiliate RulesBonus & Ads
Lei Complementar nº 224 of 26 December 2025 attributes joint and several liability for the taxes and contributions levied on fixed-odds betting operations and on net prizes to two categories of facilitator. The first is financial and payment institutions that, after formal notification by the competent federal authority, fail to adopt restrictive measures and continue to process flows for unauthorised operators. The second is individuals and legal entities (advertising agencies and influencers) that disseminate commercial advertising on behalf of unauthorised operators. The regime takes effect on 1 January 2026.
Requirements
Act on formal notifications from SPA/MF, the Receita Federal or the BCB within the deadline fixed in the notification
Suspend processing of all flows originating from or directed to the notified illegal operator
Refuse to disseminate, on behalf of unauthorised operators, any commercial communication once on notice of unauthorised status
Maintain notification logs and risk-mitigation evidence for at least five years
Brief commercial, agency and influencer counterparties on the joint-liability exposure
Joint and several tax liability is a significant tax-collection lever; in practice it pushes banks, PSPs, advertising platforms and influencers into the front line of illegal-market suppression.
Instrução Normativa RFB 2.312/2026
IRPF rules for bettor net winnings and the ComprovaBet document
Player Rights
Instrução Normativa RFB nº 2.312 of 2026 consolidates the rules governing the personal income tax (IRPF) on net winnings from fixed-odds betting and fantasy-sport contests. It institutes the ComprovaBet document that authorised operators must issue to bettors by the last business day of February of each year, sets the bettor's duty to compute annual net result by bet type, fixes the 15 percent rate on the amount exceeding the exemption band and creates a dedicated app for payment by the last business day of April.
Requirements
Issue the ComprovaBet to every bettor by the last business day of February covering the previous calendar year
Reflect winnings, losses and net result per bet type in the ComprovaBet
Operate withholding at source on amounts exceeding the annual exemption band of R$ 28,467.20
Reconcile the ComprovaBet with the SIGAP wallet data and the operator's accounting
Make the ComprovaBet available through SPA's bettor-protection channels
The IN closes a gap that previously left bettor-side tax obligations unclear; operators that are slow to issue the ComprovaBet expose bettors to enforcement risk and themselves to supervisory action.
DARF 5862 monthly GGR contribution
DARF 5862 monthly GGR contribution settlement
The 12% GGR contribution under Lei 14.790/2023 art. 30 is settled monthly through DARF 5862 issued via the eCAC portal. Apuração closes on the last calendar day of the month; payment is due by the 20th of the following month. The Receita Federal handles the internal split between the operator-borne portion and the earmarked allocations under Lei 14.790/2023 art. 32.
Requirements
Close the GGR apuração on the last calendar day of the month and generate DARF 5862 by the 5th working day of the next month
Pay DARF 5862 by the 20th of the month following the apuração period
Reconcile the DARF amount against the SIGAP monthly legal-obligations file and EFD-Contribuições
File DCTFWeb and supporting fiscal obligations on the standard Receita Federal calendar
Late payment accrues SELIC plus 1% per month under standard tributário rules and is also an autonomous infração under Portaria SPA/MF 1.233/2024. The bonus accounting rules published by the Ministry of Finance in February 2025 govern what may and may not be deducted from GGR before applying the 12%.
ComprovaBet annual issuance and DARF 6313-01
ComprovaBet annual issuance and bettor prize-tax DARF 6313-01
Player Rights
Under Instrução Normativa RFB 2.299/2025 the operator must issue the ComprovaBet (Comprovante de Resultados em Apostas em Loterias de Quota Fixa) to every bettor by the last working day of February each year, covering the prior calendar year. The bettor then self-computes 15% IRRF on net annual winnings exceeding the first IRPF progressive bracket (R$ 28.467,20 for tax year 2025) and pays via DARF 6313-01 by the last working day of April. For tax year 2025 the bettor deadline is 30 April 2026.
Requirements
Issue the ComprovaBet to every bettor by the last working day of February each year
Make the ComprovaBet available through the bettor portal and through a downloadable file
Calibrate the calculation engine to the R$ 28.467,20 annual exempt floor; track the IRPF table for any update
Do not withhold 15% at source; the obligation is self-assessment by the bettor
The previous dataset described a monthly exemption of R$ 2.824 - that figure conflated the IRPF general monthly exemption with the prize-tax floor. The prize-tax floor is annual and tracks the IRPF first bracket. The general IRPF reform under Lei 15.270/2025 (full exemption up to R$ 5.000 monthly from January 2026) does not change the prize-tax floor.
Portarias SPA/MF 1.225/2024 and 1.233/2024 set the monitoring and sanctions framework; Lei 14.790 underpins the sanctions ladder up to R$ 2 billion fines and revocation; SPA/MF, ANATEL, CGU, Receita Federal and COAF coordinate to block illegal sites and disrupt their payment rails.
31 standards20 player-flagged
65%
player-flagged
Regulatory risks this theme addresses
Allowing affiliate or technology relationships with operators that lose their authorisation
Receiving customer migrations from a suspended or blocked site without re-onboarding
Tolerating brand abuse by illegal sites and failing to coordinate with ANATEL
Supervision and sanctions 16
Portaria SPA/MF 1.225/2024
Monitoring and supervision
Portaria 1.225 sets the SPA/MF monitoring and supervisory framework, including national-scope competence, on-site and off-site inspections, information requests and the power to coordinate with other public bodies. It is the operational counterpart to Lei 14.790's supervisory mandate.
Requirements
Maintain a regulatory-correspondence log with response SLAs
Cooperate with on-site and off-site inspections and produce evidence promptly
Treat regulator information requests as binding within the stated deadline
Retain regulator-correspondence and supervisory-evidence files for at least five years
Portaria SPA/MF 1.233/2024
Sanctions framework
Portaria 1.233 sets the sanctioning system: infraction categories, dosimetry, mitigating and aggravating factors, the duty to open a sanctioning process on supervisory findings and the option of a commitment agreement (TCC) as an alternative to sanction.
Requirements
Map internal control failures to the Portaria 1.233 infraction categories
Use the dosimetry framework to estimate exposure on any open finding
Consider a TCC where it remediates the issue more effectively than a formal sanction
Track open findings in a remediation register with named owners and deadlines
Lei 14.790/2023 art. 41
Sanctions ladder up to R$ 2 billion fine
Article 41 of Lei 14.790/2023 establishes the administrative sanctions ladder applicable to authorised fixed-odds betting operators: advertência (warning); multa (fine) ranging from 0.1% to 20% of the operator's revenue in the activity (limited to R$ 2 billion per infraction, with a floor of R$ 50,000); partial or total suspension of activities; prohibition from obtaining new authorisations or from contracting with the public administration for up to 10 years; and revocation (cassação) of the authorisation.
Requirements
Operators are subject to graduated administrative sanctions for breaches of Lei 14.790/2023 or Ministry of Finance regulations.
Fines range from 0.1% to 20% of revenue in the fixed-odds betting activity, capped at R$ 2 billion per infraction with a R$ 50,000 floor.
More severe breaches may result in partial/total suspension, prohibition from new authorisations or public contracting for up to 10 years, or revocation of the authorisation.
Lei 14.790/2023 art. 36
Criminal liability for unauthorised exploitation
Article 36 introduces criminal liability for the exploitation of fixed-odds betting without authorisation, with imprisonment and fines. Personal liability attaches to directors and de facto managers.
Requirements
Do not market or accept Brazilian bets before the SPA/MF authorisation is effective
Cut off any group activity that operates outside the authorised perimeter
Train directors and senior managers on the personal-liability exposure
Retain regulator-correspondence and supervisory-evidence files for at least five years
ANATEL-SPA/MF cooperation
Domain and IP blocking of illegal sites
Affiliate Rules
SPA/MF and ANATEL operate a cooperation arrangement (TCA of 9 October 2024) under which SPA/MF identifies illegal betting sites and ANATEL orders connectivity providers to block the domains and IPs. By H1 2025 the regime had blocked more than 15,000 domains, with cumulative blocking surpassing 18,000 sites by September 2025.
Requirements
Track ANATEL blocking lists and ensure no relationship persists with blocked entities
Report brand impersonation by illegal sites to SPA/MF for inclusion in the next blocking list
Audit affiliate and technology supplier lists against blocked domains
Track open findings in a remediation register with named owners and deadlines
BCB-SPA/MF coordination
Payment-rail suppression
SPA/MF coordinates with the Banco Central do Brasil and acquirers to identify and shut down payment accounts used by illegal betting operators. By 2025, multiple payment institutions had closed accounts of unauthorised operators on SPA/MF referrals.
Requirements
Refuse counterpart payment relationships with operators flagged by SPA/MF
Cooperate with BCB and acquirer queries about payment counterparties
Audit aggregator and PSP onboarding to exclude illegal-operator exposure
Brief executive leadership on supervisory exposure each quarter
CGU and SENACON cooperation
Whole-of-government enforcement
Player Rights
The Controladoria-Geral da União, the Secretaria Nacional do Consumidor (SENACON) and the Ministério Público participate in cross-agency operations against illegal operators, consumer-protection breaches and integrity violations.
Requirements
Track CGU, SENACON and MP enforcement priorities and align internal controls
Cooperate with consumer-protection inquiries within the SENACON deadline
Treat integrity findings as a cross-agency exposure, not only an SPA/MF one
Retain regulator-correspondence and supervisory-evidence files for at least five years
Lei 14.790/2023 art. 37
Ombudsman channel and complaint resolution
Player Rights
Article 37 obliges operators to maintain an ombudsman channel (canal de ouvidoria) for complaints, with documented SLAs and escalation to SPA/MF where the bettor and operator cannot resolve the issue.
Requirements
Stand up an ombudsman channel staffed in Portuguese with documented SLAs
Publish the channel access and SLAs in the bettor portal
Escalate unresolved complaints to SPA/MF on request
Track open findings in a remediation register with named owners and deadlines
Portaria SPA/MF 1.233/2024 art. 12
Termo de Compromisso (TCC) as alternative to sanction
Article 12 contemplates a commitment agreement (Termo de Compromisso de Cessação) under which the operator commits to remediation in exchange for the suspension or non-application of the sanctioning process. The TCC is binding and breach is itself sanctionable.
Requirements
Evaluate TCC as a remediation pathway on supervisory findings
Treat TCC breach as a high-severity exposure with rapid sanction
Brief executive leadership on supervisory exposure each quarter
MF Portaria 1.902/2024
Anti-fraud, integrity and intelligence coordination
Portaria MF 1.902 of December 2024 created additional intelligence and anti-fraud arrangements inside the Ministry of Finance, supporting SPA/MF supervisory work with cross-functional intelligence on illegal operators and integrity threats.
Requirements
Cooperate with intelligence requests issued under MF 1.902
Treat intelligence-driven findings on integrity as priority remediation items
Document data-sharing protocols with the Ministry of Finance intelligence function
Retain regulator-correspondence and supervisory-evidence files for at least five years
CGU Operação Integração
Cross-agency operations against illegal operators
Affiliate Rules
CGU, Polícia Federal and SPA/MF have run joint operations against illegal operators and their payment chains, including asset freezes, criminal investigations and coordinated takedowns. The pattern is now an established enforcement modality.
Requirements
Audit affiliate and supplier lists for any link to targeted entities
Cooperate fully with cross-agency enforcement requests
Treat coordinated takedown announcements as a trigger for enhanced KYC on player migrations
Track open findings in a remediation register with named owners and deadlines
Portaria SPA/MF 1.225/2024 art. 8
Mandatory information requests
Article 8 empowers SPA/MF to issue mandatory information requests with deadlines. Failure to respond, incomplete response and false response are independent infractions.
Requirements
Treat regulator information requests as binding obligations with documented owners
Build a documented evidence vault to support timely responses
Verify every response for completeness and accuracy before submission
Brief executive leadership on supervisory exposure each quarter
Portaria SPA/MF 787/2025
Suspension of provisionally authorised operators for missing certifications
Portaria SPA/MF nº 787 of 10 April 2025 suspends the provisional authorisation of operators that failed to present the technical certifications required under Portaria 1.207/2024 and Instrução Normativa 3/2025 and grants them a fixed regularisation window. The Portaria sets the template for how SPA exercises the suspend-and-regularise power against provisionally licensed operators.
Requirements
Treat any certification gap reported by SPA as immediately actionable
Use the regularisation window only to complete the certificate set, not to launch new games
Notify all banking and payment counterparties of the suspension within one business day
If certificates are not produced inside the window, prepare for definitive revocation under Portaria 827/2024
Operators suspended under this instrument cannot accept new bets or process withdrawals beyond returning player balances; bet365 Brasil and several others reorganised certifications under this pressure during Q2 2025.
Portaria SPA/MF 2.217/2025
Revocation template for non-compliant provisional operators
Portaria SPA/MF nº 2.217 of 30 September 2025 consolidates the procedure SPA follows to revoke the provisional authorisation of operators that remain non-compliant after the suspension window opened by Portaria 787/2025. It formalises the case-file content, the right of defence, the timeline and the cross-notification to banks, ANATEL and the COAF.
Requirements
Treat any SPA non-compliance notice as triggering a defence preparation window
Produce contemporaneous evidence of certification, segregation of funds and AML controls
Anticipate the cross-notification to banks and PSPs once revocation is published
Coordinate orderly return of player balances if revocation is confirmed
Revocation is published in the DOU and entered in the Módulo de Impedidos, which feeds the SPA URL block list distributed to ANATEL.
Resolução BCB 569/2026
Fraud marker for illegal-betting flows in the financial system
Resolução BCB nº 569 of 2026 expands the BCB fraud-marker scheme so that banks, fintechs and other financial institutions share information about individuals and legal entities identified as illegal betting operators or as intermediaries of illegal-betting flows. The marker uses the same infrastructure already deployed against Pix scams and acts as a cross-institution warning.
Requirements
Mark customers identified by SPA, COAF, the police or the institution itself as illegal-betting operators or intermediaries
Share the marker via the BCB fraud-marker infrastructure within the deadlines fixed by the Resolução
Take risk-mitigation action proportional to the marker, including account freezing and reinforced KYC
Reconcile internal markers with the SPA Módulo de Impedidos and the LC 224/2025 notification list
The fraud-marker channel is the technical scaffolding that makes the LC 224/2025 joint-liability regime operationally enforceable.
ANATEL-SPA URL blocking programme 2024-2025
ANATEL-SPA URL blocking programme - 25,000 sites in the first year
Affiliate Rules
Under the Technical Cooperation Agreement between SPA/MF and ANATEL, the agencies blocked more than 25,000 URLs of illegal betting and pirate-streaming sites between October 2024 and December 2025. SPA identifies the irregular platforms and feeds the list to ANATEL, which orders internet service providers to block access. In parallel SPA closed 412 enforcement procedures against illegal advertising, removed 324 influencer profiles and triggered 1,255 SISCOAF reports leading to 550 bank-account closures.
Requirements
Monitor the SPA Módulo de Impedidos and the ANATEL block list and use them as risk signals in payments, advertising and affiliate onboarding
Decline any advertising or affiliate engagement involving operators or domains on the block list
Reflect the block list in commercial risk assessments and KYC sources
Treat repeated payment flows to blocked URLs as suspicious activity under the AML programme
The block-list programme is a practical compliance signal even though it is not a normative act in the strict sense; the Portaria 1.225/2024 and Portaria 1.233/2024 supervisory regime treats interaction with blocked sites as a material risk factor.
Sanções administrativas contra operadoras autorizadas 3
Portaria SPA/MF 787/2025
Pixbet, Caixa Loterias, 7MBR (Cbet) and TQJ-Par (Tele Sena Bet) suspended for 90 days for failure to file mandatory technical certifications
RG Critical
On 10 April 2025 the SPA/MF, by Portaria 787, suspended the provisional authorisations of Pixbet Soluções Tecnológicas Ltda (brands Pixbet, Flabet, Bet da Sorte), Caixa Loterias S.A. (Betcaixa, Megabet, Xbet Caixa), 7MBR Ltda (Cbet) and TQJ-Par Participações Societárias S.A. (Baú Bingo, Tele Sena Bet, Bet do Milhão) for up to 90 days. The ground was non-compliance with art. 3 of Portaria SPA/MF 2.104/2024, which requires submission of mandatory technical and operational certifications. The 2nd Federal Court of the Federal District subsequently stayed the Portaria as to Pixbet by writ of mandamus, restoring its operation pending review. Flamengo removed the Pixbet shirt-sponsor mark while the suspension was in force.
Requirements
Track the technical-certification deadline in Portaria SPA/MF 2.104/2024 art. 3 as a board-level deliverable
Map every certification artefact (GLI, ISO/IEC 27001, fairness audit, operational continuity) to a named owner with a calendar deadline
Maintain contingency communications for sponsors and media partners in the event of a precautionary suspension
Document remediation evidence and have it ready to file within the 90-day window to lift suspension
Portaria 787/2025 establishes that the SPA/MF will move from notice to precautionary suspension when a structural compliance milestone (technical certification) is missed, and will do so even against the largest brands in the market. The judicial pushback on proportionality also signals that the agency must articulate the link between the missed milestone and consumer-protection harm or the suspension is exposed to a writ of mandamus.
SPA/MF precautionary suspensions of 30 May 2025
Seven authorised operators (17 brands) suspended for failure to deliver the betting-system security-evaluation report
RG Critical
On 30 May 2025 the SPA/MF suspended seven authorised operators covering 17 brands for failing to deliver the betting-system security-evaluation report required by art. 8 of Portaria SPA/MF 722/2024 within 90 days of authorisation. The operators were: Bell Ventures Digital Ltda (bandbet.bet.br); Bet.Bet Soluções Tecnológicas S.A. (betpontobet.bet.br, donald.bet.br); Betesporte Apostas On Line Ltda (betesporte.bet.br, lancedesorte.bet.br); EA Entretenimento e Esportes Ltda (bateu.bet.br, hanz.bet.br, esportiva.bet.br); Logame do Brasil Ltda (lider.bet.br, geralbet.bet.br, b2x.bet.br); Pixbet Soluções Tecnológicas Ltda (pix.bet.br, fla.bet.br, betdasorte.bet.br); and Sortenabet Gaming Brasil S.A. (sortenabet.bet.br, betou.bet.br, betfusion.bet.br). A daily astreinte of R$ 40,000 applies if the precautionary measure is breached, and a sanctioning administrative process is opened if non-compliance persists.
Requirements
File the betting-system security-evaluation report within 90 days of authorisation, per art. 8 of Portaria SPA/MF 722/2024
Treat the cybersecurity audit chain (penetration test, SOC review, encryption-at-rest, key-management, incident-response runbook) as a regulatory deliverable, not an IT project
Provision the R$ 40,000-per-day astreinte in the operational risk register for every brand
Surface security-report deadlines on the board governance calendar at least 60 days in advance
The 30 May 2025 round shows the SPA/MF will not treat security-report deadlines as soft. The fact that all 17 brands across seven distinct corporate groups were suspended in a single action demonstrates the agency runs a deadline-driven, system-wide audit and acts on misses uniformly.
SENACON Despacho 35/2024 (precautionary)
SENACON nationwide precautionary suspension of betting advertising involving advance, bonus or anticipated reward
Bonus & Ads
In November 2024 the Secretaria Nacional do Consumidor (SENACON, Ministério da Justiça) issued a precautionary decision suspending nationwide all betting advertising offering bonuses, advances or anticipated rewards, and suspending nationwide all advertising of fixed-odds betting aimed at children and adolescents. Operators were ordered to file a transparency report within 20 days describing measures adopted to comply. Breach attracts a daily fine of R$ 50,000. The measure is grounded in the Consumer Defence Code (Lei 8.078/1990) read with Lei 14.790/2023 art. 5, which places the bettor-operator relationship within the CDC.
Requirements
Eliminate bonus, advance and anticipated-reward language from all consumer-facing creative
Audit affiliate, influencer and media-buying chains to ensure no third party is running suspended creative on the operator's behalf
File the SENACON-required transparency report within 20 days of any new precautionary measure
Brief creative agencies on the explicit prohibition of child- and adolescent-directed betting advertising
SENACON acts in parallel with SPA/MF and CONAR. Operators commonly under-estimate consumer-protection exposure because the fine quanta look small (R$ 50,000/day) compared with the Art. 35 Lei 14.790 ceiling, but SENACON measures bite across every brand simultaneously and influence SPA/MF dosimetry on aggravating factors.
Ações contra mercado não autorizado — ANATEL e bloqueio de URLs 2
ANATEL/SPA blocking — first year (Oct 2024 to Dec 2025)
More than 25,000 illegal betting URLs blocked by ANATEL on SPA/MF determination in the first year of the regulated market
RG Critical
In the first year of the regulated market (October 2024 to December 2025) ANATEL, acting on SPA/MF determinations, blocked more than 25,000 illegal betting URLs. In parallel 203 irregular applications were removed from the Google Play and Apple App Store, and 412 regulatory processes against illegal social-media advertising were concluded, removing 324 influencer profiles and 229 posts. By the end of 2025, 54 financial and payment institutions had filed 1,255 communications to the SPA covering 1,687 individuals with signs of transfers to unauthorised operators.
Requirements
Operate only under a definitive SPA/MF authorisation; do not rely on a perceived enforcement lag
Monitor URL-blocking lists published by SPA/MF and ANATEL to confirm no operator brand or mirror is captured by error
Run continuous app-store takedown monitoring; an unauthorised mirror in Google Play is a sanctioning trigger
Calibrate influencer and affiliate contracts so the operator can demand immediate takedown on receipt of a SPA/MF notice
The first-year figures establish that the SPA/MF will pursue unauthorised supply at scale, and that the agency treats payments, app stores, ISPs and influencers as a single enforcement perimeter. The 1,255 SISCOAF-style communications also show that the payments-rail provisions of Portaria SPA/MF 566/2025 are being used in earnest.
ANATEL escalation to ~39,000 blocked sites (Q2 2026)
Cumulative ANATEL blocking reaches approximately 39,000 illegal betting sites by Q2 2026
RG Critical
As reported by Finance Minister Dario Durigan in connection with the Polymarket/Kalshi action of April-May 2026, the cumulative number of illegal betting and prediction-market sites blocked by ANATEL on Ministry of Finance determination reached approximately 39,000 by Q2 2026. The blocking operates via ANATEL notifications to all internet access providers in Brazil and is the standard enforcement channel for unauthorised supply.
Requirements
Treat any presence on an ANATEL block list as a definitive impairment of operations, not a technical inconvenience
If acting as an ISP or payments provider, implement an automated ingestion of the ANATEL/SPA-MF block list
Audit affiliate networks for mirror domains that could be captured in mass blocks
The escalation from 25,000 to 39,000 in roughly a quarter shows that ANATEL has now industrialised the takedown pipeline and that supply-side enforcement is the agency's primary unauthorised-market lever.
Ações contra mercado não autorizado — mercados preditivos 1
Resolução CMN 5.298/2026 + ANATEL block of Polymarket and Kalshi
CMN Resolution 5.298/2026 prohibits prediction-market derivatives; ANATEL blocks Polymarket and Kalshi from 4 May 2026
RG Critical
By Resolution 5.298 of 24 April 2026 the Conselho Monetário Nacional prohibited the offer or trading in Brazil of derivative contracts whose underlying is sporting events, online games or political, electoral, cultural or social outcomes, allowing only derivatives linked to predefined economic and financial indicators. The Resolution, signed by Banco Central do Brasil president Gabriel Galípolo, took effect on 4 May 2026. On SPA/MF determination ANATEL notified internet access providers to block prediction-market platforms including Polymarket and Kalshi; 27 sites were blocked in the initial action.
Requirements
Do not offer in Brazil any contract whose payout depends on the outcome of a sporting event, an online game or a political, electoral, cultural or social event other than predefined economic and financial indicators
If a foreign prediction-market or event-derivative offering reaches Brazilian users, treat it as an unauthorised supply matter subject to ANATEL blocking and Lei 14.790 art. 36 criminal exposure
Update payment-rail screening to reject deposits and withdrawals tied to blocked prediction-market platforms
Resolução CMN 5.298/2026 closes the regulatory arbitrage that prediction markets had been claiming: by classifying event-outcome derivatives as outside the lawful perimeter, it brings prediction markets within the Lei 14.790 enforcement perimeter without requiring any change to the gambling law itself.
Ações criminais e operações conjuntas — Polícia Federal 4
PF Base Apostas — May 2026
Polícia Federal creates Base Apostas: standing investigative group for match manipulation, betting fraud and related crimes
RG Critical
On 13 May 2026 the Polícia Federal instituted the Grupo de Investigação para Repressão à Manipulação de Resultados Esportivos, Fraudes em Apostas e Crimes Correlatos, known as Base Apostas. The group sits under the Coordenação-Geral de Repressão à Corrupção, Crimes Financeiros e Lavagem de Dinheiro, with a one-year initial mandate renewable on directorate review. It is composed of officers specialised in financial intelligence, data analysis, asset recovery, digital-platform monitoring and organised-crime investigation, with a minimum staffing of one delegado, one clerk and three police analysts. Its mandate covers Lei 14.790 art. 36 (illegal betting), Lei 9.613 (money laundering), private corruption, fraud and related offences.
Requirements
Treat any Base Apostas inquiry as a federal matter spanning Lei 14.790 art. 36, Lei 9.613 and Código Penal
Maintain an internal protocol for cooperation requests, data preservation and lawful disclosure to the PF
Document integrity-monitoring outputs (Sportradar, Genius Sports or equivalent) so they are immediately available to a Base Apostas requisition
The creation of a standing PF group, rather than ad-hoc operations, signals a structural shift to permanent enforcement capacity against the sector and indicates that subsequent named operations will originate from this unit.
Operação Falsa Las Vegas — 28 May 2026
Operação Falsa Las Vegas blocks R$ 5.2 billion in PCC-linked illegal betting and laundering scheme (Black Vegas, Aposte Fácil)
RG Critical
On 28 May 2026 the São Paulo Civil Police, the Ministério Público de São Paulo and the Receita Federal launched Operação Falsa Las Vegas against an illegal betting and money-laundering scheme allegedly linked to the Primeiro Comando da Capital (PCC). The judicial action authorised five preventive arrests, 22 search-and-seizure warrants and the blocking of assets and financial resources exceeding R$ 5.2 billion, with seizure of 76 properties and a helicopter. The scheme used the Aposte Fácil platform as a façade and Black Vegas as the clandestine front, offering games prohibited in Brazil including the so-called Tigrinho slot mechanic and numbers-game modalities. The operation is an offshoot of Operação Falso Mercúrio.
Requirements
Avoid every commercial or technical relationship (white-label, payments, marketing) with operators not listed on the SPA/MF definitive-authorisation register
Implement enhanced due diligence on counterparties whose corporate structure includes shell companies, money mules or routing through high-risk jurisdictions
Treat presence of authorised-and-unauthorised twin brands (the Aposte Fácil pattern) as a red flag for SISCOAF reporting
Falsa Las Vegas is the first publicly disclosed operation in 2026 to combine the betting-fraud, organised-crime and laundering vectors in a single proceeding, and the R$ 5.2 billion block confirms that integrity exposure in the Brazilian market scales into the billions.
Operação Opções Binárias — Dec 2025
Operação Opções Binárias targets R$ 50 million scheme using binary-options platforms and illegal bet houses
RG Critical
In December 2025 the Polícia Federal launched Operação Opções Binárias against an organised criminal group suspected of having diverted more than R$ 50 million through illegal management of binary-options platforms and unauthorised betting houses. The PF executed 11 search-and-seizure warrants. The investigation describes three operating arms: Chinese-based contacts supplying platform-manipulation services, contracted digital influencers promoting the platforms, and a proprietary binary-options platform created to capture clients.
Requirements
Do not market binary options as a betting product in Brazil; they are securities (CVM jurisdiction) and a betting framing exposes the operator to Lei 14.790 art. 36
Run influencer due diligence to confirm none of the operator's promoters are concurrently associated with binary-options platforms
Maintain documentary evidence of platform integrity that can rebut accusations of manipulation in the event of a PF requisition
Opções Binárias confirms that the PF treats the binary-options vertical as part of the illegal betting enforcement perimeter when the product is structured as gambling rather than a regulated security, and that influencer participation in the supply chain is itself a charging vector.
Operação Penalidade Máxima (2023 to 2025 continuing)
Operação Penalidade Máxima: first systemic match-fixing prosecution affecting Série A players
RG Critical
Operação Penalidade Máxima, run by the Ministério Público de Goiás with Polícia Federal support, opened in April 2023 with the arrest of bettors and expanded in May 2023 to Série A matches. In September 2023 the MP-GO indicted 16 individuals for match-fixing in 13 matches, eight of them in Série A. Investigators identified that players were recruited to commit specific in-match actions (committing penalties, taking yellow or red cards) which mapped directly to in-play bets. Estimated losses to betting houses exceeded R$ 4.8 million in nine of the suspect matches. The case is the leading precedent for the application of Lei 14.790 art. 31 (integrity duties) and Código Penal art. 171 (fraud) to in-play sports betting.
Requirements
Subscribe to a recognised integrity-monitoring provider (Sportradar, Genius Sports, IBIA) and submit suspicious-pattern alerts to the SPA/MF integrity desk
Cap in-play markets on micro-events (yellow cards, throw-ins, corners) where integrity coverage is shallow
Reserve the contractual right to void bets where match-fixing is alleged on credible evidence, and document the policy clearly to bettors
Cooperate with PF and MP requisitions within statutory deadlines; failure exposes the operator to obstruction charges
Penalidade Máxima is the doctrinal anchor for the integrity duties later codified in Lei 14.790 art. 31. The fact that micro-event in-play markets were the vehicle has driven operator and regulator focus on those markets and is the implicit policy reason behind the SPA/MF reporting obligations.
Pagamentos e bloqueio de instituições financeiras 1
Portaria SPA/MF 566/2025
Portaria SPA/MF 566/2025: financial and payment institutions must refuse accounts of unauthorised betting operators
RG Critical
By Portaria SPA/MF 566 of 21 March 2025 the SPA/MF set the rules under which financial institutions and payment institutions must refuse to open or maintain accounts used to receive bets on behalf of operators that do not hold a SPA/MF authorisation. Non-compliant institutions are themselves subject to sanction under the SPA/MF regulatory regime read with Banco Central rules. The instrument operationalises the joint enforcement perimeter SPA/MF + BCB + ANATEL against unauthorised supply.
Requirements
Match every merchant CNPJ used for betting deposits and withdrawals against the SPA/MF definitive-authorisation register
Block onboarding of accounts whose declared activity is fixed-odds betting and whose owner does not appear on the register
Report patterns of transfers to unauthorised operators via the SISCOAF channel and to the SPA/MF supervision desk
Portaria 566/2025 is the financial-rail counterpart of the ANATEL blocking regime and the basis for the 1,255 institutional communications reported in the SPA/MF first-year balance.
Tributação e responsabilização solidária 1
Lei Complementar 224/2025
Lei Complementar 224/2025: joint and several tax liability for promoters, affiliates and financial institutions of unauthorised operators
Bonus & Ads
Lei Complementar 224 of 2025 established joint and several liability for those who promote unauthorised betting operators. Influencers, affiliates, media outlets and financial institutions that, after formal notification, continue to promote operators without SPA/MF authorisation may be called to answer for the taxes owed by the illegal operator. The provision entered into force in January 2026. Several taxpayers obtained TRF injunctions challenging downstream effects of LC 224/2025 on the lucro presumido regime.
Requirements
Implement a notification-tracking system so a single SPA/MF or Receita Federal notice automatically suspends all promotion of the named operator
Treat any post-notification ad spend, affiliate clicks or payments handled for an unauthorised operator as a joint-and-several tax exposure
If acting as a payment institution, freeze settlement to operators flagged by the SPA/MF immediately on notification
LC 224/2025 changes the cost-benefit calculus for the entire affiliate, influencer and payments ecosystem: even a brief continuation of promotion after notification crystallises tax co-liability, which is far harder to negotiate than an administrative fine.
Jurisprudência constitucional 2
STF ADI 7.721 — cautelar Bolsa Família / BPC
STF ADI 7.721: prohibition on registration of Bolsa Família and BPC beneficiaries maintained; operational obligations to block existing accounts suspended pending conciliation
RG Critical
On 19 December 2025 Minister Luiz Fux, rapporteur of ADI 7.721, kept in force the SPA/MF prohibition on new registrations of beneficiaries of the Bolsa Família programme and of the Benefício de Prestação Continuada (BPC) on fixed-odds betting platforms, but suspended the operational obligations to block existing accounts and to close accounts already opened by those beneficiaries pending a conciliation hearing scheduled for 10 February 2026.
Requirements
Maintain the onboarding block on Bolsa Família and BPC beneficiaries; the cautelar did not touch this
Hold any operational programme to close existing accounts of beneficiaries until a final STF decision
Document compliance with both elements of the cautelar to demonstrate good faith to SPA/MF supervisors
ADI 7.721 is the first STF intervention into the Lei 14.790 operational layer. The split (onboarding block in, closure of existing accounts out) signals that the Court accepts player-protection measures going forward but is sensitive to mass account-closure as a possible disproportionate measure.
STF ADI 4.986 / ADPF 492 / ADPF 493 — Union lottery monopoly
STF rules in ADI 4.986, ADPF 492 and ADPF 493 that the Union does not hold an operational monopoly on lotteries, while retaining exclusive legislative competence
RG Critical
In the joined judgements of ADI 4.986, ADPF 492 and ADPF 493 the Supreme Federal Tribunal held that the Union does not hold a monopoly on the operation of lottery services and that states may operate their own lotteries, while the Union retains exclusive legislative competence to define the framework. The decision is the constitutional underpinning of the subsequent federal-state coexistence model and conditions the legality of state-level fixed-odds frameworks that have proliferated since 2024.
Requirements
Map every state-level lottery or fixed-odds framework against Lei 14.790 to identify operational overlaps and contradictions
Maintain a constitutional-references register tracking ADI 4.986, ADPF 492 and ADPF 493
Brief executive leadership on the residual constitutional risk of state-level supply expansion
The ADI 4.986 / ADPF 492 / ADPF 493 line is the doctrinal source of the federalisation tension that continues to play out in 2025-2026 around state lottery operations and explains why SPA/MF action against state-licensed operators is exposed to constitutional challenge.
Ações conjuntas — aplicativos e lojas 1
MJSP notification to Google and Apple
Ministério da Justiça notifies Google and Apple to remove illegal betting apps from Brazilian app stores
RG Critical
The Ministério da Justiça e Segurança Pública, via SENACON, notified Google and Apple to remove illegal betting applications from their Brazilian app stores, following coordinated SPA/MF enforcement against unauthorised operators. The notification operationalises consumer-protection obligations under the Código de Defesa do Consumidor and Lei 14.790, and complements the ANATEL URL-blocking pipeline by removing the app-distribution channel.
Requirements
Monitor Google Play and Apple App Store listings for the operator's brand and immediately flag any unauthorised mirror app
Submit takedown requests through the operator's verified developer accounts to pre-empt MJSP-initiated removals that may capture authorised mirrors by error
Maintain evidence of authorisation status to present to platform compliance teams
The MJSP/SENACON channel is the third leg of the unauthorised-market suppression stool (ANATEL for URLs, BCB and Portaria 566/2025 for payments, MJSP for app stores). Operators should expect all three to be activated together against named unauthorised brands.
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