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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.
Comprehensive coverage
171 Standards
675 Requirements
0 Flagged
5 Categories
Showing all 171 standards
1
Theme 1

Constitutional & jurisdictional framework

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 standards 7 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
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 The 1946 prohibition has never been formally repealed and continues to outlaw land-based casinos, bingo and similar games; the modern federal regime only authorises specific lottery modalities.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 standards 6 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
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. 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 standards 11 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
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 Critical Player 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 Rights Game 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 Critical Player 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 standards 14 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
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 Critical Player 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 Critical Game 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 Critical Bonus & 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 Critical Player 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 Critical Player 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 Critical Player 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 Critical Player 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 standards 10 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
Lei 14.790/2023 art. 9, parágrafo único

Statutory basis for self-exclusion

RG Critical Player 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

Centralised cross-operator self-exclusion register

RG Critical Player Rights

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 Critical Bonus & 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 Critical Player 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 Critical Player 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 Critical Player 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 Critical Player 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 standards 11 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
Lei 14.790/2023 art. 22

Statutory principles of betting advertising

Bonus & Ads Affiliate 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 & Ads RG 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 Rules Bonus & 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 & Ads RG 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 standards 8 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
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 standards 15 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
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 Design Player 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 Design Player 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 Design RG 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 Design RG 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 standards 11 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
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 Critical Player 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 Critical Player 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
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.

Requirements
  • screen_bettors_against_un_ofac_brazilian_sanctions_lists
  • freeze_accounts_on_sanctions_hit
  • escalate_hits_to_compliance
  • perform_ongoing_screening
Portaria SPA/MF 1.143/2024 art. 13

Transaction monitoring

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 standards 9 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
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 Rules Bonus & 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.
12
Theme 12

Supervision, enforcement & illegal-market suppression

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 standards 20 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
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
  • Negotiate clear, time-bound remediation commitments
  • 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.
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.
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.
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.
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.
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.
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.
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.
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.