Betting Advertising Under Heightened Enforcement During the 2026 FIFA World Cup

Summary. The Secretariat of Prizes and Betting of the Ministry of Finance (SPA/MF) has issued Technical Note SEI No. 3620/2026, dated June 3, 2026, addressed to authorized fixed-odds betting operators, concerning communication, advertising and marketing activities during the 2026 FIFA World Cup (June 11 to July 19, 2026). The Note does not create new obligations, but reinforces the rules in force and announces coordinated and heightened enforcement throughout the tournament.

What the SPA/MF communicated

The Technical Note reaffirms the set of duties already established under Law No. 14,790/2023 (notably Articles 16, 17 and 27, and the penalty regime of Article 39) and SPA/MF Ordinance No. 1,231/2024, in addition to the Consumer Protection Code (Law No. 8,078/1990) and Annex “X” of the Brazilian Advertising Self-Regulation Code (CONAR). The core message is one of enforcement priority: during the 39 days of the World Cup, the SPA/MF, consumer protection agencies (Procons), the Public Prosecutor’s Office, Public Defenders and CONAR will, according to the Note itself, pay “heightened attention” to advertising in the sector.

Points requiring immediate review

• Mandatory warnings. The “18+” notice and the gambling-disorder risk warning must be clear, legible and occupy at least 10% of the size or length of the advertisement (Article 13, §1, of Ordinance 1,231/2024), preferably in both spoken and written form.
• Authorization number. Every advertising piece must display the number of the SPA/MF ordinance that authorized the operator (Article 15, §3).
• Liability for affiliates and influencers. The operator is jointly and severally liable for the actions of its affiliates (Articles 21 and 22), which requires a written contract in Portuguese and active monitoring of the content disseminated.
• Prohibited content. Appeals to easy gains, “calls to action” prompting immediate betting, associating betting with personal/financial success or with celebrities suggesting such success, and any targeting of children and adolescents are prohibited (Article 12).
• Apparent age. Individuals shown betting in advertising must be and appear to be over 21 years of age.
• Cross-border campaigns. Global content accessible or residually directed to Brazilian consumers must comply with national rules; offers from operators not authorized in Brazil must be blocked to local bettors.

Why this increases risk

Although the Technical Note is a guidance instrument — penalties arise from Law No. 14,790/2023 and Ordinance No. 1,231/2024, not from the Note itself —, it documents unequivocal awareness of the requirements by market participants. This element is legally relevant to the administrative offenses under Article 39, items X and XII, of Law No. 14,790/2023, which penalize maintaining a relationship with, or disseminating, boosting or monetizing content associated with, an unauthorized operator where there is awareness of the irregularity.

Recommendations

• Immediately review the entire World Cup campaign pipeline — both own and affiliate/influencer campaigns — before June 11.
• Audit pieces for warnings (≥10%), the authorization number, and the absence of “calls to action” and easy-gain appeals.
• Strengthen contractual clauses and processes for prior approval and monitoring of affiliates and influencers.
• Retain factual support for advertising messages — the burden of proving truthfulness lies with the sponsor (Article 38 of the Consumer Protection Code).
• Maintain reinforced customer service and ombudsman channels throughout the event.

The Gaming & Betting team at Souto Correa Advogados remains available to clarify any questions.