Regulatory Radar | Fixed-Odds Betting – Ed. 17

Week of September 14 to 18, 2026

The week was dominated by a single theme: the government’s push to restrict, and even ban, betting. It ran from the President’s office to Congress and triggered a coordinated response from the industry. Alongside it, there were concrete developments that call for immediate action: a significant ordinance published in the Official Gazette and two letters from the betting regulator (SPA/MF) demanding proof of the payments owed to sports bodies. Below are the points that deserve your attention.

Government pushes for restrictions and even a betting ban

The story of the week, by a wide margin, was the political escalation against betting. The Executive branch signaled that it is considering issuing a provisional measure (a decree with immediate force of law) to tighten the rules, without ruling out banning segments such as online casino, and statements by the President himself reinforced that message throughout the week. A provisional measure would take effect almost immediately and remain valid for 60 days, renewable. On the other hand, the economic team stated that “no decision has been made”, suggesting the text is not yet settled. As of this edition’s cutoff, nothing had been published, so this remains a signal, not a done deal. The industry’s reaction was organized and swift: football clubs and legal-market associations issued statements warning of the economic impact, defending legal certainty and floating the possibility of challenging in court any rupture of the regulatory framework. Much of the debate rests on market and household-debt figures whose methodologies are being contested by the legal industry’s own associations.

What this means: This is the most uncertain and highest-impact issue of the moment. A provisional measure would change the rules overnight, without the debate time a bill would allow. We recommend closely monitoring the Official Gazette and the government in the coming days, and reviewing now any marketing, sponsorship and product plans tied to at-risk segments, especially online casino. It is still only a signal, but the cost of being prepared is low and the cost of being caught off guard is high. And mind the numbers: inflated figures on the illegal market tend to become the argument for more taxation and more restriction, so the methodology behind them matters.

SPA/MF tightens the financial net around illegal betting

As the political debate unfolded, the betting regulator published in the Official Gazette a new ordinance tightening the blocking of funds tied to irregular betting. The rule now requires banks, payment institutions and acquirers to monitor and report suspicious transactions, creates a list of red flags, and provides for accounts to be blocked within 24 hours, with confirmation within 48 hours. Suspicious accounts are forwarded to the Ministry of Justice, with the risk of forfeiture of the funds. The ordinance replaces the previous rule on the subject and is already in force, although operational details still depend on a complementary instruction.

What this means: This is the most concrete rule of the week. The target is the illegal market, but the burden falls on the payments system, so licensed operators and fintechs should review their contracts with acquirers and their reconciliation flows to avoid being caught by an undue block. Keep an eye on the complementary instruction, which will set the adjustment deadlines.

Payments to sports: SPA warns that, without a defined beneficiary upfront, no market may be offered

The betting regulator sent two letters to licensed operators regarding the payments owed to athletes and sports bodies for the use of their image and trademarks. In the first, the regulator stresses that betting on a competition may only be offered if, beforehand, it is already defined who receives the funds, how they are split, and by which means payment will be made. The absence of the beneficiary’s bank details is no excuse, and offering a market without that prior definition is treated as an irregular situation, subject to enforcement and sanctioning proceedings. In the second letter, the regulator is already demanding that operators prove the payments made to a sports confederation, with a ten-day deadline to respond.

What this means: Enforcement of the sports allocations has moved from paper to practice. Anyone offering sports markets must ensure, before opening a bet, that there is a regulation or instrument defining beneficiaries, allocation criteria and payment method, and must keep documentation organized by competition. It is time to review internal processes for approving events.

Court orders game supplier to cut off unlicensed betting sites

In an action brought by the Public Prosecutor’s Office, the Federal District courts ordered, on an urgent basis, that the maker of a popular betting game stop supplying it to sites operating without a license in Brazil, disclose the domains involved and prove that it monitors its partners. The request to block the game nationwide was denied. The decision is a lower-court ruling, but it stands out for targeting not the betting house itself, but whoever supplies the content to it.

What this means: The message applies to the entire chain. Game suppliers, aggregators and technology providers may be held liable for supplying irregular operators. Supply contracts should provide for verifying the customer’s regulatory standing and for suspension mechanisms.

Enforcement tightens: arrest in a police operation and a stronger sanctioning arm

Enforcement gained muscle during the week. A new phase of a police operation resulted in the arrest of a partner of a well-known betting house, on suspicion of money laundering and related crimes tied to the pre-regulation period. In parallel, the SPA/MF appointed the head of its new subsecretariat dedicated to sanctions and published summonses of companies in administrative sanctioning proceedings.

What this means: The regulator’s enforcement machinery is being built and used. Keeping regulatory documentation in order and responding promptly to notices from the regulator is no longer mere red tape; it is protection against sanction.

Looking ahead to next week

• Closely monitor the Official Gazette and the government regarding a possible provisional measure on the sector, which could be issued at any time.
• Operators have a short deadline to prove to the regulator the payments to sports demanded this week.
• Watch for the complementary instruction that will set the adjustment deadlines under the new financial-blocking ordinance.
• At the Supreme Court, the cases on the validity of the Brazilian Betting Law and on state advertising laws remain pending, with no confirmed trial date.

Against this backdrop, some associations and operators are already organizing to challenge any eventual ban in court, on the grounds of a rupture of the regulatory framework and of legal certainty. Our team is following the matter closely and is ready to represent clients in the appropriate measures, whether in the regulatory debate or in litigation, should the discussion advance.

We remain available to discuss the impact of any of these topics on your business.

This material is for informational purposes only and does not constitute legal advice. The analyses reflect the team’s understanding as of the date of publication and may be revised in light of regulatory or case-law developments. For specific guidance on concrete situations, please consult a member of the team. © Souto Correa Advogados – Gaming & Betting Practice.