Regulatory Radar | Fixed-Odds Betting – Ed. 18

Week of October 5 to 9, 2026

This was the first week under the ban. Since Tuesday, no authorized operator has been online, balance refunds have begun, and the dispute has moved to the federal courts and to Congress. Below is what deserves your attention.

Ban in force: sites offline and balance refunds under way

Since October 6, the authorized platforms have gone offline, according to the government (188 in total). The apps were also removed from the app stores. From October 9 to 14, banks are refunding about R$ 1.3 billion in balances held by roughly 26 million bettors. From the 14th, Caixa steps in to handle whatever remains. The government says it has requested the blocking of more than 13,000 illegal sites.

What this means: Operators need to finish sending the required information to the banks, keep records of the refund process and prepare for bettor complaints. The figures come from government bodies and the press. Our search of the Official Gazette (DOU) did not locate the text of the measure, so the timeline should be checked against the official act.

First injunction in favor of an operator, with limits

On Thursday, the Federal Court in São Paulo authorized one operator to resume activity until October 25, subject to 12 conditions, and ordered the authorities not to apply sanctions until that date. The judge refused, however, to suspend the provisional measure and rejected the request to operate until 2029. The Attorney-General’s Office (AGU) said it will appeal. In parallel, the ANJL filed a collective writ of mandamus to preserve its members’ authorizations and is considering a second action.

What this means: The decision points to a path: individual relief in federal courts, temporary and conditional in scope. It is not an automatic precedent, and the Union’s appeal may overturn it. Those holding valid licenses should assess their strategy now, before the picture changes.

Supreme Court: AGU asks for the ban to be kept in full, no decision in sight

The AGU told Justice Luiz Fux it opposes the requests for suspension or for an extended transition. Among other arguments, it cited public health and the Union’s exclusive competence over lotteries. The AGU also acknowledged the risk of bettors migrating to the illegal market, but said this does not justify suspending the measure. Associations, football clubs and Abert asked to take part in the case. According to the press, citing anonymous sources, a decision is expected only after the second round of the elections.

What this means: Do not count on an injunction in the short term. The illegal-market figures used by the government are contested by the industry and tend to be used to justify further restrictions, so the methodology matters. The Supreme Court is a medium-term scenario, not the answer for the coming weeks.

Congress: amendments due October 13 and relaxation under discussion

The deadline for amendments to the provisional measure runs until October 13, and more than 50 amendments have already been filed. Some proposals would keep the casino ban and allow sports betting, others would prohibit only the unlicensed market. The joint committee is expected to be set up only in November. The measure is valid for up to four months, with the clock suspended during the recess, and can be voted on until February 2027. The press reports that part of the Centrão bloc wants to soften the text after the elections.

What this means: The final text may look very different from the current one. Anyone with a position to defend (transition, sponsorships, refund of license fees, sports betting) should speak up before amendments close. We treat the relaxation talk as a political signal, not a forecast.

Enforcement and advertising: the government builds its net

The inter-institutional committee on illegal operation and advertising held its first two meetings on the 7th and 8th. The press reports that the Public Prosecutor’s Office is investigating influencers who promote illegal betting and that the government referred about 40 high-balance accounts to the Federal Police. A Secom technical note allowed the sale of jerseys already manufactured with betting brands, as this does not constitute new advertising. Clubs continue to switch sponsors.

What this means: Advertising is the most visible enforcement front. Advertisers, agencies, influencers and clubs should review current campaigns and contracts. The risk also includes scams by fake betting sites, which exploit the vacuum and the brands of those who went offline.

Looking ahead to next week

• October 13: deadline for amendments to the provisional measure.
• October 9 to 14: banks refund balances; afterwards, Caixa takes over the remainder.
• AGU appeal against the injunction and new operator actions in federal courts.
• On the horizon: October 25, end of the injunction and the second round of the elections.

Our team is available to discuss how any of these topics may affect your business.

This material is for informational purposes only and does not constitute legal advice. The analyses reflect the team’s understanding on the date of publication and may be revised as regulation or case law evolves. For guidance on specific situations, please consult a lawyer on our team. © Souto, Correa Advogados — Gaming & Betting Practice.