Brazil fixed-odds betting: restrictions and historical licences

Brazil should not be presented as an open fixed-odds licensing opportunity. As checked on 31 October 2026 UTC, Medida Provisória nº 1.394/2026 prohibits the operation, offering, intermediation and advertising of fixed-odds betting. It also prohibits new authorisations; existing authorisations terminate 30 days after publication on 25 September 2026. S1 MP 1394 official text

What is prohibited and what remains uncertain

The measure covers relevant sports betting and defined online games, including offshore operators serving people physically in Brazil. State and Distrito Federal authorisations are not an exception. Other statutory lottery categories are not automatically prohibited by this provision. A foreign licence does not provide an alternative route around the restriction. S1 MP 1394 official text

This Medida Provisória has immediate legal effect but is not a permanently settled Act of Congress. The congressional record showed committee installation pending and an original consideration period ending 23 November 2026. That date is not a guaranteed expiry or reopening date. Later legislative and judicial developments can change the position. S3 Congress status

The STF scheduled a public hearing in ADI 8027 for 3 November 2026 at 10:00 a.m. Subsequent procedural orders dated 27 and 28 October expanded the invitations and set participation arrangements; they did not suspend MP 1394. In the public docket entries and decisions inspected for ADI 8024 and ADI 8027 at 02:22 UTC on 31 October 2026, we did not identify an order suspending the measure. This is a time-specific finding from those records, not a prediction of the Court’s eventual ruling. S4 STF hearing notice · S5 STF ADI 8024 docket · S5b STF ADI 8027 docket · S5c STF hearing order · STF — 28 October hearing arrangements

Which major brands held historical authorisations

Secretaria de Prêmios e Apostas do Ministério da Fazenda (SPA/MF) now frames its operator table as authorisations before MP nº 1.394/2026. The following exact brand–entity relationships are historical evidence, not a list of current operating permissions. S7 SPA historical archive · S8 Historical operator table

BET365: HS DO BRASIL LTDA, CNPJ 47.123.407/0001-70, Portaria SPA/MF nº 250 of 7 February 2025. BETANO: KAIZEN GAMING BRASIL LTDA, CNPJ 46.786.961/0001-74, Portaria nº 246 of the same date. Their original grants confirm virtual sports betting and regulated online-game scope; they do not establish present validity. S8 Historical operator table · S8a Former BET365 grant · S8b Former BETANO grant

BETFAIR: NSX BETFAIR BRASIL S.A, CNPJ 55.229.080/0001-43, Portaria nº 248 of 7 February 2025, amended by nº 2.291 of 9 October 2025. The archive records bet365.bet.br, betano.bet.br and betfair.bet.br respectively. Those domains identify historical records, not current betting access. S8 Historical operator table

What did the former applicant route require

The historical SPA/MF FAQ described a Brazilian applicant entity and at least 20% Brazilian shareholding. These former eligibility conditions are not a current application route. SPA historical FAQ

The historical SPA/MF FAQ described a 150-day analysis period. It never guaranteed approval in 150 days. The new measure prohibits new authorisations and removes the purpose of pending applications, so that historical procedure is not a currently available application checklist. SPA historical FAQ · S1 MP 1394 official text

What did the historical financial thresholds mean

The former authorisation consideration was R$30 million for five years and up to three brands. Separate requirements were R$30 million paid-in capital, R$30 million net assets and a R$5 million financial reserve. Capital and net-assets tests are not two additional government fees. CAIXA’s historical financial statements also record the capital, net-assets and reserve requirements. SPA historical FAQ

These are historical thresholds, not a current quotation or an assurance of a five-year right. The new measure terminates existing authorisations and contains a non-refund provision for the consideration; any challenge or remedy requires separate current analysis. S1 MP 1394 official text

Why the old 12 percent shorthand is inadequate

Lei Complementar nº 224/2025 amended the former revenue allocation. For the applicable 2026 period, 87% went to operators and 1% to social security alongside the existing 12% statutory allocation: a calculated 13% aggregate allocation. The effective-date rule yields 1 April 2026. The base is statutory receipts after specified deductions, not all stakes and not accounting profit. T1 LC 224 revenue allocation

The historical staging to 14% in 2027 and 15% later is not a post-prohibition operating proposition. These allocations never represented all corporate and local taxes. Historical liabilities may survive cessation; a prohibition does not erase them. T1 LC 224 revenue allocation · S1 MP 1394 official text

For the distinction between a licence and permission in a target market, see prediction markets and regulatory boundaries. These are separate regulatory frameworks, not alternative routes into Brazil.