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iGaming suppliers in Brazil after the betting ban: What MP 1,394 changes for B2B partners

By Cristina Possamai12 min readigamingbrazil.com ↗
iGaming suppliers in Brazil after the betting ban: What MP 1,394 changes for B2B partners

Key takeaways For iGaming suppliers in Brazil, September 2026 rewrote every contractual assumption made since the regulated market opened on January 1, 2025. On September 14, the regulator tightened rules […] O post iGaming suppliers in Brazil after the betting ban: What MP 1,394 changes for B2B pa…

Key takeaways The market shut down in 30 days. MP 1,394 of September 25, 2026 banned fixed-odds betting nationwide and terminated all federal and state authorizations on October 25, with no refund of the R$30 million license fee. Obligations remain valid even after licenses end. Operators must keep records for at least five years and continue reporting to the regulator via SIGAP, so platform and data contracts cannot simply be terminated. Payments and marketing are addressed. Article 14 prohibits payment institutions from processing betting transactions, and Article 16 bans advertising, marketing, and sponsorship, regardless of the form of remuneration. The outcome is still open. Congress extended the measure on November 11, 2026 and has until early March 2027 to vote, while the Supreme Federal Court is reviewing four pending challenges. For iGaming suppliers in Brazil, September 2026 rewrote every contractual assumption made since the regulated market opened on January 1, 2025. On September 14, the regulator tightened rules on payment flows for unlicensed operators. Eleven days later, Provisional Measure 1,394 (MP 1,394) banned fixed-odds betting nationwide and set a 30-day deadline for each federal and state authorization. This article breaks down the measure, article by article, for platform, payments, marketing, and content suppliers—and what remains unresolved in Congress and at the Supreme Federal Court. What changed in September 2026 September 14: stricter payment controls The Secretariat of Prizes and Bets (SPA) of the Ministry of Finance published Ordinance SPA/MF 2,750/2026 on September 14. According to the Ministry, the ordinance expands procedures to prevent, identify, and stop payment transactions linked to irregular fixed-odds betting, allows account blocking and refusal of new transactions, and replaces Ordinance SPA/MF 566/2025. September 25: MP 1,394 MP 1,394 was published in an extraordinary edition of the Official Gazette on September 25, 2026 and took effect the same day. Article 1 bans the operation, offering, intermediation, and advertising of fixed-odds betting, in physical or online form, including when an operator headquartered abroad offers it to an individual or legal entity in Brazil. The ban covers bets on real sporting events and online games. Article 2 extends the measure to the states and the Federal District, whose concessions and authorizations also expire within the same timeframe. Other lottery products authorized by law are not affected. The measure also repeals most of Law 14,790 of 2023, which created the regulated market, while keeping it applicable to events that occurred during the period in which authorizations were in force. The shutdown timeline DataWhat happenedSeptember 25, 2026MP 1,394 published. No new deposits into betting accounts will be allowed. Advertising and sponsorship are banned, with a 10-day deadline to remove existing material.October 5, 2026Last day for customers to withdraw their balances voluntarily.October 6, 2026OBetting websites and apps must be unavailable.October 6 and 7, 2026OOperators send each customer’s remaining balance to their financial institutions.October 9 to 14, 2026OFinancial institutions return balances to customers.October 15, 2026OCaixa Econômica Federal intervenes if a bank is unable to return the funds.October 25, 2026OFederal and state authorizations expire 30 days after publication.November 11, 2026Federal and state authorizations expire 30 days after publication.March 2027Deadline for Congress to vote on the measure. Sources: MP 1,394 of September 25, 2026; Ministry of Finance timeline, updated on October 7, 2026; Gazeta do Povo and NEXT.io for the congressional dates. From 71 license holders to none The speed of the reversal is clearer in the numbers. Gamblers Connect reported 71 license holders on February 12, 2025, six weeks after launch. By September 2026, at least 85 companies held authorization. Each cost R$30 million, lasted five years, and covered up to three brands—bringing total licensing fees paid to more than R$2.5 billion, according to Metrópoles. Article 4 of the measure provides for the termination of authorizations for reasons of public interest and does not grant operators the right to a full or partial refund of the fee, nor compensation from the State. The government justifies the ban on public health grounds and household finances. Agência Brasil, the public news agency, published official estimates of a R$62.5 billion shortfall in household budgets in 2025 and a social cost of R$38.8 billion per year. Industry figures show the other side of the coin. A study by consultancy LCA for the Brazilian Institute for Responsible Gaming (IBJR), cited by NEXT.io, found that the regulated market supported around 15,500 jobs in 2025 and a supply chain linked to at least 42 economic activities. A preliminary survey by the National Association of Games and Lotteries (ANJL) counted around 3,500 layoffs and 4,167 workers placed on collective leave since the measure was implemented. These are industry figures, and NEXT.io reported that the government has not presented any employment estimate of its own. What MP 1,394 means for iGaming suppliers in Brazil, by category The measure directly mentions operators, financial institutions, advertisers, and internet platforms. Suppliers are affected through these four channels. Gamblers Connect’s directory of B2B iGaming providers groups suppliers the same way—by what they do for an operator—and on November 12, 2026 iHub listed 36 game providers, 14 B2B service providers, 14 payment solutions, and 53 affiliate programs. Platforms and data providers An operator’s obligations did not end when its site went offline. Article 10 keeps regulatory, tax, anti-money laundering, responsible gaming, and sports integrity obligations in force for the period in which the operator was authorized. It also requires that data, documents, and records on customers, bets, financial operations, and prize payments be kept intact and accessible to authorities for at least five years. Article 11 requires operators to continue transmitting data to the SPA through its betting management system, Sigap, covering activity up to the shutdown date, including remaining balances and refunds. Failure to comply with the refund steps set out in Article 8 results in a daily fine of R$200,000. For a platform or player account management provider, this turns an active service contract into a data custody contract. The questions an operator will ask are practical: Who hosts the records? In what format can they be exported? Who maintains the connection to Sigap now that the product is deactivated? How long is access guaranteed after invoices are suspended? Payment providers Payments are the area most directly affected by the ban. Article 14 prohibits financial institutions, payment institutions, and all participants in a payment system—including instant payments—from processing, settling, or enabling transactions intended for fixed-odds betting. The only exception is transactions necessary to wind down operations and refund customers. Payment system operators must include this rule in their own regulations and exclude participants who breach it, and Article 15 requires the Central Bank of Brazil to build an electronic system to reject and return such transfers. The measure also amends what remains of Law 14,790. Institutions must report to Coaf, the financial intelligence unit, transactions linked to an irregular operator. Funds held in blocked accounts may be declared forfeited in an administrative proceeding, without the need for prior court action, and sent to the National Public Security Fund. Under Article 9, institutions holding operators’ transactional accounts had seven days, from receipt of the customer list, to return balances to accounts in each customer’s name. They then had to send the SPA a report of amounts returned and amounts that could not be returned. Affiliates, agencies, and media partners Article 16 bans communication, advertising, publicity, marketing, and sponsorship of fixed-odds betting in any medium. It covers any content that offers, advertises, promotes, or facilitates access to betting and is directed at the Brazilian public, regardless of format or remuneration model—which includes commissioned affiliate content under the rule. Existing advertising and sponsorship branding had to be removed within 10 days. Article 17 exempts content published before September 25 in which betting advertising is incidental. Violations constitute abusive advertising under the Consumer Protection Code. Internet platforms have a duty of care to prevent the circulation of this content, including content created by third parties, and app stores and operating systems must keep prohibited products out of their systems. Article 22 provides for fines of up to 10% of the group’s revenue in Brazil, capped at R$50 million per violation, with suspension or prohibition of the activity reserved for repeat offenses. Content studios and aggregators No article mentions game studios, aggregators, or certification labs. Their exposure stems from Article 1, which bans intermediation as well as operation, and reaches operators abroad that serve people in Brazil. Exposure also stems from Article 23, which provides that the Ministry of Finance and the Ministry of Justice may order website blocking via Anatel (the National Telecommunications Agency) and the .br Domain Management Committee. A supplier whose content or platform remains active on a foreign site that still accepts customers in Brazil should treat this as a legal—not commercial—issue for advisory purposes. Unpaid invoices and canceled contracts The commercial damage extended across the entire supply chain. NEXT.io reported on November 10 that some operators left supplier invoices outstanding after the ban and quoted an executive at an international technology supplier who expects “millions in tax invoices that will never be paid.” The same report described contract cancellations with suppliers, with companies treating the ban as force majeure. Three administrative steps are common to all supplier categories. First, reconcile receivables on two dates: September 25, when new deposits were halted, and October 25, when authorizations ended. Second, review termination, force majeure, and data return clauses in light of Articles 10 and 11, because an operator that still has reporting obligations needs certain services. Third, keep certification files, integration documents, and audit evidence organized. This is general information, not legal advice, and the situation in each contract depends on its terms and the applicable law. Status in Congress and at the Supreme Federal Court A provisional measure has the force of law from publication, but it lapses unless Congress converts it into law. On November 11, 2026, the president of Congress, Senator Davi Alcolumbre, extended MP 1,394 for a further 60 days, Gazeta do Povo reported. Taking the parliamentary recess into account, NEXT.io expects the vote to take place by March 4, 2027. Lawmakers submitted 99 amendments, and NEXT.io reported that several would keep sports betting while restricting online casino games. The Supreme Federal Court (STF) has four challenges to the measure under review. Justice Luiz Fux chaired a public hearing on November 3, to which 26 participants were summoned, including industry associations ANJL and IBJR, the Office of the Prosecutor General, the Ministry of Finance, and football clubs, Gamblers Connect reported. On November 9, he stayed proceedings against the ban in lower courts until the STF rules, after a federal appellate court briefly restored one operator’s authorization. No date has been set for the decision. Three scenarios suppliers can prepare for: The ban becomes law Brazil becomes a closed market. Obligations under Articles 10 and 11 are fulfilled, and the remaining work consists of record retention, final reporting, and collections. A partial reopening Several amendments point to the return of sports betting without online casino games. Sports betting, data, payments, and identity suppliers would re-enter the tender processes, regardless of the conditions set by the new text. Casino content suppliers would not. The measure lapses If the measure is rejected or not voted on in time, it loses effect. Article 62 of the Constitution gives Congress 60 days to regularize, by legislative decree, the legal relationships created while the measure was in force. Without a decree, acts carried out under the measure remain governed by it. It is still unclear whether and how the terminated authorizations will be restored. In all cases, the assets that retain their value are the same: certified versions of products, hands-on knowledge of SIGAP reporting, reconciliation against the volumes produced by Pix, and a documented compliance track record. What happens next? For iGaming suppliers in Brazil, the next decision points are the STF ruling, which still has no set date, and the congressional vote, expected in early March 2027. Until one of these bodies changes the text, MP 1,394 remains in force and the betting ban in Brazil applies to operators, payment institutions, advertisers, and platforms. Gamblers Connect is tracking the changes, the court case, and every SPA notice in its coverage of iGaming news in Latin America. Frequently asked questions Is online betting legal in Brazil after MP 1,394? No. Since September 25, 2026, the operation, offering, intermediation, and advertising of fixed-odds betting have been prohibited nationwide, both online and in person, and all federal and state authorizations were terminated on October 25, 2026. The measure remains in force while Congress decides whether to convert it into law, with a vote expected in early March 2027. Do operators still have obligations after their authorization ends? Yes. Article 10 keeps regulatory, tax, anti-money laundering, and responsible gaming obligations in force for the authorized period and requires records to be kept for at least five years. Article 11 requires the continued transmission of data to the SPA (State Administration of Public Bets) through SIGP (Integrated Public Betting System) relating to activity up to the shutdown date. Which suppliers does MP 1,394 mention directly? Financial and payment institutions, under Article 14; anyone involved in advertising, marketing, or sponsorship, under Article 16; and internet application providers, app stores, and operating systems, under Articles 19 to 22. Platform providers, game studios, and aggregators are not mentioned and are covered by the general ban on operating or intermediating fixed-odds betting. Sources: Provisional Measure 1,394, of September 25, 2026 (full text). Chamber of Deputies, September 25, 2026. Provisional Measure 1,394/2026: understand the new rules for fixed-odds betting. Brazil’s Ministry of Finance, Secretariat of Prizes and Bets, updated on October 7, 2026. SPA publishes ordinance to tackle the illegal betting market. Ministry of Finance, September 15, 2026. Brazil bans online gambling; bettors to receive refunds. Agência Brasil, September 28, 2026. MP bars the return of R$2.5 billion paid by betting firms to operate legally. Metrópoles, September 25, 2026. Brazil’s betting ban hits entire supply chain: The price nobody calculated. NEXT.io, November 10, 2026. Alcolumbre extends for 60 days the MP that bans betting in Brazil. Gazeta do Povo, November 11, 2026. Brazil’s Supreme Court Sets November 3 Hearing On Betting Ban And MP 1.394/2026. Gamblers Connect, October 27, 2026. Brazil Supreme Federal Court Holds Public Hearing To Address Economic And Legal Repercussions Of Online Betting Ban. Gamblers Connect, November 4, 2026. Brazil License Holders Increase To 71 After 21 New Approvals. Gamblers Connect, February 12, 2025. iHub directory, profile counts by category. Gamblers Connect, November 12, 2026. O post iGaming suppliers in Brazil after the betting ban: What MP 1,394 changes for B2B partners apareceu primeiro em iGaming Brazil.