Talk to us

Brazil switched off betting. Free-to-play is what’s left standing.

Provisional Measure 1,394 ends Brazil’s regulated sports betting and online casino market less than two years after it opened. Thirty million players don’t disappear with it. Here is what changed, what survives, and how to build in what remains without becoming part of the problem.

By , Chief Operating Officer6 min read

On 25 September 2026, President Lula signed Provisional Measure 1,394. It prohibits the operation, offer, intermediation and advertising of fixed-odds betting anywhere in Brazil, covering both bets on real sporting events and online games of chance, and it applies to operators based abroad who take Brazilian customers.

Brazil’s regulated market opened in January 2025. It is closing in October 2026.

This piece sets out what the measure does, why the government says it acted, what the fallout looks like, and where free-to-play fits now. It reflects the position on 1 October 2026. The measure still has to pass Congress, and nothing here is legal advice.

What the measure does

The text is short and blunt:

  • Deposits stopped on publication. No new money can enter betting accounts.
  • Sites and apps go dark ten days after publication, including in app stores, on pain of blocking. Bets still open at that point are void and stakes are refunded in full.
  • Every authorisation granted under Law 14,790/2023 is extinguished after thirty days, including state and district licences. The measure says expressly that operators get no refund of the licence fee they paid and no compensation.
  • No new authorisations, and pending applications fall away.
  • Other lottery products are untouched. The ban is aimed at fixed-odds betting, not at every lottery modality the law allows.

As a provisional measure it has immediate force, but Congress has 120 days to approve, amend or reject it, and debate is expected to wait until after the election. The first round is on 4 October.

Why the government says it acted

Ministers framed it as a public-health and household-debt measure. Reported government figures put online bettors at around 30 million people, with the Health Ministry saying 10.9 million showed risky or problematic gambling patterns in 2023, and treatment for pathological gambling rising by around 140% between 2018 and 2025.

It also lands days before a tight presidential vote, with polling showing strong public support for a ban, and opponents calling it electioneering. Both things can be true at once. For anyone building in this market, the motive matters less than the direction: Congress was already moving the same way. A Senate committee approved a near-total ban on betting advertising and sponsorship on 2 September, and other bills proposed repealing the betting law outright.

The fallout

  • Operators. 85 licences were granted at R$30 million each. That is R$2.55 billion paid for authorisations that will end within a month, with no refund on offer.
  • Tax. Betting was one of the fastest-growing lines in federal revenue: the GGR tax rate rose from 12% to 18% in October 2025, and collections in January to April 2026 were almost double the same period of 2025.
  • Football. Clubs took around R$1.1 billion from betting sponsors in 2025. Shirt fronts, stadium boards and broadcast inventory now need new buyers within days.
  • Prediction markets were already gone. From 4 May 2026, National Monetary Council Resolution 5,298 barred derivatives on sporting, electoral and entertainment events, and Anatel began blocking platforms including Polymarket and Kalshi in April.
  • The illegal market. Industry bodies warn that demand will move offshore rather than vanish. They have an obvious interest in saying so, and they may also be right. Either way, the enforcement burden now sits with blocking and payments.

What is still standing

Three things remain lawful, each with its own conditions.

Fantasy sport. Article 49 of Law 14,790/2023 says fantasy sport is not a lottery, a commercial promotion or a fixed-odds bet, and needs no public authorisation. The provisional measure revokes much of that law, but not Article 49. The exemption only covers products that meet the statutory definition:

  1. Virtual teams of at least two real people, where performance depends on knowledge, statistical analysis, strategy and skill.
  2. Rules set in advance.
  3. A guaranteed prize that doesn’t depend on the number of entrants or the entry fees collected.
  4. Results that don’t turn on a single person’s performance in a real event.

Commercial promotions. Prize draws, contests and similar giveaways used to promote a brand remain legal under Law 5,768/1971, with prior authorisation from the Prizes and Betting Secretariat. A new enforcement ordinance for promotions came into force on 29 June 2026, so this is a supervised route, not a loophole.

Genuinely free-to-play. No stake, no purchase, no cash-equivalent prize: predictors, quizzes, streaks and leagues played for bragging rights or for prizes run as authorised promotions.

What is not standing: anything where money goes at risk on a sporting event or a random outcome, however it’s dressed. The measure defines online games by their use of random generation, so a casino-style product doesn’t become legal by swapping cash for a token that can be bought or redeemed.

The free-to-play opportunity

The ban removes the product. It doesn’t remove the audience, the fixtures, the clubs or the advertisers.

  • Thirty million people who follow sport with an opinion on the result. That interest is the reason predictor games, fantasy leagues and second-screen formats work.
  • Clubs and rights holders with inventory to fill. Sponsors who replace betting brands want engagement they can measure, not just a logo.
  • Media owners who lose betting ad revenue. Free-to-play formats are content their audiences come back to every matchday.
  • Brands outside gambling. Banks, telecoms, retailers and drinks brands already run promotions around football; a well-built predictor game is a better one.

The opportunity is real, but only for products that are free-to-play in fact, not in branding.

How to build it without becoming the problem

A product launched into this moment will be watched closely. These are the lines we would hold:

  • No stake, no purchase. If money goes in, the product has to fit the fantasy-sport definition exactly, or it isn’t free-to-play.
  • Prizes through the authorised route. Anything of value is a commercial promotion with prior authorisation, or it isn’t offered.
  • No convertible currency. In-game points that can be bought, sold or cashed out recreate the thing the law just banned.
  • Never a funnel. No links, codes or referrals to offshore betting. Beyond being illegal under the advertising ban, it is exactly the harm the measure is aimed at.
  • Adults only, and safer-play anyway. Age assurance, sensible limits on time and frequency, and clear support signposting, even with no money involved.
  • Data handled properly. Brazil’s data protection law (LGPD) applies to every predictor entry and every marketing consent.

What it means for platforms

Brazil just showed how fast a market can change. A licence regime that took years to build was switched off in a sentence, with ten days’ notice.

Platforms that hard-code a market into their product spend those ten days rebuilding. Platforms that treat market policy as configuration can turn a product off, keep the brand, and switch on what’s still allowed. Platforms that keep different kinds of value separate in the ledger can run a free-to-play product with no cash anywhere in it and prove that to a regulator.

That is how we build. If you’re weighing what to do in Brazil now, whether that’s a club, a rights holder, a media owner or an operator with an audience and no product, talk to us.

Sources

Related insights

Let’s talk about what you’re building.

Tell us what you’re building. We’ll tell you plainly what the platform does today and what it would take.

Talk to us