Brazil Gambling Licence Requirements After MP 1,394
Brazil has taken no new licence applications since 25 Sep 2026. The requirements that now apply are wind-down duties under MP 1,394: go dark, refund, report.
The requirements for a Brazilian licence used to fill this page: a Brazilian company, local shareholding, capital, a reserve, certified systems. Since Medida Provisória nº 1,394 took effect on 25 September 2026, no new authorisation can be granted, so none of that is a route into the market any more. The requirements that matter now run the other way. They are the steps an authorised operator must take to leave.
- New applicants face no requirements because there is nothing to apply for (art. 6).
- Licensed operators take sites and apps offline ten days after publication (art. 7).
- Refund money must be secured and player lists sent within two days after that (art. 8).
- Final data goes to the SPA through Sigap, and records are kept for five years (arts. 10 and 11).
Going offline
From the day of publication an operator may not take new money into its transactional accounts. The only exception is money coming back from assets in which player funds were already invested on that date, and only to meet the wind-down obligations (art. 7 §1). Ten days after publication the operator must make its betting sites and apps unavailable, including in app stores, or face blocking (art. 7). Bets whose result is not settled by then are void, and the full stake goes back to the player with no deductions of any kind (art. 7 §2). Players keep the right to prizes on bets settled before that deadline (art. 7 §3).
Refunds
Within two days after going offline, the operator must do three things (art. 8):
| Requirement | What it involves |
|---|---|
| Fund the refunds | Make available and liquid the money for balances, voided bets and prizes owed |
| Instruct the banks | Send each bank holding a transactional account an itemised list of players by CPF, with amounts and source accounts |
| Report to the SPA | Send the same information to the Secretaria de Prêmios e Apostas with proof that the funds are there |
The refund money stays segregated from the operator’s own assets and may not be used for anything else. Missing these steps carries a daily fine of R$200,000 until the operator complies. The banks then pay players within seven days, preferably back to the account the money came from, and report what they paid and what they could not (art. 9).
Reporting and records
Ending the authorisation does not end the operator’s duties for the time it ran (art. 10). Regulatory, tax and payment obligations remain, as do the AML, counter-terrorist-financing, responsible-gaming and sports-integrity duties. The operator must keep answering the authorities’ requests and keep its data and records on players, bets, financial operations and prize payments intact and accessible for at least five years. Through Sigap it must send the SPA its data up to the day it stopped, covering players, bets, prizes, deposits, withdrawals, remaining balances, refunds, revenue and responsible-gaming measures (art. 11). The operator’s contact details with the SPA have to stay current for as long as these duties last (art. 5).
Sanction proceedings not finally decided on 25 September are suspended, and they are closed for good if the operator meets every wind-down duty on time (art. 13). Doing the exit properly is also the cheapest outcome.
Offshore operators with Brazilian players
There is no licence requirement to meet, because the ban itself reaches operators based abroad that offer bets to people in Brazil (art. 1). The practical requirement is to block Brazilian traffic and review payment flows, since banks and payment institutions may not process betting transactions (art. 14) and the authorities can order sites blocked (art. 23).
The measure lapses unless Congress converts it into law within 60 days, extendable once by 60. We will update this page if the position changes. For the measure in full, see our Brazil guide; to compare markets that are still open, book a free consultation.
Frequently asked questions
What are the Brazil gambling licence requirements now?
There are none for new applicants, because Medida Provisória 1,394 of 25 September 2026 bars new authorisations. The requirements that apply now are the wind-down duties the measure places on operators that held an authorisation.
What must a licensed operator do first?
Stop taking new money into player accounts from publication (art. 7 §1), then take betting sites and apps offline, including app-store listings, ten days after publication (art. 7). Bets still open at that point are void and the stakes are refunded in full.
What records does an operator have to keep?
Data, documents and records of the licensed activity, including players, bets, financial operations and prize payments, for at least five years (art. 10), and final reporting to the SPA through Sigap (art. 11).
Do the old Law 14,790 requirements still matter?
For the past, yes. Article 29 repeals most of Law 14,790/2023, but its sole paragraph keeps the old rules applicable to what happened while authorisations were in force and to the wind-down duties.
Sources
This article is for general informational purposes only and is not legal, tax or financial advice. Consult a qualified professional before acting.
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