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Key facts (as of 29 October 2026)
The ban: Medida Provisória 1.394, published in an extra edition of the official gazette on 25 September 2026, prohibits the operation, offer, intermediation and advertising of fixed-odds betting in Brazil. That includes bets on real sports events and on virtual events of online games, and applies "even when carried out by an agent based abroad" offering bets to people in Brazil (Art. 1).
Licences: federal authorisations under Law 14.790/2023 end 30 days after publication, with no refund of the licence fee and no compensation (Art. 4). State lottery permissions end on the same timetable (Art. 2).
Payments: financial institutions, payment institutions and payment-arrangement participants, "including instant payment", may not process, settle or enable transactions for fixed-odds betting, except those needed to wind down and refund bettors (Art. 14).
Refunds: on 6 October the Ministry of Justice reported that R$1.325bn still awaited return to about 26.5 million bettors (citing the Ministry of Finance's SPA), with banks to refund between 9 and 14 October. 6 October was the first day without the 188 previously authorised sites; one was still online and had been referred for blocking (Ministry of Justice).
Concentration: BTG Pactual provided banking to 14 licensed operators representing about 70% of the market (15M, 30 September 2026).
In Congress: as of 28 October 2026 the joint committee had been designated (30 September) but not yet installed; amendments closed on 13 October; the initial 60-day period ends on 23 November 2026, extendable by 60 days (Congresso Nacional).
WarningA provisional measure has force of law from publication but must be converted by Congress to survive. Under Brazil's constitution it lapses if not converted within 60 days, extendable once by 60 (Constitution, Art. 62). Check its status before relying on any detail here.
What MP 1.394 does
| Article | Content |
|---|---|
| Art. 1 | Bans fixed-odds betting, including by foreign operators targeting people in Brazil; other lottery types authorised by law are not covered |
| Art. 4 | Federal authorisations end after 30 days; no refund of the licence fee or compensation |
| Art. 6 | No new authorisations; pending applications fall away |
| Art. 7 | Sites and apps offline within 10 days; no new money into transactional accounts; open bets void with full refund; settled winnings payable |
| Art. 8 | Within 2 days after going offline, operators ensure liquidity and send banks a list of bettors by CPF, amounts and source accounts; fine of R$200,000 a day for non-compliance |
| Art. 9 | Banks refund within 7 days to an active account in the bettor's name, preferably the source account; unrefundable amounts go to a Caixa Econômica Federal account |
| Art. 10 | AML, responsible gambling and record-keeping obligations survive; records kept at least five years |
| Art. 14 | Banks, payment institutions and arrangement participants may not process betting transactions |
| Art. 15 | Central bank to set up a system to reject and return interbank instant-payment funds linked to illegal betting |
| Art. 16 | Advertising and sponsorship banned; material removed within 10 days |
| Art. 22 | Internet platforms, app stores and operating systems face fines up to 10% of the group's Brazilian turnover; without turnover, R$10 to R$1,000 per registered user, capped at R$50m per infringement |
| Art. 23 | Ministries may order site blocking through Anatel and CGI.br |
Source: Planalto, MP 1.394 (25 September 2026).
The refund flow
sequenceDiagram
participant Op as Operator
participant SPA as Ministry of Finance (SPA)
participant Bank as Bank holding transactional account
participant B as Bettor
Note over Op: Day 0: MP published, no new deposits
Note over Op: Day 10: sites offline, open bets void
Op->>Bank: Within 2 days: list of bettors by CPF, amounts, source accounts
Op->>SPA: Same list plus proof of funds
Bank->>B: Within 7 days: refund to active account in bettor's name
Bank->>SPA: Report of refunds made and failed
Bank->>Bank: Unrefunded balances to Caixa accountTimeline
| Date | Event | Source |
|---|---|---|
| 29 Dec 2023 | Law 14.790 creates the licensed fixed-odds market | Planalto |
| 25 Sep 2026 | MP 1.394 published; ban takes effect | Planalto |
| 30 Sep 2026 | BTG reported as banker to 14 operators with about 70% of the market | 15M |
| 5 Oct 2026 | Voluntary withdrawal window closes at 23:59 | Ministry of Justice |
| 6 Oct 2026 | First day without the 188 authorised sites; R$1.325bn awaiting return | Ministry of Justice |
| 9–14 Oct 2026 | Banks refund bettors; unrefundable sums then go to Caixa | Ministry of Justice |
| 13 Oct 2026 | Deadline for amendments in Congress | Congresso Nacional |
| 25 Oct 2026 | Licences end, 30 days after publication | Planalto; 15M |
| 23 Nov 2026 | Initial 60-day period for Congress ends (extendable by 60) | Congresso Nacional |
What it means for payments
| Party | Impact |
|---|---|
| Operators | Revenue stops; must fund refunds; obligations survive |
| Banks holding transactional accounts | Run refunds; report to the ministry |
| PSPs and acquirers | Stop processing betting transactions; manage reserves and disputes |
| Pix participants | Must comply; central bank to build a reject-and-return mechanism |
| Affiliates and suppliers | Lose income; receivables at risk |
| App stores and platforms | Must remove betting apps and content |
WarningWhen a market closes, stablecoins are not a way back in. MP 1.394 explicitly covers foreign operators serving people in Brazil, and bans intermediation as well as operation. The right response is to stop serving the market.
NoteThe lesson for PSPs elsewhere is concentration risk. A single market can go from licensed to banned in a day, with payment providers named as the enforcement point. Treat each regulated market as a revenue line that can stop.
Lessons for operators and PSPs
- Map exposure by market. Know what share of volume, reserves and receivables depend on each country.
- Keep wind-down playbooks. Brazil gave ten days to go offline and two days to send refund lists.
- Segregate player money. Refunds ran from transactional accounts; segregation made the process possible.
- Diversify banks. One bank served about 70% of the market by share.
- Plan for reserve releases and disputes. An acquirer may hold reserves longer when a market closes, to cover chargebacks. See Rolling reserves.
- Respect finality limits. Even instant rails are getting return mechanisms for illegal betting. See Settlement finality.
Illustrative example: a PSP's exposure
Illustrative example. The PSP and figures are invented.
A PSP processed Pix deposits for three Brazilian operators, 35% of its revenue. On 25 September it stops new deposits for those merchants, keeps payout rails open only for refunds the operators instruct, and reconciles balances daily. Its acquirer extends the hold on a R$4m reserve while chargebacks and disputes run off. The PSP cuts staff costs, writes off one unpaid invoice, and adds a market-closure clause and a concentration limit to its risk policy.
Q/A
Does the ban cover online casino as well as sports betting?
It covers fixed-odds bets on real sports events and on virtual events of online games, defined as games where the result comes from a random generator.
Can offshore operators keep serving Brazilians?
No. Article 1 covers agents based abroad who offer bets to people in Brazil.
What happens to bettors' balances?
Operators fund refunds; banks pay them to an active account in the bettor's name, preferably the source account, within seven days of receiving the list.
Are other lotteries banned?
No. Other lottery types authorised by law are not covered (Art. 1 §2).
Could the measure change?
Yes. Congress must convert it, and 13 October was the deadline for proposed amendments (Congresso Nacional).
What about crypto payments to offshore sites?
Article 14 bars regulated payment players from enabling betting transactions, and Article 1 bans intermediation. Serving the market by any rail is unlawful.
Sources
- Planalto, Medida Provisória 1.394 (25 September 2026): https://www.planalto.gov.br/ccivil_03/_ato2023-2026/2026/mpv/mpv1394.htm
- Ministério da Justiça, bets offline: https://www.gov.br/mj/pt-br/assuntos/noticias/bets-fora-do-ar-plataformas-cumprem-determinacao-e-encerram-apostas-no-brasil
- 15M, payments and fintech news (BTG item 30 September; licences lapse item 26 October 2026): https://15m.com/news/payments-fintech/
- Congresso Nacional, MPV 1394/2026 status: https://www.congressonacional.leg.br/materias/medidas-provisorias/-/mpv/175871
- Constitution of Brazil, Art. 62 (provisional measures): https://www.planalto.gov.br/ccivil_03/constituicao/constituicao.htm
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