Brazil's Brazilian Institute of Regulatory Law (IBDRE) has criticised Provisional Measure 1.394/2026.
The institute argues that it marks a sharp departure from the framework built around fixed-odds betting. This comes as industry groups have separately taken their challenge to Brazil's Supreme Court.
The institute noted that Brazil has spent the past few years bringing a largely unregulated market into the fold. Under Law 14.790/2023 and subsequent Ministry of Finance rules, licensed operators must meet requirements on authorisation, taxation, player identification, responsible gambling, anti-money laundering, sports integrity and reporting.
The new measure would end existing authorisations, concessions and permissions within 30 days, and take betting systems offline within 10.
It would also ban betting advertising, marketing and sponsorships, and operators would receive neither a refund of licence fees nor any compensation from the government.
IBDRE said the pace and scale of the change raises questions over legal certainty, legitimate expectations and proportionality. Operators were granted five-year federal licences after paying BR30m in fees, and many have invested heavily in technology, compliance, staff and commercial infrastructure.
Consumer protection is another concern. The regulated market has brought in tools such as SIGAP (System of Management for Bets), player identification, centralised self-exclusion, transaction traceability and anti-money laundering monitoring.
According to IBDRE, more than one million Brazilians had used the centralised self-exclusion mechanism on licensed platforms by September 2026.
If demand for betting continues once licensed platforms close, the institute warned, some consumers may turn to offshore or clandestine operators, where none of those safeguards apply.
415 new unlicensed betting sites appeared in Brazil within two days of the provisional measure banning fixed-odds betting and casino games
