Brazil's Secretariat of Prizes and Betting (SPA) has set out how former fixed-odds betting operators can use their financial reserves to repay customers left unpaid after the national betting ban.
The instruction also establishes a separate route for operators to recover unused reserves once their restitution obligations are complete.
Under the rules published in the Federal Official Gazette, an operator may request access to its reserve if the money it placed with institutions holding betting transaction accounts is insufficient to refund all affected bettors.
SPA approval is required before any reserve assets can be moved.
The operator must submit a request and a declaration from its administrators. It must also give the bank holding the reserve an individual list of bettors and the amounts due.
The SPA will compare that request with unpaid-balance data submitted by transaction-account institutions through its betting management system, SIGAP.
Any approval is limited to the verified shortfall. The custodian can then liquidate reserve assets up to that amount and transfer the proceeds to an account designated by Caixa Econômica Federal. Those funds remain reserved for customer repayments, rather than returning to the operator.
Operators cannot use the reserve to meet payroll, taxes, administrative costs or other expenses linked to shutting down. The instruction also says that permission to draw on it does not certify that the operator complied with earlier rules governing customer money.
Brazil introduced the reserve requirement in 2024 as protection against operator insolvency or a shortage of liquid funds. Licensed operators had to maintain at least BR$5m (US$895,000), held by a financial institution in federal Government securities.
The new procedure addresses how that safeguard operates after the closure of the fixed-odds market.
A second procedure allows an operator to request release of the remaining reserve after refunds are completed and no known obligations to bettors remain. Its application must include audited accounts for 2025 and a financial position dated 31 October 2026 or later, together with a separate auditor assurance report.
The SPA must approve release before the custodian can return the money to an account controlled by the operator.
The reserve rule provides a controlled source of funds where ordinary customer repayments fall short.
SPA appoints sanctions coordinator
In a separate personnel order published on 10 November, the SPA designated Alessandro Guimarães Pereira General Coordinator of Sanctioning Action within its Sanctioning Action Subsecretariat. The appointment took effect on publication.
Earlier in the closure process, the SPA set a 15 December deadline for former operators to settle their remaining financial and regulatory obligations.
False, inaccurate or omitted information in a reserve application can expose those responsible to administrative, civil and criminal sanctions
