ANJL challenges Comsefaz method for measuring Brazil’s betting market

Brazil has another round of the same argument regulators and operators keep having: how much money is actually leaving households and how much of that is just being counted badly. The immediate issue is a Comsefaz study, but for PSPs and merchants in high-risk verticals the real question is more practical: what data set is being used, and does it actually describe betting rather than a broader payments universe?

1. Comsefaz, the Commission of Finance, Revenue and Taxation Secretaries of the States and the Federal District, published a study that SBC Notícias Brasil reported publicly on 6 August. It said that in 2025 Brazilian families sent about 62.5 billion reais, or about 12.250 billion dollars at an exchange rate of roughly 5.10 reais per dollar, to betting companies after subtracting what those same families received back.
2. The study was based on transfers tracked through Pix, Brazil’s instant payments rail, which handles a large share of the country’s digital transactions. ANJL, the National Association of Games and Lotteries, says that is where the methodology starts to drift: the tracked transfers were not limited to bookmakers, but to a broader set of legal entities classified under four headings — arts, culture, sports and recreation.
3. According to ANJL, that wider bucket includes dozens of entertainment providers that have nothing to do with online gambling, which would inflate the final number. The association also says Comsefaz used the wrong time frame and ignored a basic point: banked consumers in Brazil have adopted Pix for all kinds of spending, not only for bets.
4. The strongest counterpoint from ANJL comes from the Secretariat of Prizes and Betting of the Ministry of Finance (SPA/MF), the sector regulator. Its records show that gross gaming revenue, or GGR, for betting houses in Brazil in 2025 was about 37 billion reais, or about 7.255 billion dollars.
5. That means the SPA/MF number is a little more than half of the loss figure attributed by Comsefaz. ANJL says that gap is enough to reject the study’s conclusion as unsupported, and it adds another missing piece: the illegal market. The association cites SPA/MF figures to show the scale of unauthorized operations, although the excerpt provided here cuts off before those numbers are stated.