ANJL and IBJR ask Brazil’s Supreme Court to suspend MP 1.394 and cite 833 new illegal betting sites since the ban

The Associação Nacional de Jogos e Loterias (ANJL) and the Instituto Brasileiro de Jogo Responsável (IBJR) have filed a second petition with Supreme Federal Court Justice Luiz Fux, again asking for an injunction to suspend the effects of Medida Provisória 1.394/2026, which banned fixed-odds betting in Brazil. Their core argument is simple enough: the regulated market was shut down “in a few hours,” and the vacuum is already feeding the illegal side of the business.

1. ANJL and IBJR filed the petition on Monday afternoon, September 28, and said it should be considered within the existing cases already assigned to Fux: ADIs 7.721, 7.723 and 7.749, which address Brazil’s betting legal framework. The document also says ANJL has already filed ADI 8027 against the MP.
2. The new filing says ADI 8027 is combined with an Ação Declaratória de Constitucionalidade (ADC) covering Chapter V of Law 13.756/2018 and Law 14.790/2023. The associations want the new case allocated to Fux by prevention, on the basis that the declaratory request concerns the same subject matter as the ADIs he already reports.
3. On substance, the entities argue that the regulated market was “truly extinguished abruptly and in a few hours,” with no grace period for operators to wind down obligations. They warn that if the MP remains in force, the sector will be wiped out “definitively before even being reviewed by Congress.”
4. To support the request for urgency, ANJL and IBJR point to what they call an “exponential and improper increase” in the illegal market over the last weekend. Citing monitoring from the bet-legal.org observatory, accessed on September 28, they say 833 new illegal sites appeared since the prohibition. The filing does not identify who runs the observatory or spell out the methodology behind that count.
5. The petition turns the government’s own consumer-protection logic against the ban. In the associations’ view, pushing bettors into the clandestine market amounts to a “violation of proportionality in the dimension of insufficient protection.” They ask for four layers of relief, starting with a full suspension of MP 1.394 until Congress finishes reviewing it or until the merits of ADI 8027 are decided.

For high-risk payment providers, the detail that matters is not just the constitutional fight. If the regulated market is paused while the illegal market expands, the payment flow does not disappear; it moves, and usually into places PSPs and acquirers do not want to be seen near. That is the part operators and their processors will be watching in Brasília, whether they like the politics or not.