CNC’s STF petition on Brazil’s bets ban contradicts its own numbers

The Brazilian National Confederation of Commerce, Goods, Services and Tourism (CNC) filed two petitions with the Supreme Federal Court on 5 October in support of MP 1.394/2026. The problem, as the document itself shows, is that several of its headline claims do not survive contact with the underlying numbers — which matters for PSPs and acquirers because the regulatory case against regulated betting is being built on those figures.

1. “Spending on betting exceeded R$ 30 billion per month” is not supported by the CNC’s own material. The phrase appears in paragraphs 40 and 70, but paragraph 76 reframes the same number as a “flow of around R$ 30 billion per month in bets.” That distinction matters: flow is gross turnover sent to platforms, including amounts later returned as prizes.
2. The CNC’s source list undercuts the R$ 30 billion figure. Item 4 cites a Comsefaz bulletin with an average net outflow of R$ 4.7 billion per month. Item 11 cites the Central Bank: R$ 20.8 billion in gross transfers in August 2024. Official Treasury data put actual spend, or GGR, at R$ 36.9 billion in 2025 — R$ 3.1 billion per month — and R$ 20.07 billion in the first half of 2026, or R$ 3.3 billion per month. In other words, the CNC is inflating actual spend by roughly ten times.
3. “Default caused by the platforms took R$ 143 billion from retail” is also shaky. The period runs from January 2023 to March 2026, but the CNC itself says in paragraph 59 that the regulated market started in January 2025. That means 24 of the 39 months predate the regime it blames, and 12 predate Law 14.790, from December 2023. The petition also contradicts itself: paragraph 14 speaks of a loss of R$ 117 billion per year, while R$ 143 billion over 39 months works out to R$ 44 billion per year.
4. There is a second magnitude problem. R$ 143 billion over 39 months equals R$ 3.7 billion per month, which is more than the entire GGR of the regulated market. The same 2024 in which CNC says retail lost R$ 103 billion was also a year when retail grew 4.7%, according to IBGE.
5. “Around 268,000 families entered severe delinquency” is presented too cleanly to be credible. In its April release, CNC said betting may have led 270,000 families into that situation. In the STF filing, that hypothesis becomes a hard fact, and even the number changes slightly: 268,000. The petition cites “difference-in-differences” to isolate causality, but it does not explain how Peic, CNC’s own household debt survey, identifies which families actually bet. CNC had previously attributed the 2025 delinquency record to high interest rates.

The broader pattern is simple enough: the petition says it is leaning on “data from different sources converging to the same conclusion,” but in chapter VII, three of the 12 items are the same CNC study, and nine are media reports. For PSPs, acquirers, and banks, that matters because Brazil’s regulatory debate around bets is not just political theater; it is part of the paper trail regulators and courts will use to decide what stays open, what gets restricted, and which flows get blamed for everything from household debt to retail weakness.