TRF3 restores CDA Gaming’s authorization, with Casa de Apostas and Betsul back online pending the final ruling

A federal judge at Brazil’s TRF3 granted CDA Gaming Ltda. interim relief on Tuesday (3/11), temporarily restoring its fixed-odds betting authorization after it was extinguished by Provisional Measure No. 1.394/2026. For high-risk operators and their PSPs, the practical point is simple: the company’s payment rails, operational systems, and domains are to be restored, at least until the final judgment or a new court order.

1. Federal appellate judge Adriana Pileggi of the 3rd Panel of the Federal Regional Court of the 3rd Region (TRF3) granted anticipatory appellate relief in Agravo de Instrumento No. 5034200-15.2026.4.03.0000, signed at 14h on Tuesday (3/11). The relief applies only to CDA Gaming Ltda., which operates the brands Casa de Apostas, Betsul, and Jogo Online.
2. The ruling suspends the extinguishing effect of Article 4 of MP No. 1.394/2026 on the authorization granted under SPA/MF Ordinance No. 255/2025. To the extent needed to comply with that order, it also sets aside the restrictions in Article 7 and the effects of Official Letter No. 1256/2026/GAB-SEDIGI/SEDIGI/MJ from the National Secretariat for Digital Rights.
3. Pileggi also ordered the restoration of electronic domains and the operational, financial, and payment services indispensable to the business. The measure remains in force until the final ruling on the mandamus proceeding or a further judicial decision, while “applicable regulatory requirements and state oversight” stay in place.
4. The first-instance court had refused the injunction. In Mandado de Segurança No. 5031432-52.2026.4.03.6100, the 26th Federal Civil Court of São Paulo held that the public interest in protecting the population from the negative effects of betting should prevail over the company’s argument on legal certainty.
5. CDA Gaming said it paid R$ 30 million for the license, which is valid until 31 December 2029. In the alternative, it had asked to keep back-office systems, banking interfaces, and customer support channels running so it could refund players and send information to regulators; the court granted the main request instead.

The decision is unusually blunt on the provisional measure itself. Pileggi said the company made “substantial financial and technical investments” to obtain the license, and that public interest cannot be invoked as if it only appeared after the deal was signed. She also said the rapid extinguishing of authorizations violates legal certainty, reasonableness, and proportionality, and found that the constitutional requirements of relevance and urgency for issuing a provisional measure were not met.