“Prohibition Is Not Protection”: ABRAJOGO, Sindibets, and AMIG Take Technical Memo to Brazil’s Supreme Court Against the Betting MP

ABRAJOGO, Sindibets SP, and AMIG have filed a joint request to join Brazil’s Supreme Federal Court case as amicus curiae, backing a precautionary measure in ADI No. 8.024 against Provisional Measure No. 1.394/2026. Their core claim is blunt: the MP was issued without any impact study, and the result could be lost revenue, lost jobs, and less consumer protection in the betting market.

1. The petition was filed with Justice Luiz Fux, who is the rapporteur in ADI No. 8.024 brought by ANSEJA against MP No. 1.394/2026. The filing is 37 pages long and was signed on 24 October, the eve of the date when Article 4 of the MP terminated all federal, state, and district authorizations for fixed-odds betting.
2. The entities say their goal is not to re-argue the legal points already in the case, but to put “facts and numbers” before the Court. They say much of the material was obtained through Brazil’s Access to Information Law and is meant to show the economic effect of the MP in the real economy.
3. On representativeness, the groups argue that their role is complementary. Sindibets says its territorial base covers 53 of the 85 companies authorized by the SPA/MF. AMIG says it has more than 1,400 members whose income depends on the sector. ABRAJOGO says it has represented international operators and providers for more than ten years and has been part of the debate since Law No. 13.756/2018.
4. The memo also says the groups filed a complaint with the TCU over the lack of fiscal instruction for the MP. ABRAJOGO additionally sent a technical note to the SPA/MF on 17 August about online game design, with comparisons to Ontario, Alberta, and the United Kingdom.
5. The technical memo’s central point is the absence of a prior study. A request under the Access to Information Law sent to the Ministry of Finance on 20 September received the reply “Informação Inexistente” on 24 September at 17:33, the day before the MP was issued. According to the filing, technical units found no studies, notes, or estimates on the economic, fiscal, regulatory, or social impact of a ban.

The memo also cites numbers from the revenue side. Cetad, within the Federal Revenue Service, said its only documents on the subject are two 2026 notes. One of them, dated January, projected higher tax revenue from an increase in the GGR rate: R$ 255.15 million in 2026, R$ 775.05 million in 2027, and R$ 1.245 billion in 2028. By contrast, the MP’s Explanatory Memorandum estimates revenue losses of R$ 1.541 billion in 2026, R$ 5.150 billion in 2027, and R$ 5.330 billion in 2028. The entities say the Congressional budget note does not spell out assumptions or methodology, and that the loss figure is understated.