Brazil’s betting market and the seven questions investors are asking after 85 licences expired

Since 25 October, Brazil has had no authorised betting market, and that is not the sort of sentence that calms an investment committee. The issue now is not whether Brazil can attract capital in theory, but whether it can offer the legal certainty, enforcement capacity, and regulatory stability that high-risk operators and their payment partners need.

1. Since 25 October, the authorised betting market has effectively disappeared. The 85 licences issued under Law 14.790, totaling BRL2.55 billion ($476.2 million) in grants, expired without refund. For investors, that leaves an immediate question: who, if anyone, will make the earlier licensing costs and the resulting liabilities workable enough to justify new money?
2. Provisional Measure 1,394 is still in force, but the process around it remains unresolved. Congress has not yet set up the joint committee that will analyse it, and Minister Luiz Fux, of the Supreme Federal Court (STF), will hear from the government, associations, and clubs in a public hearing on 3 November before deciding on suspension requests. In plain terms, the market is being asked to price regulatory risk while the rulebook itself is still under dispute.
3. The first question for any serious operator is whether the liabilities tied to Provisional Measure 1,394 will be resolved. No top-tier operator wants to enter a market where previous investors are still fighting in court over the BRL2.55 billion they paid. Any future model, whether iGaming or land-based gaming, starts with fixing those licensing disputes and the 19 ongoing lawsuits.
4. The second question is whether the rules will come by law. Changes made by law, with transitional measures and compensation rules, carry different weight from changes made by decree. Spain is the example Pariente uses: in 2024, the Supreme Court annulled advertising restrictions established by decree, ruling that limits of that scope require a law approved by Parliament.
5. The third question is whether Brazil can field a regulator that can outlast governments. The United Arab Emirates created its federal regulator in 2023 before issuing its first licence in 2024. Singapore built its regulatory structure before opening its resorts. Brazil already has a Secretariat for Prizes and Bets, with data and payment control systems set up in less than two years; the task now is to give it a technical mandate and stability.
6. The fourth question is whether the concession model fits the investment horizon. Macau renewed its concessions in 2022 for 10 years, with investment commitments revised by the government. Italy has started granting online licences for up to nine years. For integrated resorts, the cycle matters: if the licence term and capital recovery window do not match, the market becomes a financing problem before it becomes a gaming market.

The broader point is simple. On paper, Brazil already has the legal, regulatory, and professional foundations to rebuild the sector. In practice, the investment case depends on whether the government can preserve those structures, settle the current disputes, and offer a framework that lasts longer than the next political cycle.