IBDRE challenges Brazil’s MP 1,394/2026, which would shut fixed-odds betting operators in 10 days

The Brazilian Institute of Regulatory Law (IBDRE) has issued a formal statement against Provisional Measure No. 1,394/2026, saying it would cause a “deep rupture” in Brazil’s fixed-odds betting framework. For PSPs and operators, the practical issue is obvious: licensed activity would be pulled offline fast, while demand does not disappear just because the formal channel does.

1. According to the note published on Monday (28/9), the Federal Government issued the MP on 25 September and it would terminate all current authorizations for fixed-odds betting in Brazil, with systems to be made unavailable within 10 days.
2. The measure would end all valid authorizations, concessions and permissions within 30 days, including state and district-level licenses. It would also ban advertising, promotion, marketing and sponsorship tied to the sector.
3. The part IBDRE contests most directly is the clause saying operators would not be entitled to reimbursement of license fees or compensation from the government. Federal authorizations were granted for five years, with each one requiring payment of R$ 30 million, plus investments in technology, compliance, staff and operational infrastructure required by the state.
4. IBDRE says Brazil spent years building a regulated market out of an activity that had already reached millions of Brazilians without oversight. Under Law No. 14.790/2023 and the Ministry of Finance’s later regulation, the sector was formalized with authorization, taxation, supervision, bettor identification, responsible-gaming tools and anti-money-laundering controls.
5. One of the core tools in that framework was SIGAP, the betting management system. By September 2026, more than one million Brazilians had used the centralized self-exclusion mechanism on licensed platforms, while the federal government had also been stepping up tools against the clandestine market, including financial pressure on illegal operators.

For high-risk payment providers, the point is not theoretical. IBDRE warns that if the formal market is extinguished, demand will not vanish; it will move. The institute says Brazil’s pre-regulation experience already showed a large offshore betting market operating outside domestic supervision, and that users shifting to clandestine platforms would be taken out of the monitored payment environment and into a much harder one to control.