Brazil’s SPA lets betting operators use existing withdrawal APIs to return balances on the last day of the deadline

The Secretariat of Prizes and Bets (SPA/MF) has told fixed-odds betting operators they can use their existing withdrawal integrations to return money to players, just as the deadline set by Provisional Measure 1.394/2026 ran out. For PSPs and acquiring teams, the detail that matters is simple: the refund flow is being pushed through payment APIs already in production, not through a brand-new rail.

1. The circular, Circular SEI No. 1711/2026/MF, was sent on Wednesday (7) at 19:12 and signed electronically by deputy secretary Fabio Macorin. It authorizes operators to use the mechanisms and API integrations already used for withdrawals, as long as technical, operational, and security requirements are met.
2. Provisional Measure No. 1.394/2026, published on 25 September, ordered operators to take their websites and apps offline 10 days later, which happened on 5 October. Article 8 then gave companies two days, ending on Wednesday (7), to secure liquidity and send banks, payment institutions, and the SPA an individualized list of bettors, with CPF, amounts to be refunded, and source accounts. Non-compliance carries a daily fine of R$ 200,000.
3. The MP itself says the refund is not the operator’s job. Under Article 9, the institutions holding the transactional accounts must make the reimbursement within seven days of receiving the list, by transferring funds to an active account in the bettor’s name, preferably the original source account.
4. The SPA’s circular takes a different operational route while keeping the legal obligation in place. It says operators may use existing payout flows “for the purpose of fulfilling the refund obligation,” with the stated goal of making the process safe and efficient by reusing payment infrastructure that is already built and running.
5. The amounts to be returned go beyond the available balance. They include open bets whose outcome had not been settled by the time the platforms shut down, which are treated as void and refunded in full without deductions, as well as bets with settled outcomes within the deadline. Institutions that received the list on the last day have until 14 October to complete the transfers.

The circular also keeps the reporting chain in place: using APIs does not remove operators’ communication duties, especially the obligation to report remaining balances and amounts sent to payment institutions. The notice does not cover the next step under the MP, where institutions must later send the SPA an individualized report of amounts refunded and amounts that could not be returned, along with the reasons and account holders involved.