To operate fixed-odds betting in Brazil, a company must file an authorization request with the Secretariat of Prizes and Betting of the Ministry of Finance (SPA/MF), prepared in accordance with SPA/MF Ordinance No. 827 of May 21, 2024. The applicant must be a legal entity incorporated under Brazilian law, with head office and management in the country, must show minimum capital stock and net equity of R$ 30 million (Brazilian reais), pay the R$ 30 million grant and demonstrate legal standing, tax and labor regularity, good repute, economic and financial capacity and technical qualification. The authorization is valid for five years and covers the exploitation of up to three commercial brands, operated on domains under .bet.br.
That is the short answer. The useful answer, the one that avoids months of formal requirements and a denial, lies in the detail of each requirement. That is what we unpack below.
Where the authorization requirement comes from
Law No. 14.790/2023 ended the period of tolerance in which foreign operators accepted bets from Brazilians with no regulatory link to the country. From then on, the commercial exploitation of fixed-odds betting came to depend on an authorizing act of the Ministry of Finance, and the SPA/MF was set up to grant, supervise and sanction.
Regulation arrived in blocks, which explains much of the market's confusion. Payment rules and the certification of transactional systems came in SPA/MF Ordinance No. 615 of April 16, 2024. The authorization procedure itself came in SPA/MF Ordinance No. 827 of May 21, 2024. Anti-money laundering and counter-terrorist financing (AML/CTF) duties came in SPA/MF Ordinance No. 1.143 of July 11, 2024. Responsible gaming and commercial communication came in SPA/MF Ordinance No. 1.231 of July 31, 2024. Registration of the .bet.br domain was governed by SPA/MF Normative Instruction No. 11 of November 4, 2024.
Anyone who treats licensing as a single form usually discovers late that they are facing five sets of rules that speak to one another, and that the SPA/MF expects consistency among them.
Requirements for the applicant
Corporate form and nationality
An application is accepted only from a Brazilian legal entity, incorporated as a limited liability company or a corporation, with head office and management in the national territory. Foreign groups may operate in Brazil, but through a Brazilian subsidiary: branches, agencies or representative offices of foreign companies are not eligible. The rules also require Brazilian ownership in the capital stock, in the proportion set out in the regulation, which in practice means redesigning the cap table before filing, not after.
Economic and financial capacity
The thresholds are high and deliberately selective: minimum paid-in capital stock of R$ 30 million, minimum net equity of R$ 30 million and a minimum financial reserve of R$ 5 million earmarked to secure payment of prizes and taxes. To that is added a declaration on the lawful origin of the funds making up the capital, a document the SPA/MF reads closely and that usually triggers follow-up inquiries when the history of contributions is hard to trace.
Good repute and background of shareholders and officers
Shareholders, controllers and officers undergo a background review. Criminal records and convictions involving money laundering, illegal gambling or crimes against the financial system compromise the application. Prior experience of officers in gaming operations or in regulated sectors counts toward technical qualification, and must be evidenced in documents, not merely asserted.
Technical certifications
The betting system, the random number generator where online games are offered, the transactional platform and the integrity controls all require certification issued by a recognized laboratory, in the terms required by the regulation. Certification takes time and depends on the platform already being configured to the Brazilian standard, including bettor identification, a ban on bets by anyone under 18 and full traceability of transactions.
AML/CTF and responsible gaming
The operator needs a formal AML/CTF policy, with an internal risk assessment, know your customer procedures, monitoring of atypical transactions and reporting to Brazil's financial intelligence unit. It also needs a responsible gaming program: betting and deposit limits, self-exclusion, playing time alerts, support channels and strict rules on commercial communication, which may not suggest that betting is a source of income or a solution to financial hardship.
Documents, grant fee and deadlines
The application is filed electronically and supported by corporate documents, proof of paid-in capital, financial statements, tax and labor clearance certificates, background documents for shareholders and officers, internal policies, technical certifications, a description of the systems architecture and payment methods, plus the business plan and the brands the applicant intends to operate.
The grant fee is R$ 30 million, corresponding to five years of authorization and up to three commercial brands. Additional brands mean additional cost under the regulation. As for the decision period, Ordinance No. 827/2024 provides that the Ministry of Finance has up to 150 days to notify the applicant of approval or denial, counted as set out in the rule. The clock, however, stops each time a formal requirement goes unanswered, and that is exactly where poorly prepared applications drag on.
Once approved, the authorization ordinance is published in the Official Gazette, the .bet.br domain is enabled and the operation begins under permanent supervision, with continuing duties of reporting, maintenance of financial guarantees and registration updates.
Five mistakes that stall an application
- Capital declared but not paid in. The rule speaks of paid-in capital. Articles of association amended on the eve of filing, without demonstrable funding, trigger an immediate requirement.
- A foreign corporate structure without a proper subsidiary. Trying to license the offshore holding, or a branch, is a dead end.
- Generic AML/CTF policies. Documents translated from another market, without a risk assessment of the Brazilian business and without a reporting workflow to the financial intelligence unit, are rejected.
- Certification that does not match the platform actually operated. Certifying one environment and running another is a serious regulatory risk, not a formality.
- Marketing launched before authorization. Campaigns, sponsorships and influencers promoting an unauthorized brand expose the company to sanction and weaken the application itself.
What happens to those who operate without authorization
As of January 1, 2025, legal entities not authorized to exploit fixed-odds betting became subject to the penalties set out in the legislation and the regulation, once the adaptation period fixed for December 31, 2024 had closed. The consequences are not limited to administrative fines: there is blocking of domains and payment channels, orders to suspend the operation, liability for officers and damage to the group's regulatory reputation, which makes future applications harder. Suppliers, payment processors, media platforms and sports clubs also take on risk when contracting with an irregular operator.
In a regulated sector, licensing is not a cost of entry: it is the condition for the revenue generated to be, in fact, defensible revenue.
How to prepare before filing
- Design the Brazilian corporate structure well in advance, including the Brazilian shareholder and governance compatible with the background review.
- Plan cash flow around the grant fee, paid-in capital and financial reserve, without counting on future revenue.
- Contract technical certification early, with the platform frozen in the configuration that will actually run.
- Produce tailored AML/CTF and responsible gaming policies, with a formally appointed officer.
- Review contracts with suppliers, affiliates and sponsored parties so they only take effect after authorization.
How our firm can help
We work on structuring and preparing authorization requests before the SPA/MF, from corporate design to responding to formal requirements, including drafting the internal policies demanded, reviewing contracts with suppliers and affiliates and monitoring the continuing obligations that follow the authorization ordinance. Every application has its particularities and no outcome can be promised, but a well-prepared filing reduces the number of inquiries and shortens the road to a decision.
