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iGaming contracts built around Brazil's betting rules
Before the SPA/MF, the operator is the one who answers. The contract decides whether it can recover from the partner that failed.
iGaming contracts are the agreements behind a betting operation: platform, games, payments, KYC, affiliates, influencers and sponsorship. They must reflect Law 14,790/2023 (Brazil's betting law) and SPA/MF (federal regulator) ordinances. Talk to a lawyer before signing with a new partner, when changing suppliers or when an ordinance changes obligations along the chain.
iGaming contracts organize the chain behind every bet: platform supplier, game studio, certification body, payment institution, identity verification provider, affiliate, influencer and sponsored club. Each link has obligations arising from Law 14,790/2023 (Brazil's fixed-odds betting law) and from the ordinances of the Secretariat of Prizes and Betting (SPA/MF, the federal regulator), but the authorized operator is the one who answers to the regulator.
That is why a standard contract from another market does not work. SPA/MF Ordinance 722/2024 requires systems hosted in a data center in Brazil; Ordinance 1,207/2024 requires games certified for Brazil; Ordinance 615/2024 limits payment methods; and Ordinance 1,231/2024 makes the operator jointly liable for affiliates' ads, whose contracts must be available to the SPA/MF.
We draft and review these contracts with one simple test: every regulatory obligation needs an owner, evidence and a consequence. That way the operator knows what to demand, the partner knows what to deliver and the clause works when it has to be used.
When to call a lawyer
Platform contract imported from another country
A template built for another jurisdiction, with no data center in Brazil, no local certification and no rule on SPA/MF access to data. The gap becomes the operator's risk.
Affiliates and influencers without compliance clauses
Partners publish without prior approval, without the mandatory warnings and with no duty of immediate takedown. Joint liability falls on the operator.
Supplier change or game update
A change to a critical component, such as the random number generator, requires new certification. The contract must say who bears the cost, the timeline and any downtime.
Sports sponsorship under negotiation
Naming rights, shirt deals and activations must address sector advertising rules, the protection of minors and who answers for each piece published.
What happens when you leave it for later
- Sanctions on the operator for a partner's failure, with no clear right of recourse against that partner.
- Games or systems live without valid certification, exposed to the sanctioning regime of SPA/MF Ordinance 1,233/2024.
- Non-compliant affiliate campaigns with no contractual mechanism for fast takedown.
- Lengthy commercial disputes due to missing service level, audit and exit clauses, putting business continuity at risk.
How we work
Contract chain map
We list every partner, what each one delivers and which regulatory obligations touch each contract.
Liability matrix
We define who meets each requirement (certification, data, AML/CFT, advertising, responsible gambling), how it is proven and what happens if it fails.
Drafting and review
We draft or adjust agreements with compliance, audit, data access, service level, confidentiality, data protection and termination clauses.
Negotiation
We support negotiations with Brazilian and foreign partners, explaining the regulatory basis of each demand and what Brazilian rules make non-negotiable.
Management and updates
We review the contract portfolio when an ordinance changes and keep affiliate contracts organized for presentation to the SPA/MF.
What you receive
- Contract chain map with risks per partner
- Regulatory liability matrix between the parties
- Standard templates for affiliate, influencer, supplier and sponsorship agreements
- Annotated review of contracts in force, with adjustment priorities
- Compliance amendments whenever the rules change
Why the firm
Contracts written from the rule
We start from SPA/MF ordinances to reach the clause, not the other way around. The result is a contract that speaks the language of inspection.
Advertising and data in the same review
The affiliate clause reflects the advertising rule and the player data policy, because all three fronts are reviewed together.
Litigation experience behind the drafting
The firm also handles contract disputes, and that shapes drafting: we write with an eye on how the clause will be read in a conflict.
Illustrative scenario
Hypothetical scenario, for illustration only. An authorized operator is about to hire a foreign live casino studio using the supplier's own template. In the review, the firm finds no obligation to certify for Brazil, silence on recertification after updates and no rule on data access in the event of an inspection. It proposes compliance clauses, cure periods, audit rights and an orderly exit, and leads the negotiation by explaining the regulatory basis of each request. The final contract allocates responsibilities clearly. Every negotiation has its own outcome, which depends on the parties and the facts.
A hypothetical scenario, shown only to illustrate our method. Every case depends on its own facts.Frequently asked questions
Which clauses do iGaming contracts with suppliers need?
They need regulatory compliance, certification, data access, audit, service level, confidentiality and orderly exit clauses. For platforms and games, certification for Brazil by an SPA/MF-accredited entity and hosting systems in a data center in Brazil are central points. It is also essential to define who bears the consequences of a supplier failure.
Is the operator liable for what affiliates publish?
Yes. SPA/MF Ordinance 1,231/2024 makes the operator jointly liable for its affiliates' ads and requires the contracts to be available to the SPA/MF. The contract should therefore provide for prior content approval, monitoring and immediate takedown.
Can I use the foreign supplier's standard contract?
It can be a starting point, but it is rarely enough. Templates from other markets often ignore Brazilian requirements such as local certification, a data center in Brazil, permitted payment methods and data protection under the LGPD, Law 13,709/2018 (Brazil's data protection law).
What should a payment provider agreement cover?
It must reflect SPA/MF Ordinance 615/2024, which allows Pix (Brazil's instant payment system), TED bank transfers, debit or prepaid cards and transfers between accounts at the same institution, and does not allow credit cards. It should also address account ownership, anti-money laundering controls and information sharing.
Does a sponsorship deal with a football club follow special rules?
It has its own points of attention. Sponsorship is allowed, but it must follow the advertising rules of SPA/MF Ordinance 1,231/2024 and Annex X of the CONAR code (Brazil's advertising self-regulation council), especially the protection of minors under 18 and the mandatory warnings.
When should signed contracts be reviewed?
Whenever an ordinance changes obligations along the chain, when products or suppliers change and before renewals. In 2026, for example, the standardized advertising warnings required changes to affiliate and agency contracts.
Related matters
Do your contracts protect the operator or only describe the service?
Send your key contracts for an initial review. We will show what to fix first and why.