What has been confirmed

MP 1,394, published on September 25, 2026, prohibits the operation, offering, intermediation and advertising of fixed-odds betting in Brazil. Its scope includes sports betting and online games, including offers by businesses abroad to people located in Brazil. Other lottery categories authorized by law are outside this prohibition. Original text, articles 1 and 2.

In an October 6 announcement, Brazil's Ministry of Justice reported the start of platform unavailability for previously authorized operators. It also recorded the October 5 voluntary withdrawal deadline and the balance refund timetable. Ministry announcement.

The provisional measure is subject to congressional review. That process should not be confused with permission to continue operating while awaiting a political outcome. Senate proceedings.

Website blocking is only part of the impact

For a B2B company, the useful question is which revenue streams, obligations and resources remain tied to Brazilian operations. A supplier can serve clients in several countries while still earning most of its revenue from one end market. An affiliate can hold several contracts that depend on the same revenue source.

Our commercial assessment is to map exposure by client, end market and contract type. Separating recurring fees, variable commissions and receivables makes renegotiation priorities easier to identify. Review the continuation of each service with legal counsel, considering its actual use and recipient.

Four immediate review areas

  • Contracts: document scope, jurisdiction, counterparty, due dates and suspension or termination terms. Do not assume every agreement receives the same treatment.
  • Receivables and cash: distinguish invoiced amounts, performance-dependent revenue and obligations to third parties. Model delays without assuming revenue will automatically recover.
  • Data and support: identify who owns records, reporting and customer assistance during the transition. Ending the offering does not end every responsibility.
  • Communications: review campaigns, sales materials and launch commitments. Messaging must reflect the market's current position.

Article 10 preserves obligations relating to the authorized period, including record retention. The SPA has also published wind-down and reporting requirements. Each company's legal adviser should confirm the procedure applicable to its circumstances. SPA announcement.

How to choose your next commercial move

Shortlist capabilities your company can lawfully offer in other markets: platform integration, content, support, payments or business development, depending on your product. For each capability, record local requirements, necessary adaptations, implementation costs and access to potential buyers.

A contact is useful when the buyer's need matches the supplier's delivery capacity. Before an introduction, align scope, jurisdiction, decision ownership and timing expectations. This preparation reduces poorly matched discussions and avoids selling capacity the operation does not yet have.

What to avoid during the transition

International expansion does not automatically transfer licences, users or databases. It is also not a route to keep serving people in Brazil through a different domain. The measure expressly reaches foreign offers aimed at people located in Brazil.

The commercial priority is to build alternatives consistent with each destination's rules. Our Latin America diversification article provides a method for comparing markets before committing budget. DigitalBreeze identifies business needs, connects companies and supports commercial intermediation, with scope and compensation agreed by project, deal commission or a combination of both.

Sources consulted

Information verified on October 8, 2026.

Commercial analysis based on sources consulted on this date. Scenarios are hypotheses, not forecasts. Legal, tax and investment decisions require case-specific assessment.