On 25 September 2026 the Brazilian government published Provisional Measure 1,394/2026. It prohibits operating, offering, brokering and advertising fixed-odds betting in Brazil. That covers sports betting and online casino games, in physical and digital form, including offshore providers serving people located in Brazil. Other lotteries authorised by law are not affected.

The measure applies immediately, and its long-term future rests with Congress. I lead regulatory compliance at OpenTag, and I want to set out what the measure says, the timetable it imposes and the obligations that continue after closure, plainly and without commentary on the policy itself. Then I will explain where OpenTag stands and how we are supporting our operators through it.

What the measure says

The prohibition is broad. It covers the operation, offering, intermediation and advertising of fixed-odds betting throughout the national territory, whether on real sporting events or on virtual online game events, and whether the operator is based in Brazil or abroad. Communication, publicity, marketing and sponsorship connected to fixed-odds betting are prohibited in any medium, physical or digital.

Authorisations granted under Law 14,790/2023, at federal, state and Federal District level, are terminated 30 days after publication. The measure states that termination gives no entitlement to a refund of authorisation fees and no compensation from the government. New authorisations stop immediately, and pending applications are deemed withdrawn.

The requirements also reach beyond betting operators. Payment providers, advertising channels, internet services, app stores and operating systems all carry duties under the measure, which I come back to below.

What the measure does not do is also worth stating precisely. It does not touch the other lottery modalities that the law already authorises, and it does not remove any of the obligations an operator carried before 25 September. Those continue, and I return to them below.

Congress still has a decisive role

A provisional measure has the force of law from the day it is published. To remain in force permanently it must be converted into law by Congress, which has up to 120 days to do so (60 days, extendable once by another 60, not counting the parliamentary recess). If Congress does not approve the conversion within that period, the measure lapses.

Two things follow, and both matter. First, the measure is fully in force today. Every deadline below is binding now, and nothing about the congressional review suspends it. Second, the framework may still change, whether through conversion, amendment or lapse. I am not going to predict the outcome, and I would not advise anyone to plan on one. Compliance with the obligations as they stand is the only safe position while Congress does its work.

The timetable

The government announced the following sequence. Each step has its own deadline, and several of them fall within days of each other.

25 September
Immediate restrictions
New deposits stop. New authorisations stop, and pending applications are deemed withdrawn. Betting payments are prohibited, except for the transactions needed to close accounts and refund players. One narrow exception applies: proceeds from investments that already held bettors' funds at publication may enter the transactional accounts, solely to meet the repayment obligations in Article 7.
By 5 October, 23:59
Voluntary withdrawals
Bettors can withdraw their available balances. Funds not withdrawn by the deadline remain refundable. Advertising and sponsorship materials already displayed must be removed by the same date, with a limited exception for content published before the measure in which betting promotion appears only incidentally.
From 6 October
Websites and apps offline
Access is made unavailable. Unresolved bets become void, with stakes refunded without deductions. Winnings on bets resolved by the cutoff remain payable.
7 to 8 October
Refund preparation
Within two days of shutdown, operators must secure and segregate the refund funds; send the amounts, CPFs and originating accounts to the banks and payment institutions and to the Secretariat of Prizes and Betting (SPA); and give SPA evidence that the funds are in place. Breaches of these Article 8 duties carry a fine of R$200,000 per day until corrected, plus other sanctions.
9 to 14 October
Bank refunds
Banks and payment institutions return balances, voided stakes and winnings to active accounts held by the bettors, preferably the accounts the funds came from. The measure itself gives them seven days from receiving the operator's information. Completed and unsuccessful refunds are both reported to SPA.
From 14 October
Caixa support
Funds the banks cannot return go to a designated account at Caixa Econômica Federal for repayment. Operators remain liable for shortfalls, discrepancies and any other outstanding obligation.
30 days after publication
Authorisations end
Concessions, permissions and authorisations for fixed-odds betting are terminated. Under the measure, termination gives no entitlement to a refund of authorisation fees or to government compensation.
The announced timetable under Provisional Measure 1,394/2026. Congress's review of up to 120 days runs alongside it.

What continues after closure

This is the part I would ask every operator to read twice. Taking a website offline does not close the file. After closure, tax, financial, anti-money-laundering and counter-terrorist-financing, responsible gambling and sports integrity duties all continue. So does regulatory reporting through SIGAP, along with the duty to cooperate with oversight and to keep contact details current with SPA, which may set further reporting procedures and deadlines. Complete records covering players, bets, transactions and prize payments must remain accessible to the authorities for at least five years.

There is one further point that rewards attention. Administrative sanction proceedings under Law 14,790 that had not been finally decided at publication are suspended. Whether they are dismissed depends on timely compliance with every obligation in Chapter III of the measure. In other words, the closure sequence is not only a set of deadlines; it is also the condition on which open proceedings are closed.

In practice that means the regulator, the tax authority and the financial system can ask, months or years from now, for the evidence behind every refund, every voided bet, every paid win and every balance that went to Caixa. The refund process itself is a compliance event with its own audit trail, and it will be examined with the same rigour as any period of live operation.

Enforcement extends across the sector

The measure places duties on the wider ecosystem, not only on operators. Internet services must prevent prohibited promotional content and remove it when notified. App stores and operating systems must prevent prohibited offerings from being made available. Authorities can require websites to be blocked or redirected, and a new interagency committee coordinates enforcement.

Article 22 sets provider fines of up to 10% of the economic group’s revenue in Brazil, excluding taxes, or user-based fines where there is no revenue, with a stated cap of R$50 million per violation. Daily fines are available, and repeated non-compliance can lead to suspension or prohibition of activities. Financial institutions must report transactions connected to non-compliant operators to COAF, the financial intelligence unit, and the measure provides for administrative forfeiture of relevant frozen funds, with rights of defence.

For an operator this matters in a practical way. The payment institution, the app store and the advertising channel each have their own reason to act on the same dates, so an operator’s closure plan has to be coordinated with all of them rather than executed alone.

What this looks like operationally

Stripped of commentary, an operator with a Brazilian brand has four workstreams between now and mid-October, and each one has to be evidenced. The immediate priorities are to understand the requirements, protect player funds, and coordinate the next steps across platform, payments and reporting.

Money
Balances and refunds
Deposits closed, withdrawals open until the cutoff, refund funds secured and segregated, refund file prepared per bettor.
Product
Bets and access
Bets resolved by the cutoff settled and paid, unresolved bets voided with full stakes returned, sites and apps taken offline on 6 October.
Communication
Players and advertising
Players told how and by when to withdraw, all advertising and sponsorship material removed by 5 October.
Records
Evidence and reporting
SIGAP reporting maintained, funding evidence delivered to SPA, complete records retained and accessible for at least five years.
Four workstreams, one deadline sequence

None of this is unusual work for a regulated operator. What is unusual is the compression: withdrawals, shutdown, refund file, bank returns and Caixa transfer all fall inside three weeks, on top of an advertising takedown and the end of authorisations. The operators who will come through it cleanly are the ones whose platform already holds every balance, bet and transaction as an accountable record, so that the refund file is an export rather than a reconstruction.

Where OpenTag stands

OpenTag provides the iGaming platform behind licensed brands in Brazil, and our responsibility to those operators does not change with the regulation. It becomes more specific. Our compliance, operations and account teams are working with each operator on the closure sequence step by step: closing deposits while keeping withdrawals open; settling bets resolved by the cutoff and voiding the rest with stakes returned in full; producing the per-bettor refund file with amounts, CPF and originating account; reporting the balances that evidence the segregated funds; keeping SIGAP reporting running; and preserving the complete record, including the back office audit trail of every manual action taken during the closure, for the retention period.

That work is possible because the platform was built for regulated markets and has been independently assessed against a recognised technical standard. Our GLI-19 certified iGaming platform treats wallet integrity, transaction ordering and audit logging as core architecture, which is exactly what a refund of this scale depends on. A certification does not carry out the closure for you. It does mean that the evidence a regulator asks for later already exists.

Most operators with a Brazilian brand also run brands in other markets, and the same platform serves them across jurisdictions. Part of our conversation with each operator is therefore about the rest of their business: where their teams, players and product investment go next, and how the platform supports that without a second migration.

We are also developing a new product line designed to meet the applicable requirements in Brazil. I will say more when it is ready. If you operate in Brazil, I would rather have that conversation with you early than late.

What I would ask of every operator

Treat the measure as fully in force, because it is. Meet each deadline in the sequence above and keep the evidence that you did. Follow the congressional review closely, but do not plan around a result that nobody can promise. And keep every obligation that survives closure, from records to reporting, exactly as you kept it while live.

If you operate in Brazil, get in touch with me, Rea Maor or Yuri Ferreira to discuss your next steps and how OpenTag can support your business. We are ready to help our operators navigate these changes and meet their compliance obligations, whatever the coming months bring.