Brazil Casino License

Possible challenges and drawbacks of a gambling license in Brazil

Obtaining and operating under a Brazilian gambling license opens up a promising market, but it comes with a number of administrative, financial, and operational hurdles that need to be considered in advance:

High entry threshold

The cost of the license and the initial capital requirements are approximately R$35 million (approximately US$40 million), which makes the market inaccessible to small operators and startups.

Licensing process

The application process requires detailed documentation, technical descriptions, financial reports, and cybersecurity materials. The slightest discrepancies can lead to delays or rejection of the application.

Insufficient regulatory maturity

The regulator, the Secretariat for Prizes and Betting (SPA/MF), was established recently. Many procedures, including software certification and payment system integration, are still being finalized, creating uncertainty and delays.

Limited access to banking services

Traditional banks in Brazil are reluctant to work with gambling companies, considering them high risk. Operators have to use international fintech solutions, which increases costs and onboarding timelines.

Strict requirements for local presence

The requirement to have an office in the country and a local shareholder with a stake of at least 20% creates an additional financial and administrative burden. It is also necessary to appoint a resident compliance officer registered with the SPA.

High compliance costs

Operators are required to undergo regular financial and technical audits, submit reports, and pay regulatory fees. Compliance costs can reach tens of thousands of euros per year.

Complexities of localization and technical adaptation

Platforms must be adapted to meet legal requirements, including the availability of a Portuguese-language interface, local monitoring tools, and AML systems. This requires significant investment and the involvement of local specialists.

Restrictions on advertising and marketing

Brazilian law strictly regulates the promotion of gambling: advertising aimed at minors, the use of young influencers, and promotional offers during sports broadcasts are prohibited.

Multi-level tax system

In addition to the federal GGR tax, depending on the region, operators may face additional ISS or ICMS taxes, which complicates calculations and financial planning.

Access risks and geo-restrictions
The mandatory implementation of mechanisms to block users from prohibited jurisdictions requires additional technical solutions and constant monitoring, and violations can lead to license revocation.

Requirements for obtaining a Brazil gambling license

The main requirements for licensing online gambling activities in this jurisdiction include:

1. Registering a company in Brazil: To obtain a license, the applicant must register a legal entity in Brazil. The company must comply with local corporate laws and have its registered headquarters and administrative offices in the country. In addition, the corporate structure must have at least 20% of the shares owned by a Brazilian citizen.
2. Financial stability and guarantee obligations: Operators are required to demonstrate financial stability by providing detailed financial statements and a two-year forecast. A minimum financial reserve of 5 million Brazilian reais (approximately US$854,350) is also required.
3. License fees: To obtain a license, a registration fee of 30 million Brazilian reais (approximately US$5.1 million) must be paid. The license is issued for five years, and failure to pay the fee by the due date will result in the application being canceled.
4. Technical compliance and certification: All gaming platforms must comply with integrity and security requirements. Gaming systems are certified by independent laboratories, and software must be audited to meet transparency and reliability standards.
5. AML/CFT and KYC policies: Operators are required to implement strict anti-money laundering (AML) and counter-terrorist financing (CFT) measures. Customer identification (KYC) procedures and monitoring of suspicious activity are also required. Operators must keep records of all transactions and promptly provide data to regulators.
6. Responsible Gaming: Licensees must implement measures to protect players, including:

• self-exclusion programs;
• setting betting limits;
• protecting vulnerable users.

1. Mandatory local presence: Operators are required to maintain a physical presence in Brazil, which includes offices and local staff. 24/7 customer support in Portuguese is also required.
2. Advertising regulation: Advertising materials must comply with strict requirements. Key restrictions include:

• the gambling license logo must be included in advertisements;
• it is prohibited to attract the attention of minors;
• mention of the risks of gambling must be clear and understandable;
• the protagonists of the advertisement must be over 21 years of age;
• specifying odds and taxes in Brazilian reals.

1. Registration on a consumer protection platform: Operators are required to register with the official Brazilian consumer dispute resolution platform, which guarantees the protection of players' rights and service standards. This platform allows consumers to register complaints against companies and seek resolution. It is managed by the Ministry of Justice and Public Security and aims to facilitate communication between consumers and companies to effectively resolve issues.
2. Prohibiting certain individuals from participating: Licensed operators cannot accept bets from government officials, athletes, and other individuals with significant market power. These restrictions must be taken into account in the KYC system.

Brazilian regulators plan to exercise strict control over operators. Non-compliance may lead to license revocation and heavy fines.

Documents required a gambling license in Brazil

To obtain a gaming license in Brazil you will need:

Company registration documents.

The list of required documents includes:

• constituent documents confirming that the company is registered in Brazil;
• documents confirming that at least 20% of the shares are owned by the Brazilian partner;
• address and registration data of the head office and administrative bodies of the company in Brazil.

Financial documentation.

• proof of financial reserve of 5 million Brazilian reais;
• a certificate of financial discipline issued by the Central Bank of Brazil;
• a financial report with a two-year forecast;
• tax documents issued by the Special Secretariat of Federal Revenue.

Employee Qualifications.

• appointment of a financial director and a customer support manager;
• certificates of no criminal record or misdemeanor for the owners and key employees of the company;
• proof of qualifications of professionals responsible for anti-money laundering (AML) and counter-terrorist financing (CFT) compliance.

Technical certificates.

• documents confirming that the platform meets safety and reliability requirements;
• certificates of independent laboratories on technical compliance of gaming software;
• confirmation of compliance with data protection requirements and KYC protocols.

License and advertising obligations.

• documents confirming payment of the R$30 million license fee;
• registration on the official Brazilian consumer dispute resolution platform;
• advertising policy that complies with Brazilian law, including information on rates, taxes, and age restrictions.

Types of licensing for Brazil

Federal license (basic SPA license)

This is the key and most sought-after type of license, issued by the Secretariat for Prizes and Betting for a period of up to 5 years. Federal license holders are entitled to offer fixed-odds betting online and through land-based betting outlets.

This license requires comprehensive certification, including:

• technical security standards (e.g., ISO 27001);
• compliance of payment solutions with Sicoaf/Bacen requirements (Portaria SPA/MF No. 1.143/2024);
• audits by independent laboratories such as Gaming Laboratories International (GLI) and Gaming Associates Labs (GA Lab).

A federal license provides full participation in the regulated market, but requires significant investment and strict compliance with compliance procedures.

Temporary license (SPA interim permit)

A temporary license is issued to companies that have already paid the license fee but, for objective reasons, have not completed technical certification or provided a full set of documents.

Since Provisional Measure No. 1,394 of 25 September 2026, no new authorisations for fixed-odds betting can be granted in Brazil, and pending applications have lapsed. Upon request, the term may be extended if the applicant proves that they are actively working to eliminate deficiencies.

Temporary licenses are a tool that facilitates the transition to a regulated market, especially for operators who are in the process of adapting their platforms or integrating with local financial systems.

State and municipal licenses (regional permits)

In addition to federal regulation, Brazil has regional licenses issued by individual state and municipal authorities. For example, the Rio de Janeiro State Lottery (Loterj) and the municipality of Bodo issue their own gambling and betting licenses. Such permits are cheaper than federal ones and are attractive to operators focused on local markets or product testing. However, they are geographically limited — the company's activities cannot go beyond the region that issued the license.

Regional licenses can be the first step for operators planning further expansion and obtaining federal status.

Initial fee and annual license fee

The main financial requirement for obtaining a federal license is a one-time initial fee of BRL 30 million (approximately USD 5.6 million). The license covers up to three commercial brands within a single structure. Each additional group of three brands requires an additional payment of BRL 30 million.

This fee is payable before final approval of the license and is a prerequisite for its issuance. Once the payment has been made, the operator is entitled to operate for five years without the need for renewal or additional payments for the license itself. The payment confirms the company's readiness to comply with legal requirements, including sufficient capital, a sustainable financial model, and technical infrastructure.

Although there is no separate annual license fee in Brazil, operators are required to incur regular compliance costs, which effectively constitute their annual obligations to the regulator. These include:

• audits of financial statements and IT systems (approximately $17,000 to $35,000 per year, depending on the scale of the business);
• regulatory fees and social contributions determined by the SPA;
• contributions to responsible gaming funds and consumer protection programs;
• quarterly reporting and administrative fees for data verification and updates.

Thus, despite the absence of a direct annual fee for license renewal, operators must budget for ongoing compliance and regulatory support costs.

For companies operating under state or municipal licenses, the cost of entry is significantly lower, ranging from several hundred thousand to several million reais, depending on the region. However, such permits are only valid within a specific state or city and do not grant the right to operate nationwide.

Gambling regulation in Brazil

Until the 1940s, gambling was an integral part of Brazilian culture. Gambling establishments were popular, and dice games and other entertainment were considered the norm. However, in 1946, President Dutra introduced a total ban on gambling for religious and moral reasons.

The 1970s saw the beginning of a relaxation of the ban: state lotteries were allowed, which became an important source of revenue for the budget.

The 1980s brought another change: betting on horse racing was legalized.

1993 was an important milestone with the passage of the Zico Law, which legalized commercial bingo and the use of slot machines. However, in 1998, the Pelé Law once again restricted this area, banning commercial bingo and leaving only non-commercial lotteries permitted.

Until recently, online gambling and sports betting remained unregulated. Despite this, the popularity of this market in Brazil is enormous.

2018 marked the beginning of a new era. Congress authorized the federal government to develop a system for regulating online sports betting, but the process has been delayed.

2023 – The ABRADIE Association was created to establish a safe environment for gambling and combat fraud. In March, the government accelerated the development of new laws.

In July 2024, detailed regulations were published, including rules on licensing, anti-money laundering, and player protection.

January 1, 2025, marks the beginning of a new phase: the regulated gambling market, including betting and lotteries, is officially launched. Following Provisional Measure No. 1,394 of 25 September 2026, fixed-odds betting – both sports betting and online casino games – is prohibited in Brazil; other lottery types authorised by law are not affected. Land-based casinos also remain prohibited.

Online gambling regulation in Brazil is likely to become even stricter in the coming years, including tighter licensing controls and the fight against illegal operators. Additional responsible gaming requirements are expected, as well as user protection measures such as deposit limits and self-exclusion mechanisms. At the same time, the government may expand the list of permitted games, which will attract even more international operators. Overall, the market will continue to grow rapidly, and regulators will seek to create a transparent and secure gambling ecosystem that will generate significant tax revenues for the country.

Regulatory Authorities

Following the enactment of Law No. 14.790/2023 (Lei das Apostas) in 2023, the government established a multi-level structure of authorities responsible for the supervision, licensing, taxation, and transparency control of gambling activities:

• Brazilian Ministry of Finance (Ministério da Fazenda).

The main regulatory body responsible for developing and implementing gambling policy. The ministry determines the regulatory framework, drafts regulations, sets requirements for operators, and monitors compliance with the law. It also approves general rules for the operation of the fixed-odds betting market, online games, and lotteries.

• Secretariat for Prizes and Betting (Secretaria de Prêmios e Apostas, SPA).

The SPA is a key department of the Ministry of Finance and effectively acts as the federal regulator of gambling in Brazil. It was created by Decree No. 11,907 of 30 January 2024.

The main functions of the SPA are:

• issuing federal licenses for online betting and gambling;
• administering the SIGAP (Sistema de Gestão de Apostas) portal, through which applications are submitted and reviewed;
• monitoring the activities of licensed operators and controlling their technical compliance;
• implementing AML/KYC, cybersecurity, and responsible gaming standards;
• applying sanctions to companies that violate the law.

The SPA also coordinates with other agencies—the Central Bank, tax authorities, and COAF—to ensure the transparency of financial transactions.

• Ministry of Sports (Ministério do Esporte).

This agency is responsible for ethical oversight in the field of sports betting. After approval by the SPA, the Ministry of Sports confirms the legitimacy of the operator's activities and ensures that sports competitions and betting are conducted without manipulation or corruption. The ministry also participates in the development of mechanisms to protect athletes and sports organizations from the illegal influence of bookmakers.

• Federal Revenue Service (Receita Federal do Brasil, RFB).

The RFB controls the taxation of gambling and collects taxes on operators' winnings and profits. It also monitors compliance with tax obligations and interacts with the SPA in the financial licensing of operators.

• Council for Financial Activities Control (COAF).

COAF plays a central role in monitoring financial flows and preventing money laundering and terrorist financing (AML/CFT). All licensed operators are required to register with COAF and regularly report suspicious transactions.

• Central Bank of Brazil (Banco Central do Brasil, BCB).

The Central Bank oversees payment systems and financial instruments used in the gambling industry. Its task is to prevent transactions in favor of unlicensed operators, ensure compliance with Sicoaf/Bacen standards, and stabilize financial flows between operators and players.

• National Telecommunications Agency (Anatel).

Anatel is responsible for the technical control of the internet, including blocking illegal sites and unlicensed platforms. It works with the Ministry of Finance and SPA to restrict user access to offshore gambling resources and protect consumers from fraud.

• Regional authorities and lottery operators (e.g., LOTERJ).

At the state and municipal levels, there are local licensing authorities such as Loterj (Rio de Janeiro State Lottery). They can issue licenses for lotteries and betting within their territories. However, in January 2025, the Federal Supreme Court (STF) limited their powers by prohibiting operators licensed by Loterj from operating outside the state.

The Brazilian government is also preparing to create a new body, the Secretaría Nacional de Apostas Esportivas, which will take on the functions of coordinating the entire industry, including licensing, control, and development strategies. It is expected that this secretariat will become a single center of oversight, ensuring a balance between regulation, player protection, and market development.

Legal framework for online gambling

The modern legal system regulating online gambling in Brazil has developed relatively recently and is the result of the gradual liberalization of legislation. While gambling was strictly prohibited in the country for many decades, 2018 saw the beginning of a phased legalization process and the creation of a comprehensive regulatory framework that now governs online betting, lotteries, and virtual games.

For most of the 20th century, Brazil was governed by Decree-Law No. 9,215 of 1946, which effectively banned most forms of gambling, including casinos and slot machines. The only exceptions were lotteries and horse racing betting. This law remained in force for more than 70 years, creating an extremely limited legal environment for the gambling business.

The situation began to change only in the 21st century, when the government recognized the need to legalize and control the rapidly growing online gambling market. Federal Law No. 13.756/2018, adopted in 2018, legalized fixed-odds betting, allowing private operators to accept bets on sporting events. The law laid the foundation for the formation of a regulated market and paved the way for the development of subsequent regulations. However, at this stage, there was no detailed licensing mechanism, which effectively limited the ability of operators to legally enter the market.

The main document defining the current legal framework for online gambling in Brazil is Law No. 14.790 of 2023, also known as the “Lei das Apostas” (Betting Law). It came into force in December 2023 and created a comprehensive regulatory framework for the entire iGaming industry, including online sports betting, virtual casino games, and lotteries.

This law became a key document defining:

• The procedure for obtaining a federal license for online gambling operators.
• the requirements for capital, ownership structure, and reputation of license applicants;
• taxation rules, including the amount of the initial fee and license fees;
• control and reporting mechanisms for operators;
• mandatory measures to protect players, prevent gambling addiction, and prevent money laundering.

The law also formally established the powers of the Ministry of Finance and its division, the Secretariat for Prizes and Betting (SPA), as the central regulatory authorities. The SPA is responsible for administering licenses, certifying operators, and overseeing compliance.

This law was the first document to systematically describe how foreign and local companies can legally operate in the Brazilian betting market.

Decree No. 11,870/2023 was adopted to further develop Law No. 14,790/2023, specifying the procedure for enforcing the law. This document regulates the post-licensing obligations of operators, including:

• maintaining records and providing transaction data;
• certifying software and servers (in accordance with international standards such as ISO 27001);
• mandatory cooperation with financial regulators and compliance with AML/KYC standards;
• technical requirements for web platforms and user data protection.

Based on the decree, additional SPA regulations and instructions were issued in 2024, detailing the procedure for submitting applications, obtaining licenses, and supervising operators.

Despite the legalization of online gambling, land-based casinos in Brazil are still prohibited. This restriction continues to apply in accordance with Decree-Law No. 9.215/1946. However, the possibility of reform and partial legalization of gambling zones in the future is being discussed.

The legal framework for online gambling in Brazil is currently one of the most dynamic in Latin America. Legislation continues to be supplemented with new regulations aimed at increasing transparency, protecting players, and strengthening tax control.

Gaming business licensing

The gaming business licensing system in Brazil is a centralized and clearly structured model focused on legalizing and controlling the entire online gambling industry at the federal level. It was introduced after the adoption of Law No. 14.790/2023 and is regulated by the Secretariat for Prizes and Betting.

Unlike many other jurisdictions, where operators are required to obtain separate licenses for sports betting and casino games, Brazil has a single federal license. It covers all major areas of online gambling, including:

• fixed odds betting (including sports and esports events);
• online casino games such as slots, roulette, blackjack, and crash games;
• virtual sports simulators and lotteries.

Thus, a single licensed operator is granted the right to offer a wide range of gambling products within a single legal framework.

The federal license is issued for a period of 5 years and allows the operator to manage up to three brands (skins) under a single license. This creates an opportunity for international companies to promote different brands under common corporate management while remaining fully compliant with Brazilian law.

Applications are submitted electronically through the SIGAP portal, where the operator must provide detailed information about the company's structure, financial resources, IT infrastructure, data protection system, and responsible gaming policy.

To obtain a license, a license fee must be paid, which is a one-time payment covering the entire five-year term of the license. During this period, there are no additional annual renewal fees, but the operator is required to comply with the regulatory, technical, and tax requirements established by the SPA.

Before a license is issued, the company must have its software and servers certified by accredited laboratories such as Gaming Laboratories International (GLI) or Gaming Associates Labs (GA Lab), as well as confirm compliance with ISO 27001 cybersecurity standards.

Under the terms of the license, at least 20% of the company's capital must be owned by a Brazilian resident, and the operator itself must have an office in the country. The company must employ a resident compliance officer registered with the SPA, who is responsible for monitoring compliance with legislation and interacting with the regulator.

Further improvements to the regulatory framework are expected in the coming years, including the introduction of additional SPA regulations, the creation of a national register of licensed operators, and stricter requirements for financial reporting and AML systems. All this makes Brazil one of the most promising and regulated jurisdictions for iGaming operators in Latin America.

Obligations for conducting gaming business in Brazil

Licensed companies are required to maintain transparent accounting records and submit them regularly to regulatory authorities. The main requirements include:

• quarterly and annual financial reports confirming compliance with tax legislation and license conditions;
• anti-money laundering (AML) reports – companies must identify customers and monitor suspicious activity;
• transactions, providing information to the Central Bank of Brazil (BCB);
• annual independent audits to confirm the accuracy of financial activities and compliance with security standards;
• Reports to the Ministry of Finance (via the SPA) – income, tax payments, and compliance data are sent to the Secretariat for Prizes and Betting (SPA).

Companies are also required to strictly comply with advertising requirements. Advertising of the gambling business in Brazil is strictly regulated by the Ministry of Finance and must comply with national legislation, including the indication of taxes, tariffs, and age restrictions. It is prohibited to use celebrities, make misleading statements about the chances of winning, and portray gambling as a way to solve financial problems. Only licensed operators that have been officially approved by the regulator may promote their services.

Companies are required to strictly comply with the rules and provide financial reports promptly.

Penalties for non-compliance

Companies operating licensed online gambling activities in Brazil must strictly comply with applicable laws and regulations. In the event of regulatory violations, various penalties are available, including:

1. Warnings. Initially, when non-compliance is identified, the regulator may issue a formal warning. This allows the company to remedy the violation without incurring more severe penalties.
2. Financial penalties. Depending on the severity of the violation, a company can be fined up to 2 billion Brazilian reals (about USD 342 million). The amount of the fine is determined by the nature of the violation, its consequences, and the degree of damage to consumers and the state.
3. Revocation of authorization. In case of serious or systematic violations, the regulator may revoke the online gambling license, which will lead to the immediate termination of the company's operations in Brazil.
4. Prohibition on obtaining a new license. Companies that have committed serious violations can be barred from re-licensing for up to 10 years. This prevents the possibility of resuming operations in the market in the short term.
5. Ban on participation in public tenders. Violators may be banned from bidding for public services and concessions within the federal public administration for at least 5 years.
6. Disqualification from leadership positions. Individuals responsible for violations may be disqualified from serving as a director or administrator in companies engaged in gambling activities for up to 20 years. This applies to both existing and future businesses in the gambling industry.

Taxation and financial obligations

Licensed online gambling operators in Brazil are required to pay a number of taxes and fees regulated by Law No. 14,790 and subsequent regulations. The main tax rates include:

• Gross gaming revenue (GGR) tax – 12% of the total amount of bets minus winnings paid out. This tax goes to the state budget and is distributed to various social and sports programs.
• Corporate income tax (IRPJ) – 15% of the company's net profit. If the annual profit exceeds BRL 240,000, an additional rate of 10% applies.
• Social contributions (CSLL) – 9% of taxable income goes to the social security fund.
• Municipal service tax (ISS) – usually between 2% to 5% depending on the municipality where the company is registered.

In addition, licensees must take into account the costs associated with registering on official government platforms and complying with regulatory requirements.

For more information, visit the official website of the Brazilian Federal Revenue Service (Receita Federal).

Conclusion

Brazil represents a promising jurisdiction for obtaining a gaming license, as the country’s gambling market is growing strongly and offers operators opportunities to generate high profits and enter one of the largest economies in the region. However, it is important to note that the legal framework for gambling activities in Brazil is still not fully defined, which can make it difficult to navigate the licensing requirements.

In such circumstances, it is essential to seek expert advice to help navigate the legal intricacies and provide legal support throughout the licensing process. Gofaizen & Sherle has extensive experience with FinTech, Crypto, and Gambling projects, making it a reliable partner for obtaining a gambling license in Brazil. She specializes in tailor-made solutions, taking into account the specificities of clients’ business models, and will help you choose the most appropriate type of license depending on the specifics of your company’s business.

Gofaizen & Sherle experts will not only prepare all the necessary documents but also provide full legal support, which will allow you to complete the licensing process and comply with the legal requirements of Brazil.