Brazil's B2B Betting Regulation: What the Industry's Top Voices Are Saying

The first chapter of Brazil's regulated betting market was about getting operators licensed. The second is about everyone who powers them. The framework that launched the legal market was built around operators, by design and by necessity. But regulation, like any living system, expands to fill the space around it. Public Consultation 001/2026, published by the Secretaria de Prêmios e Apostas (SPA), signals that the next frontier is the supply chain itself.

To make sense of what Public Consultation 001/2026 actually means in practice, we convened four of the country's most experienced voices, across legal, technical, compliance, and operational perspectives, to examine the framework and what it demands from everyone in the supply chain.

The webinar was moderated by our Director of Regulatory Affairs, Valter Delfraro Junior, and ran for over an hour. We covered the regulatory logic behind the consultation, its technical implications for game development, compliance obligations under Brazil's anti-money laundering framework, and the practical challenges facing B2B companies, domestic and international alike, that want to operate in the country.

Meet the Panelists

Simone Vicentini — Founding Partner, Vicentini Advogados Former Deputy Secretary at the SPA (Ministry of Finance), Simone was one of the architects of Brazil's early regulatory framework, including the credentialing system for testing laboratories. She now advises operators and suppliers on licensing and compliance through her own firm.

Fabiola Jaeger — CEO & Co-founder, Caleta Gaming With 16 years in the gaming industry, Fabiola leads Caleta Gaming, a Brazilian-founded studio with over 150 games across 10 categories and licenses in Malta, Bahamas and Colombia. She brings deep expertise in mathematical modeling, game design and the technical realities of operating across multiple regulated jurisdictions.

Fred Justo — Director of AML & Integrity, Legitimus Fred spent years as a regulator at the SPA, where he was the principal author of Portaria 1143 — Brazil's landmark anti-money laundering regulation for the betting sector. He is also a member of the Clean Game Committee of the Brazilian Olympic Committee and now leads integrity at Legitimus, which holds approximately 70% of the KYC market in Brazil by number of licensed brands.

Hugo Baungartner — CPO, Grupo Esportes Game Brasil With 28+ years in gaming, Hugo oversees product strategy for Esportes da Sorte, Onabet and Loto. He is a specialist in strategic partnerships, M&A and market expansion across Latin America, and has been one of the most vocal operators pushing international suppliers to formalize their Brazilian presence.

The Regulatory Logic: Why B2B Suppliers Are Now in Scope

Brazil's initial regulatory architecture placed the operator at the center of everything. That was a choice driven by urgency rather than permanent design. As Simone Vicentini explained, it was always meant to be a starting point, not a ceiling.

According to her, the model until now was structured around the operator because of the urgency of getting the regulated market started. But suppliers are not mere accessories. They are critical partners. Regulating the full supply chain eliminates blind spots where there is currently no visibility.

The consultation covers six categories of B2B providers: betting system providers (PAM), betting platform providers, sports betting providers, online game providers, KYC service providers and sports betting data providers. Rather than a traditional license with an upfront fee, the proposed framework mirrors the credentialing model already used for testing laboratories, a mechanism designed to make de-credentialing faster and more operationally efficient when non-compliance is detected. The absence of a formal outorga is not a weakness. It means the regulator can move quickly when it needs to.

One of the most significant clauses in the draft is the obligation for credentialed suppliers to report operator irregularities directly to the SPA. This is not a minor procedural addition. It turns every B2B partner into a compliance checkpoint, restructuring the logic of accountability across the entire supply chain.

From the operator's side, Hugo Baungartner framed the consultation as long overdue. He estimates that as many as 30% of international suppliers have yet to formally establish a presence in Brazil, often held back by fiscal uncertainty or corporate hesitation. His position on the matter left little room for ambiguity.

"If you don't adapt, you don't come in. I can't put our license and our operation at risk. I've already told all our platform providers: whoever doesn't comply simply won't be in our ecosystem."

Technical Implications: What Game Providers Need to Know

Fabiola Jaeger offered the sharpest technical critique of the discussion. Her central concern is that the framework groups all "online game providers" into a single regulatory category, treating game studios, content aggregators and live casino studios as interchangeable when they have fundamentally different operational profiles.

"Each does something fundamentally different, so each should have different obligations and a different type of authorization. A game studio makes content; an aggregator distributes it from multiple sources; a live studio involves an entirely different production infrastructure. Lumping them together is not correct."

She also raised concerns about existing provisions in Portaria 1207, the technical standard for online games, that conflict with basic principles of game design. Among them: a prohibition on mystery prizes, despite those prizes being determined by RNG, and a requirement that the maximum prize must be guaranteed to occur within a defined number of rounds, which is fundamentally at odds with how randomness works. To put it plainly, the regulation, as written, describes a game that cannot mathematically exist.

A further issue discussed was inconsistency between certified laboratories. When multiple labs interpret the same regulatory text differently, suppliers receive contradictory guidance and end up making retroactive corrections after games are already live. Clearer regulatory language, or a unified interpretation process, would reduce costs and instability for everyone involved.

On the positive side, there is a concrete opportunity embedded in the consultation. Once suppliers are formally recognized, the current "brand report" bottleneck, which requires a laboratory certificate for every new operator-provider connection, could be significantly simplified. As Valter noted: "The brand report exists because the SPA currently has no direct relationship with the provider. Once it does, a lot of this will be revisited."

AML, KYC and the Compliance Imperative

Fred Justo, who authored Portaria 1143 during his time at the SPA, made clear that extending compliance obligations to B2B suppliers was always part of the plan. It was a matter of sequencing, not intention.

"The suppliers need to understand that they are part of a chain. Whoever is alongside the operator shares in both the responsibilities and the rewards. The culture of integrity must be carried into the B2B layer."

He disclosed that in the weeks before the webinar, the SPA had already begun notifying operators about KYC non-compliance, in some cases identifying failures through simulated registrations. Under the new framework, a KYC provider that identifies a systematic failure would be legally obligated to first alert the operator and, if unresolved, escalate directly to the regulator. The door, as Fred described it, is now a regulated threshold.

"We are the gateway. We are the ones opening and closing the door when a CPF arrives for registration. That is a real responsibility, and now it needs to be formally acknowledged."

He also pointed out that Brazil's betting sector was fully compliant with the ECA Digital before it came into force, a concrete measure of the sector's regulatory maturity relative to other industries, and a strong counter-argument to those who question its social responsibility credentials.

International Benchmarks and Brazil's Tax Complexity

Drawing on Caleta's experience in Bahamas, Malta and Colombia, Fabiola offered a comparative view of international regulatory models and a clear caution against importing frameworks wholesale without adapting them to Brazil's specific texture.

She highlighted Peru's approach to unauthorized game distribution as a model worth studying: a portal that automatically notifies game providers when their content appears on unlicensed platforms, requiring them to trace and account for the distribution chain. "If your game ends up on an illegal site, you should be barred from the legal market. Once the SPA requires that, all intermediaries are forced to open the chain."

One of the most candid moments of the webinar dealt with Brazil's tax environment. Fabiola described repeated difficulties explaining Brazil's layered fiscal structure, PIS, COFINS, ISS, IRPJ, CSLL, to international partners accustomed to straightforward VAT-based systems. She also raised the commercially sensitive issue of Gaming Tax pass-through: some operators currently require game providers to absorb the tax as a condition of contracting, compressing already thin margins.

"With RTPs at 95 to 97%, margins are thin. If I absorb the Gaming Tax on top of that, something has to give, and in the end, the biggest loser is the player. We need to clarify who pays what and make the commercial framework more flexible."

This is not an abstract concern. If Brazil's regulatory framework is perceived as fiscally opaque or commercially unworkable by international suppliers, the 30% who have yet to formalize their presence may choose to stay out entirely. The consequence is not just fewer providers. It is less competition, thinner product variety and a narrower range of choices for the Brazilian consumer.

What Happens Next — and What You Should Do Now

The consultation period closed on March 23, 2026. At the time of the webinar, fewer than a dozen substantive contributions had been submitted. All four panelists urged industry participants to file before the window closed, noting that well-structured technical input from the private sector is one of the most effective instruments for shaping the final text.

Once the SPA has reviewed submissions, the expectation is that a final portaria could launch the credentialing process in the second half of 2026, triggering a six-month transition clock for suppliers currently operating without formal authorization.

If you don't have a Brazilian entity yet, the time to open one is now. CNPJ registration, a local bank account and a Brazilian representative are the baseline requirements signaled by the draft portaria.

If you already operate in Brazil, review your documentation against the published draft. The framework closely mirrors the requirements applied to operators under Portaria 827. Pay particular attention to the AML policy and internal controls requirements flowing from Portaria 1143.

If you supply operators but haven't engaged with the consultation, seek specialist legal advice. The proposed obligation to report operator irregularities changes the risk calculus of every B2B relationship in the market. You need to understand what that means for your contracts and your compliance architecture before the framework goes live.

Conclusion: A New Competitive Standard

What the webinar made clear is that Brazil's B2B regulation is not a bureaucratic checkbox exercise. It is a structural recalibration of who participates in the regulated market and on what terms. The four voices Oddsgate brought together, representing legal, technical, compliance and operational perspectives, converged on a single conclusion: the suppliers who treat this as a competitive opportunity rather than a compliance burden will be the ones best positioned in the market that emerges.

Brazil's regulated market is young, but it is moving fast. The SPA has signaled that the tolerance period for grey-area supply-chain arrangements is coming to a close. As Valter Delfraro put it in his closing remarks: "In Brazil, there are only two sides — the legal game and the illegal game. The choice, and the responsibility, belongs to each member of the industry."

This article is based on the Oddsgate Webinar on Public Consultation 001/2026 on B2B Supplier Regulation in Brazil's Betting Market, broadcast in March 2026. Oddsgate is a B2B iGaming technology company headquartered in São Paulo, Brazil.