What the license requires
A betting license is not a single document — it is the outcome of three blocks of requirements that all have to be met at once. Failing any one of them blocks or suspends the authorization.
| Block | What the SPA requires |
|---|---|
| Corporate | A legal entity incorporated in Brazil — either an Ltda. (limited liability company) or an S.A. (corporation) — with an active CNPJ (the Brazilian company tax ID) and national headquarters, with at least one member of the controlling group able to show knowledge and experience in gaming, betting, or lotteries |
| Technical | Robust IT infrastructure, games sourced from certified providers, a player-support and ombudsman structure, and the ability to generate auditable reports |
| Financial | Proof of economic and financial capacity, accounting documentation, and payment of the license fee |
None of these blocks substitutes for another: a company with strong capital but a platform that is not technically compliant does not get authorized — and the reverse is equally true.
What the license fee covers
Law No. 14,790/2023 caps the license fee at a maximum of R$30 million, covering the use of 3 commercial brands operated across the legal entity's electronic channels per authorization act (Art. 12, sole paragraph). SPA/MF Ordinance No. 827/2024 set that fee at the full cap: the authorization is granted for a 5-year term on payment of R$30 million, covering up to three brands per authorization act (Art. 5, I).
The detail that matters is that the three-brand ceiling is per authorization act, not per company. A group that wants to run more than three brands has to request additional authorizations, and each granted act carries another R$30 million license fee, R$5 million in financial reserves, and R$15 million in paid-in share capital (SPA/MF Ordinance No. 827/2024, Art. 11, § 4).
As for what happens at the end of the 5 years: neither Law No. 14,790/2023 nor SPA/MF Ordinance No. 827/2024 sets out a renewal procedure for the authorization. An operator planning beyond that term should confirm the conditions in force with the SPA/MF and specialized legal counsel rather than assume automatic renewal.
The license fee is just one line item in the cost of entry — it sits alongside the corporate structure, the platform's technical compliance, and ongoing proof of financial capacity, which together make up the real investment required to enter the regulated market.
Is there a difference between a federal and a state license?
Yes, and the difference is territorial rather than one of exclusivity. Ruling on ADPFs 492 and 493 and ADI 4986, Brazil's Supreme Federal Court (STF) rejected a federal monopoly over lottery services: states may operate them too. The limit came later. In ACO 3696, upheld by the full court in a virtual session closing on 28 February 2025, the STF ordered Loterj and the State of Rio de Janeiro to stop accepting fixed-odds bets placed outside their territory, holding that states may operate and regulate lottery activity only within their own territories, and that only the federal government may run the service in a format that crosses state lines. Then in ADI 7640, decided on 12 September 2025, the STF struck down the restrictions that had barred a single economic group from operating lotteries in more than one state and had confined advertising of those services to the authorizing state's territory.
What this means in practice: a state lottery authorization only reaches bettors inside that state. For a fixed-odds operation with a nationwide audience — sportsbook, online casino, crash games — the authorization that counts is the federal SPA/MF one, and a state license is not a substitute. Sustaining nationwide activity on the basis of a state accreditation remains the subject of ongoing regulatory and judicial challenge.
What happens to operators without a license
Operating without SPA/MF authorization has stopped being a tolerated gray area. Unlicensed platforms that accept Brazilian players are subject to access blocking by internet service providers, restrictions on payment rails — including cutting off access to PIX, the main deposit and withdrawal method in the country — and other sanctions provided for by law.
That enforcement net tightened sharply in 2025 and 2026. Law No. 15,358/2026 inserted Art. 21-A into Law No. 14,790/2023, requiring financial and payment institutions to block the accounts of operators the competent authority has identified as irregular, plus Arts. 24-A to 24-C, which impose integration with fraud-signal sharing systems, enhanced due diligence, and dedicated safeguards inside the PIX payment scheme; it also made carrying advertising for an unauthorized operator an administrative infraction (Art. 39, XII, and Art. 40, III). Decree No. 13,033/2026 implemented Art. 21-A, setting out the procedure for blocking accounts and forfeiting funds to the federal government. And Complementary Law No. 224/2025, Art. 6, made both payment institutions that process transactions with unauthorized operators after formal notice and anyone advertising those operators jointly liable for the taxes owed on the activity. Together, that makes informality a choice with growing legal, financial, and reputational risk rather than a viable medium-term alternative.
For anyone entering the market, the license should be treated as a business prerequisite, not a formality to sort out later: the corporate structure, the technology platform, and the financial proof all need to advance in parallel, because authorization is only granted once all three blocks are ready at the same time.