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Brazil MP 1.394: Where Things Stand

Brazil MP 1.394: Where Things Stand

The measure

Provisional Measure 1.394, published on 25 September 2026 and in force on publication, prohibits the operation, offer and advertising of fixed-odds sports betting and online games in Brazil, including state authorizations. Other lottery products authorized by law are not affected.

Licenses granted under Law 14.790/2023 are extinguished 30 days after publication, with no refund of license fees under the text. Congress has 120 days to convert the measure into law.

Where things stand

  • Players: Deposits have been barred since 25 September. Withdrawals remain open until 23:59 on 5 October. Government estimates reported in the press put balances still held in player accounts at about R$1.7 billion.
  • Supreme Court (STF): Industry associations ANJL and IBJR asked Justice Luiz Fux to suspend the measure, or at least exempt licensed operators. On 28 September the Attorney General’s Office (AGU) asked for 72 hours to respond. On 29 September the national mayors’ association (ANPV) filed ADI 8028, asking for suspension before 5 October or a transition of at least 180 days. No decision yet.
  • Congress: The measure has been received. A separate bill criminalizing the operation and promotion of betting reached Congress on 28 September. Party leaders say the matter will be discussed after the election, with a transition period, treatment of license fees and possible carve-outs among the changes under discussion.
  • Industry: Associations have announced legal action over license fees and investments. Sponsorship and advertising contracts are being unwound ahead of the 5 October deadline.

Upcoming timeline

DateEvent
1 OctAGU response window closes. A ruling by Justice Fux on the injunction requests  may follow.
4 OctFirst round of the general elections
5 Oct, 23:59Deadline for voluntary withdrawals. Deadline to remove all advertising, marketing and sponsorship   material
6 Oct, 00:00Sites and apps blocked by internet providers, app stores and CGI.br. Visitors redirected to a page on  balance refunds
7 to 8 OctOperators report remaining balances, by taxpayer ID (CPF), to their financial  institutions.
9 to 14 OctBanks return remaining balances to players. From 14 Oct, Caixa Econômica Federal handles   blocked cases.
25 OctLicenses under Law 14.790 extinguished (30 days after publication). Presidential runoff, if   required.
Nov to DecCongressional leaders expected to agree a process and rapporteur. The measure is valid for 60 days,   extendable by 60.
Early 2027The 120-day clock pauses during the congressional recess, so a final vote could fall in February 2027, with   the new legislature.

What to watch

  • Whether the Supreme Court suspends or limits the measure before 6 October.
  • The post-election agreement in Congress: rapporteur, transition period, license fees and scope.
  • How effective blocking of offshore sites and payments proves once licensed operators are offline.
  • The future structure of the Secretariat of Prizes and Betting (SPA) and its data and payment-control systems.

Prepared by Alex W. Pariente, Founder and Principal, Pariente Advisory. Sources: MP 1.394/2026 (Diário Oficial da União, 25 Sep 2026); Senado Notícias; BNLData; iGaming Brazil; InfoMoney; Gazeta Brasil; Atlas Público.

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