Brazil sets final filing deadlines for betting operators’ closure

The Ministry of Finance’s Secretariat of Prizes and Betting has issued Ordinance SPA/MF No. 3,005 for operators whose fixed-odds betting authorizations will be extinguished under Provisional Measure No. 1,394 of 25 September 2026.

Published in the Official Gazette on 2 October 2026, the ordinance sets procedures and final deadlines for closure-related regulatory, financial, accounting, registration and reporting obligations. It applies to Ministry of Finance-authorized operators within the affected cohort, not to every betting operator in Brazil.

A 7 October balance filing

Operators must keep the Secretariat’s records current throughout the closure and transition period. Changes to registration data, correspondence addresses, telephone numbers or official email addresses must be reported within 48 hours under Article 2, paragraph 1. The designated legal representative remains responsible for obligations arising from the end of operations and the transition period.

The refund process starts with a filing through the Betting Management System, or SIGAP. Under Article 3, operators must submit final wallet balances and the balance of the transactional account used to move betting funds. The balance position must be calculated at 23:59:59 on 5 October 2026 and transmitted to the Secretariat by 7 October.

The filing must identify the financial or payment institution holding the transactional account, the operator’s CNPJ, its brands, each bettor’s CPF and date of birth, the refund amount and the destination account details. Operators must also provide the date on which refund information was sent to the institution responsible for making the payment. The Secretariat will specify the required formats and data structures.

A 15 December regularisation deadline

The ordinance separates the refund-data deadline from the broader regularisation period. Article 4 requires affected operators to complete regulatory, financial, registration, accounting and reporting obligations by 15 December 2026, unless the ordinance or a later Secretariat act sets a specific deadline.

Financial duties include conclusively calculating, issuing payment guides for and paying all amounts owed to the legal recipients under Law No. 13,756/2018, based on betting revenue collected through the final date for accepting bets. Operators must also report amounts calculated, paid and unpaid and respond to Secretariat notices or investigative requests by 15 December.

Extinguishing an authorisation, dissolving the company or entering liquidation does not remove obligations incurred while the operator was active. Each operator must designate a legal representative to follow outstanding obligations until they are fully regularised.

The instrument also provides a conditional procedural benefit. Administrative sanctioning proceedings suspended under Article 13 of the provisional measure may be definitively closed for an operator that proves timely and complete compliance with the transition obligations. The Secretariat must first issue a Conclusive Regulatory Compliance Certificate after reviewing SIGAP records and statutory payments.

That outcome is conditional. If the operator has not met the requirements in Articles 3, 4 and 5 after the relevant deadline, the Secretariat will order the suspension of related sanctioning proceedings to be lifted.

Non-compliance with the ordinance or the relevant provisions of the provisional measure can trigger the penalties in Article 41 of Law No. 14,790/2023. The ordinance also says that partners and administrators may be liable according to their culpability.

The 7 October SIGAP filing is the next specified operator deadline. The ordinance leaves the required formats, structures and validation rules to technical specifications that the Secretariat is to make available, making that publication the next official implementation signal to monitor.