Currently, only betting operators (the so-called 'Bets') are directly subject to Brazil’s regulatory framework and supervised by the Secretariat of Prizes and Betting (SPA) of the Ministry of Finance (MF).
However, the regulator is preparing to expand its regulatory perimeter to cover other actors in the betting value chain — the so-called B2B providers.
Through Project No. 7 of its 2025–2026 Biennial Agenda, the SPA/MF announced its intention to regulate B2B providers to strengthen enforcement against the illegal and unlicensed market, ensuring that all critical components of the betting ecosystem — such as online game providers and aggregators, platform suppliers, and odds providers — operate under uniform standards of security, integrity, and transparency.
This marks a step toward the consolidation and verticalization of Brazil’s regulatory framework, aiming to ensure full accountability across the entire production chain.
The Secretariat’s proposal aligns with best practices from more mature jurisdictions, such as the United Kingdom and Malta, pioneers in regulating suppliers of critical components for betting operations.
In the UK, for instance, the UK Gambling Commission enforces a specific licensing regime for software suppliers, imposing requirements for suitability, security, governance, and incident reporting, ensuring that only pre-authorized companies can provide systems, games, and technology infrastructure to licensed operators.
In Malta, the Malta Gaming Authority (MGA) applies a similar model through the Critical Gaming Supply Licence (B2B), which requires proof of financial integrity, technical capability, and the appointment of key function holders responsible for essential operations.
In Brazil, regulation is expected to follow a similar trajectory, adapted to local market conditions.
The upcoming B2B regulation is likely to draw on parameters already applied to certification laboratories under Ordinance SPA/MF Nº 300 de 2024, which defines four categories of requirements — legal, fiscal and labor, suitability, and technical — as conditions for operational recognition before the SPA.
It is therefore reasonable to assume that this qualification model will be extended to critical service providers in the betting sector, ensuring that only companies that are legally established, financially solid, technically competent, and demonstrably reliable may integrate the operational infrastructure of betting activities.
Given the range of activities encompassed by Project 7 of the Biennial Agenda, the SPA is expected to adopt a segmented regulatory framework, with specific rules for each type of B2B provider and a set of convergent general guidelines to ensure consistency and integration across the regulation.
Among these, a prior authorization procedure should apply to all market participants, requiring qualification and verification of the nature and scope of their activities.
The expansion of the regulatory perimeter thus represents an important institutional milestone, aligned with international best practices.
By requiring that most critical actors within the betting ecosystem comply with standardized oversight and compliance rules, Brazil seeks to reinforce the security, integrity, and credibility of its regulated market — and, above all, to curb the growth of illegal operations.
Udo Seckelmann
Lawyer, Head of the Sports Betting and Cryptoassets Department at Bichara e Motta Advogados, Professor at CBF Academy, and Master in International Sports Law from the Instituto Superior de Derecho y Economía (ISDE) in Madrid.
Pedro Heitor de Araújo
Law student at PUC-Rio, working in Cryptolaw and Gambling Law at Bichara e Motta Advogados since 2022. As an analyst and researcher, he focuses on the legal dynamics of cryptoasset regulation, decentralized finance (DeFi), betting, and gaming.
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