Brazil’s MP 1.394: A Licensed Market Closed by Decree

A licence tells you where you may operate. It does not tell you for how long.

Brazil answered that question on 25 September, by decree. Provisional Measure 1.394 shuts down fixed-odds betting completely. Where the operator is based doesn’t matter: if the bettor is in Brazil, the ban applies. Every authorisation granted under the 2023 betting law ends 30 days after publication. Operators had ten days to take sites and apps offline. The measure is now being challenged in Brazil’s Supreme Court, where a ruling on interim relief is expected after the election runoff.

Official figures put it at 85 authorisations, each a five-year permit at R30million,soR2.55 billion paid in. Under the measure, none of that fee comes back.

And this is a market that only opened, properly regulated, in January 2025. Less than two years later, those R$30 million permits end 30 days after the decree was published. We often see a licence treated as the finish line for jurisdictional risk. Brazil shows it is the start of a different one: the risk that the rules themselves change.

“A licence is a permission, not a hedge. When we work with a client on a licensing roadmap, one question goes on the table early: if this market closed next month, which part of the business still stands?” Alexander Zheltukhin, Head of Licensing, OpiniQ

It’s a far easier conversation to have on a quiet day. We have it with licensing teams market by market, before they need it.