Aposta Ganha CPO: Looking back on Brazil’s start
Elvis Lourenço, Chief Product Officer at Aposta Ganha, reflects on Brazil’s first regulated Q1, and what we can expect going forward.
The long-awaited start of the regulated sports betting and online gaming market in Brazil began in January 2025 – but far from being smooth sailing, the first quarter was marked by turbulence, legal disputes, user migration and strict compliance measures. The good news? The industry is already showing signs of maturity, and the next steps are set to position Brazil as one of the most important markets in the world.
In this article, we analyse the key events of the first three months of regulation and what lies ahead.
Mandatory KYC and mass migration: A 60% drop in active users
The year began with a major operational and commercial challenge for licensed operators. With the new regulations in effect, all users were required to complete the full KYC (know your customer) process, including document verification and facial recognition at the time of registration.Although the measure aims to protect players and ensure system integrity, the immediate impact was severe:
• Operators reported an average reduction of over 60% in their active user base, compared to the peak recorded in November 2024.• Conversion rates dropped drastically due to friction in onboarding and lengthy verification processes.• Many players migrated to offshore, unregulated platforms, which still offer quick sign-up and aggressive bonuses.
This scenario exposed a strategic problem: The rigidity of the registration process could, paradoxically, empower illegal gambling if not accompanied by educational initiatives and improvements to the user experience.
Victory in the Supreme Court: The end of legal uncertainty with LOTERJ
In parallel with operational challenges, the industry faced a legal battle with serious commercial implications: The controversial activity of LOTERJ, the state lottery of Rio de Janeiro, which granted licenses for operators to operate across the national territory without complying with federal regulations.
In early March, the Supreme Federal Court (STF) ruled against this unrestricted territoriality, and the Secretariat of Prizes and Betting (SPA/MF) emerged strengthened by the decision.
The outcome:
• Federal authority over national licensing was reaffirmed.• Operators working under state licenses are now required to regularize under the federal model.• The market gained legal certaintyto grow in a structured and predictable way.
The decision also discouraged other states from pursuing similar paths, closing a chapter of regulatory uncertainty and conflict.
B2B Countdown: Mandatory certifications incoming
Another important milestone in Q1 was the beginning of the certification process for B2B companies, which provide content, games, platforms and payment solutions.
According to current regulation, all providers must submit the following by April 2025:
• Technical certifications issued by accredited laboratories.• Proof of game integrity and certified RNGs (random number generators).• Compliance with LGPD (data protection), consumer protection and responsible gaming standards.
Operators that continue using uncertified providers face sanctions and possible license revocation. This move ensures that the entire ecosystem – not just operators – complies with the rules.
Crackdown on illegal gambling
Aware that the migration of players to unlicensed platforms increased following the implementation of mandatory KYC, the Ministry of Finance intensified its crackdown on illegal gambling.
The Ordinance MF/SPA No. 566, issued on March 20, 2025, marked a new phase in enforcement. Key measures include:
• Blocking domains and apps of unauthorized operators.• Coordinated actions with the Central Bank, financial institutions and payment gateways to disrupt financial flows.• Educational campaigns to warn consumers about the risks of using illegal websites.
The goal is to protect players, strengthen the regulated ecosystem and increase tax collection, which depends on player migration to legal operators.
What’s next? The regulatory roadmap ahead
With the first months of the regulated market marked by operational challenges and institutional progress, Q2 2025 will focus on consolidation and the implementation of essential regulatory pillars. Based on the Regulatory Agenda of the Secretariat of Prizes and Betting (SPA/MF), here are the key initiatives underway:
Launch of the National Betting Monitoring System
The SPA is preparing to roll out the Betting Monitoring and Audit System, a strategic tool that will enable:
• Real-time tracking of events and bets recorded in the regulated market;• Detection of suspicious patterns and prevention of match-fixing;• Generation of structured data for supervision, intelligence and transparency purposes.
This system will be a milestone in control and integrity, aligning Brazil with international best practices.
Consolidation of responsible gambling programs
As a central pillar of the regulatory model, the SPA will intensify the implementation and enforcement of responsible gambling programs, requiring operators to:
• Offer tools for voluntary self-exclusion and limits on time and spending;• Monitor risky behaviors, with alerts and automated interventions;• Promote educational campaigns on conscious gambling and support channels.
These requirements aim to protect players and reinforce the credibility and sustainability of the regulated market.
Compliance with the 2025 Regulatory Agenda According to the SPA’s presentation in February, the coming months will include:
• New regulatory acts, including rules on advertising, AML (anti-money laundering) and match-fixing prevention;• Technical guidelines for auditing, certification and internal controls of licensed operators;• Cooperation with other public authorities, including the Central Bank, Federal Revenue Service and law enforcement.
The agenda is being executed with transparency and is continuously updated on the Ministry of Finance’s official portal.
Conclusion: A turbulent start, but a promising future
The first quarter of Brazil’s regulated betting market was undoubtedly a stress test for the entire industry. The loss of active users due to mandatory KYC, the legal battle with LOTERJ, and pressure on B2B and operators to adapt were expected growing pains in a maturing market.
On the other hand, institutional victories, strengthened federal oversight and action against illegal gambling show that Brazil is on the right track. With improvements in player onboarding and increased regulatory stability, Brazil is poised to become one of the leading global hubs for online betting by the end of 2025.
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