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The Brazilian gaming market went into a new round of debate after the publication of a Technical Note by the National Association of Games and Lotteries (ANJL) to the Secretariat of Prizes and Betting (SPA) of the Ministry of Finance. The letter, submitted on September 22, questions the constitutionality of the recently published “API of Restricted Users” under the SIGAP system, that automates the exclusion of beneficiaries of Bolsa Família and Continuous Benefit Program (BPC) from fixed-odds betting sites’ CPF (taxpayer ID).
The laws, published in the Federal Official Gazette on October 1, 2025, seek to prevent vulnerable communities from engaging in online gambling. However, according to the ANJL, the action goes beyond what the Supreme Federal Court (STF) previously determined and raises issues of constitutionality, legitimacy, and potential unforeseen consequences.
Divergence from Supreme Court Decisions
The ANJL Technical Note refer expressly to the STF’s precautionary judgment in Direct Actions of Unconstitutionality (ADIs) 7721 and 7723, confirmed by the Court’s plenary session in November 2024. In the judgment, the Court prohibited the use of social benefit funds for gambling. But it did not prohibit gambling by beneficiaries using money obtained from other sources.
By preemptively blocking all recipients of Bolsa Família and BPC, without discrimination on the origin of the funds, the new API may be being setting constraints not authorized by law or by judicial decision. The association believes that it is an overreach of the law and contrary to the principle of legality of the democratic state.
Risks of Driving Players to the Illegal Market
In addition to legal complications, the ANJL also anticipates practical consequences that would follow from the blanket prohibition. According to Plínio Lemos Jorge, the president of the ANJL, the prohibition would supposedly have the opposite of the intended effect.
“Instead of protecting Bolsa Família and BPC recipients, the action could push them into the illicit betting sector, which does not have responsible gaming safeguards, no limits on spending or time, and no state regulation. This would increase the risks of insolvency and compulsive gambling“, he argued.
This type of transition to non-regulated platforms would be contrary to the efforts of the government for responsible gaming and would render the overall impact of regulation in Brazil’s gambling market less powerful.
Civil Rights and Service Standards
The association also cites Law No. 13.460/2017, which guarantees citizens the right to proper provision of public services and prohibits restrictions not specifically authorized by law. From this perspective, the automatic ban may be understood as infringing civil liberties by restricting individuals’ access to regulated platforms without express legal grounds.
The ANJL further notes that the creation of precedents to arbitrary limitation is a dangerous path for civil liberties and the rule of law.
Technical and Structural Challenges
The Technical Note further indicates another factor: the technical sophistication of reporting and compliance requirements on operators. As ANJL further observes, the need for real-time checking and blocking through the new API places an enormous technical burden on betting operators’ systems.
“Though this aspect is not yet fully defined in the current regulations, the Association has been conducting training seminars, workshops, and publishing guidelines in an effort to guide the market through this process“, said Lemos Jorge. He added that the industry already had a learning curve in place for standardizing and reporting data and that the new API introduces an additional layer of operational complexity.
A Policy and Law Debate
The ANJL action reflects an intensifying debate across Brazil’s licensed betting industry. On the one hand, policymakers and regulators seek to safeguard vulnerable segments from potential gambling harm. On the other, market players and legal experts warn against excessive restrictions that could prove unconstitutional, counterproductive, or both.
The outcome of this conversation will not only establish the legal boundaries of responsible gambling policies but also determine the working relationships of Brazil’s rapidly evolving betting industry.
Source: BNL Data
