Brazil’s betting industry group, National Association of Games and Lotteries (ANJL), cautions that any attempt to restrict the online gaming market or reverse the existing legislation may result in fiscal, legal, and consumer protection issues. According to the group, stricter limits won’t curb the demand but may instead fuel the market for unregulated gaming.
Recent statements from the National Association of Games and Lotteries underscore an emerging concern in Brazil’s regulated industry. Instead of seeing legal operators as the source of risk, ANJL believes that the biggest challenge now is cutting the share of betting that takes place outside regulated channels.
Revenue Risks Move to the Center of the Debate
According to the group, the public finance question is also in place. Based on data cited from Brazil’s Ministry of Finance, ANJL says that a reversal of the current system could cost the government up to BRL 80 billion in taxes collected over the course of five years.
The estimate also carries broader implications beyond the betting industry. It connects the potential loss to public spending plans, including investments related to Constitutional Amendment Proposal 18/2025. Therefore, the debate is no longer about whether betting should be tightly regulated. It’s also about whether Brazil can afford to lose ground in a market it’s only recently begun to formalize.
The legal barriers may prove to be as daunting. Operators with licenses have invested around BRL 2.6 billion in authorization fees alone, according to the association. If the market were suddenly restricted or shut down after these investments, Brazil may face damage or lost profits suits from operators entering under the existing regulations.
ANJL Says the Illegal Market Would Benefit First
ANJL took the opportunity to differentiate clearly between regulated platforms and offshore or underground operators. Citing the data from Instituto Esfera, the group noted that approximately 52% of betting activities in Brazil still occur at unregulated websites.
That idea is at the core of the association’s argument. ANJL believes that limiting legal operators may strengthen sites that do not adhere to responsible gambling principles, cannot block minors, and are harder for the government to monitor. Therefore, regulation may lose its value if users end up using the channels outside the legal framework.
The group cited the 2025 Ministry of Finance data showing the gambling activity in Brazil tends to be relatively low in monthly value. According to the figures, about 95% of the total bets come from people who bet less than BRL 70 monthly. The average bet is around BRL 110.
Lessons From Other Regulated Markets
To support its case, the association gave the examples of Germany and the Netherlands. In these jurisdictions, previous attempts at tightening regulations had not eliminated unlicensed gaming activities. The argument ANJL is making is that the pressure from the black market only relaxed after those jurisdictions reviewed the legal options and eliminated the excessive barriers for users.
Additionally, ANJL has reaffirmed its willingness to assist federal agencies and offer technical input. Therefore, the group is arguing not for deregulation, but for a policy approach that prioritizes directing consumers towards the legal market.
