Brazil's Betting Ban: What Changes in Your Fintech App

Brazil's betting ban began on September 25, 2026, with Provisional Measure 1,394. Since then, a fintech's app has to refuse Pix (Brazil's instant payment system), TED and boleto payments going to fixed-odds betting and only let through the wind-down of operations and refunds to bettors. Whoever holds a betting operator's account returns the balances within seven days.

This article reads Provisional Measure No. 1,394 and the Central Bank resolutions from the perspective of those who build the product, with texts checked on October 14, 2026. How your operation is classified remains a question for the fintech's legal team.

In 2025, Wama designed and developed the app for Cappta, a payment institution that offers payment acquiring and white-label digital accounts. In an app like that, what the Central Bank and the app stores require from the app already defines the architecture; the provisional measure adds a destination rule to every transaction.

What does the betting ban change in a fintech app?

The provisional measure prohibits operating, offering, brokering and advertising fixed-odds betting, including by companies abroad, on sports and online games (art. 1). Other authorized lotteries are excluded. In the product, the change lands in four places.

• Transaction engine: Pix, TED and boleto payments going to betting operators are refused (art. 14 and BCB Resolutions 590, 595, 596 and 597).

• Exception: winding down operations and refunding bettors remain allowed.

• Back office of whoever holds a betting operator's account: refunds by CPF (Brazil's individual tax ID) within seven days, a report to the Secretariat of Prizes and Betting (SPA) and the remainder sent to Caixa (art. 9).

• Communication: betting ads come out of the app, the website and partnerships (art. 16).

The institution's website remains subject to what already applied to the fintech website as a compliance asset; the provisional measure affects the app and operations.

Who is affected by the betting ban?

The prohibition in art. 14 applies to financial institutions, payment institutions, scheme owners and other participants in payment schemes, including instant payment schemes. BCB Resolution 590 sets the date of the duty: since September 25, without depending on the scheme changing its rules (art. 1, § 2). Four roles touch different code:

In Banking as a Service, the obligation falls on the authorized institution, and those who build on Banking as a Service receive the rule from it as an integration requirement.

Where does the prohibition live in Pix, TED and boleto?

Each rail got its own article, all effective upon publication.

• Pix: BCB Resolution No. 597 added item XI to art. 32 of the Pix Regulation.

• TED: BCB Resolution No. 595 binds both the issuing and the receiving institution.

• Boleto: BCB Resolution No. 596 doesn't repeat the refund exception, which applies through the provisional measure and Resolution 590.

• All schemes: BCB Resolution No. 590, of September 28, covers cards and the rest.

In the product, this becomes a single rule in the transaction engine, before settlement, not three patches per rail. Items IX and X of the same art. 32 are covered in what BCB Resolution 587 requires from the app. The rule doesn't say how to identify that the receiver is a betting operator: the method is up to the institution, documented.

Which transactions does the system still need to let through?

Those needed to wind down operations and refund bettors (art. 14 of the provisional measure; art. 1, § 1, of Resolution 590). An engine that refuses by destination without looking at the purpose blocks exactly the money the provisional measure orders returned. The safest design separates three paths:

1. Payment to a betting operator: refused, with the reason recorded.

2. Outflow from the operator's account to the bettor: allowed when it's part of the refund, linked to the list sent by the operator.

3. New credit to the operator's account: refused, except redemption of assets holding bettors' funds (art. 7, § 1).

On screen, the refusal explains the reason in plain language, without exposing the anti-fraud logic; the refusal message the Pix manual calls for serves as a basis.

How does the 7-day refund work?

Whoever holds an operator's transaction account executes the refund. The operator had ten days to go offline (art. 7) and, two days later, sends the list of bettors with CPF, amount and source account (art. 8, II). From receipt, the institution has seven days to refund (art. 9). The back office needs to support:

1. Importing the list sent by the operator and checking the CPFs.

2. Paying preferably into the source account, if active and owned by the bettor, or into another account with the same holder (§ 1).

3. Recording the reason for each amount not refunded.

4. Sending the SPA the itemized report of refunded and non-refunded amounts (§ 2).

5. Transferring the remainder to a specific account at Caixa, under the supervision of the Ministry of Finance (§ 3).

The provisional measure doesn't define the report's layout or channel, nor the deadline for the transfer to Caixa, according to a law firm analysis published on October 1, which recommends an audit trail for each step. At Milhas Pix, an airline miles marketplace with Pix payments, Wama designed everything from the acquisition page to the transaction tracking screens: that per-item tracking is exactly what a refund batch demands.

What has the Central Bank not published yet?

The procedure in art. 15: electronic data communication for rejecting transactions and interbank refunds of illegal betting funds in Pix. As of October 14, 2026, it hadn't come out; BCB Normative Instructions 778 to 781, the most recent ones, deal with other matters. To adopt it without a rewrite:

• a destination rule isolated in a service, like the Pix limits engine, with versioned criteria;

• the refusal reason as structured data, not free text;

• the refund as its own transaction, linked to the original.

Arts. 21-A and 24-A to 24-C of Law 14,790 (blocking accounts of unlicensed operators, signs of fraud and filters in Pix) remain in force, according to a legal analysis from October 6. Transactions linked to unlicensed operators are reported to Coaf, Brazil's financial intelligence unit (art. 28).

Advertising and app stores: what comes out of the app

The provisional measure prohibits advertising, marketing and sponsorship of betting in any medium, including content that makes access easier (art. 16, § 1), with removal within ten days. In the fintech's app, review banners, cashback and partner offers that led to betting, payment shortcuts to operators and third-party content, since the application provider has a duty of care (art. 19). App stores must block betting apps (art. 21), and the fine for the provider can reach 10% of the group's revenue in the country (art. 22).

Timeline through November 2026

The provisional measure's page in Congress listed 97 amendments on October 14. The text may change when it becomes law, so the rule in the system needs to be configurable.

How to put Provisional Measure 1,394 into the scope of whoever builds the app

1. Confirm the institution's role with legal: payer, receiver, holder of a betting operator's account or scheme owner.

2. Separate screen, system and routine: refusal and offer removal are design; the destination rule and refunds are engineering; the SPA report and the remainder sent to Caixa are operations.

3. Write into the contract the effective date of each deliverable and who owns the system's code.

At Wama, a single person is accountable for the project from briefing to deploy, and AI enters the code through Claude Code, always with human review. When the client needs to own the code, the project goes to custom development; a SaaS MVP costs between US$ 4,000 and US$ 20,000, up to US$ 40,000 depending on complexity.

Common mistakes

• Blocking without exceptions. Refusing outflows from the operator's account blocks the refund the provisional measure requires.

• Handling only Pix. TED, boleto and cards were covered too.

• Refusals with no recorded reason. The report and the art. 15 procedure turn into rework.

Frequently asked questions

Since when does a fintech need to block transactions to betting operators?

Since September 25, 2026, the publication date of Provisional Measure 1,394. BCB Resolution 590 confirmed that the duty applies since then and doesn't depend on the scheme changing its rules. Pix, TED and boleto got rules in BCB Resolutions 597, 595 and 596, effective upon publication.

Can a fintech let any betting-related payment through?

Yes, when the transaction is needed to wind down the operator's operations or to refund bettors. Otherwise, payments to betting operators are refused. In the operator's account, new credits are also prohibited, except the redemption of assets holding bettors' funds.

How long does the institution have to return bettors' money?

Seven days from receipt of the list with CPF, amount and source account. The refund goes, preferably, to the source account, if active and owned by the bettor. At the end of the period, the institution sends a report to the SPA and transfers to Caixa whatever it couldn't refund.

Has the Central Bank defined how to reject betting transactions in Pix?

Partly. The prohibition already applies through BCB Resolution 597, which amended the Pix Regulation. Still missing is the procedure in art. 15 of the provisional measure, for electronic communication for rejections and interbank refunds, which hadn't been published as of October 14, 2026.

Can Provisional Measure 1,394 still change?

Yes. A provisional measure has the force of law from publication, but it must be converted by Congress by November 23, 2026, a deadline extendable for another 60 days. On October 14, the measure's page listed 97 amendments. That's why the rule in the system should be configurable.

If your fintech needs to bring the betting ban into the transaction engine, the refusal screen and the refund routine within the same scope, talk to Wama.