Brazil’s fledgling regulated betting market faces potential upheaval as Senator Eduardo Girão introduces legislation that would fundamentally reshape how operators engage with customers. Bill 1018/2026 proposes amendments to Law No. 14.790/2023 that would eliminate cashback programmes, loyalty schemes, and gamification mechanics across licensed platforms.

The proposal arrives barely a year into Brazil’s formal regulatory framework, targeting retention strategies that have become standard practice across mature iGaming markets.

If enacted, operators would face a comprehensive reworking of their customer relationship management infrastructure.

Scope of Proposed Restrictions

The legislation introduces Article 29-A, which would prohibit fixed and variable cashback offers, points-based loyalty programmes, and any rewards calculated from player losses. Equally significant are restrictions on gamification elements, think promotional missions, challenges, leaderboards, and tiered VIP structures that encourage progression through increased play.

Communications would face strict limitations. Operators could no longer deploy personalised marketing based on individual betting history, a cornerstone of modern digital customer engagement. Email campaigns, push notifications, and targeted messages referencing past wagers would be prohibited outright.

The bill also mandates transparency requirements around recommendation algorithms, compelling operators to disclose how their platforms influence betting behaviour.

Regulatory Rationale

Senator Girão’s justification centres on what he characterises as operators circumventing the existing ban on welcome bonuses through indirect incentive structures. The proposal argues that cashback, gamification, and loyalty mechanics create a system of continuous behavioural conditioning. Vulnerable users are particularly affected, he claims.

The legislation calls for the Ministry of Finance to establish technical criteria identifying compulsive betting patterns, positioning consumer protection as the primary policy objective.

Market Implications

Should the National Congress approve the measure, operators would face a 90-day compliance window from publication. This compressed timeline would force rapid operational changes across an industry still establishing itself in the Brazilian market.

The proposal represents one of the most restrictive regulatory approaches globally. Whilst European markets have introduced controls on bonus structures and advertising, few jurisdictions have attempted such comprehensive elimination of retention mechanics. We’re talking about uncharted territory here.

For operators, the commercial calculation becomes stark. Brazil’s enormous market potential must be weighed against a regulatory environment that would prohibit fundamental tools for customer acquisition and lifetime value optimisation. The legislation effectively challenges whether a commercially viable business model remains possible under such constraints.

The bill’s progress through Brazil’s legislative process will be closely watched across the global industry. Its outcome may signal whether Latin America’s largest market proves welcoming to international operators, or whether regulatory overreach creates an environment where sustainable business becomes untenable.