Brazil’s SPA Maps 2026/27 Agenda: Licensing Overhaul and Caixa Regulation Finally on the Table

Brazil’s Secretariat of Prizes and Bets (SPA) has published its regulatory roadmap for 2026/27, and if you read between the lines, it’s essentially an admission that Year One didn’t go quite as planned. The new agenda, formalized through Normative Ordinance No 408, prioritizes licensing procedure reviews and enforcement against illegal operators—both areas that should have been watertight before the market even opened.

But here we are. The SPA is essentially going back to fix the plumbing while the house is already occupied.

Systems Thinking 101

Let’s be clear about what’s happening here. Brazil launched one of the world’s most anticipated regulated betting markets, and now the regulator is publicly stating it needs to review the licensing process itself. This isn’t routine housekeeping—it’s a tacit acknowledgment that the criteria for approvals, rejections, suspensions, and terminations may not be working as intended.

This is systems thinking in action. When a regulatory framework requires fundamental review within its first operational year, it suggests the initial design didn’t adequately account for real-world complexity. The root cause? Likely a combination of political pressure to launch quickly, underestimation of enforcement challenges, and the classic regulatory trap of drafting rules in a vacuum without sufficient industry consultation.

The agenda’s structure tells the story: Q1 focuses on licensing and payment blocking—the foundational elements that should have been bulletproof from day one. The fact that Caixa Loterias regulation isn’t scheduled until Q3 2027 reveals the political minefield surrounding the state lottery monopoly’s role in the new market.

Q1 2026: Fixing the Front Door While Closing the Back Door

The SPA’s Q1 priorities reveal a two-front war. First, there’s the licensing review, examining why some operators got in, others didn’t, and whether the criteria are actually serving the market’s stated goals. Second, there’s the payment blocking mechanism—Brazil’s primary weapon against offshore operators.

The review of Normative Ordinance No 566, which established reporting protocols for illegal betting payments, suggests the Pix-based blocking system isn’t performing as hoped. Payment blocking is only effective if it’s fast, accurate, and doesn’t create collateral damage. If the SPA is reviewing procedures this early, expect stories of legitimate transactions caught in the crossfire or illegal operators finding workarounds faster than regulators can adapt.

The affiliate advertising review in Q1 is particularly telling. Affiliate marketing is the lifeblood of player acquisition in regulated markets, but it’s also where compliance gets messy. Affiliates operate in gray zones, often pushing boundaries on responsible gambling messaging and bonus promotions. The fact this made the top-tier priority list suggests the SPA has seen enough concerning activity to warrant immediate attention.

Mid-Year Priorities: Retail and Responsible Gambling

Q2’s focus on fixed-odds betting through physical terminals addresses a uniquely Brazilian challenge. The country has a massive retail infrastructure for lottery products, and integrating sports betting into that network requires careful regulation. Get it wrong, and you create accessibility problems that undermine responsible gambling efforts.

Speaking of which, Q3’s responsible gambling initiative—including tools for bettors to monitor their own activity—is arriving fashionably late. Most mature markets build these features into initial licensing requirements. Brazil is retrofitting them after launch, which means operators built their platforms without these requirements in mind. Expect integration challenges and operator pushback on technical specifications.

The Caixa Elephant in the Room

The most politically charged item sits at the end of the timeline: Caixa Loterias regulation in Q3 2027. Caixa holds Brazil’s federal lottery monopoly and was supposed to launch sports betting in 2025. Political interference delayed that indefinitely, creating an awkward situation where the state-owned entity watches private operators capture market share in a product category it was promised.

Scheduling this review for Q3 2027—18 months from now—signals either extreme political sensitivity or genuine uncertainty about how to integrate Caixa into the competitive landscape without creating unfair advantages. Possibly both.

The systemic issue here is structural: how do you maintain a state lottery monopoly in traditional games while allowing competition in sports betting, especially when the lines between product categories increasingly blur? The SPA is essentially kicking this can down the road, hoping time provides clarity. Spoiler: it won’t.

Leadership Vacuum and Regulatory Continuity

The ordinance was signed by acting chief Daniele Correa Cardoso, following Regis Dudena’s recent departure. Leadership transitions in a regulator’s formative phase create continuity risks. Policy priorities shift, institutional knowledge walks out the door, and operators face uncertainty about enforcement philosophy.

If Cardoso becomes permanent, her first major test will be executing this ambitious agenda while maintaining market confidence. The 2025/26 agenda promised much—including advertising regulation updates that were subsequently overtaken by the Senate’s aggressive ad ban proposal—suggesting political forces often override regulatory planning.

The Broader Industry Implications

For operators, this agenda signals a maturing regulatory environment that will likely become more demanding, not less. The licensing review could result in stricter requirements or even license revocations for operators not meeting enhanced standards. The payment blocking review suggests more sophisticated enforcement mechanisms are coming.

For the global industry watching Brazil, this is a masterclass in the challenges of launching a major regulated market. You can’t simply copy-paste European or North American frameworks onto Brazilian political, economic, and social reality. The SPA is learning this in real-time, which means operators should expect ongoing regulatory flux for at least another two years.

The Reality Check

Brazil’s betting market will be fine—the demand is massive, the opportunity undeniable. But the path to regulatory maturity will be messier and longer than the initial optimism suggested. The SPA’s 2026/27 agenda is less a roadmap than a repair manual, addressing foundational issues that should have been resolved before launch.

The question isn’t whether Brazil will get there. It’s how much market disruption, operator frustration, and player confusion occurs along the way. Based on this agenda, the answer is: plenty.