Key Points
- Brazilian households lost BRL62.5 billion ($12.5bn) to betting operators in 2025 — 69% above the BRL36.9bn recorded by the Ministry of Finance’s own regulator.
- The BRL25.6bn gap between the two estimates matches LCA Consultores’ finding that illegal operators hold between 41% and 51% of Brazil’s total betting market, costing the state up to BRL10.8bn in lost tax revenue each year.
- A Bolsa Família betting ban enacted in late 2025 measurably slowed Pix transaction growth, confirming that lower-income welfare recipients represent a material share of Brazil’s online sports betting market.
Brazil’s Two Sets of Betting Numbers — and Why the Gap Is the Real Story
Brazilian households lost BRL62.5 billion ($12.5 billion) to betting operators in 2025. The figure is net: total money wagered minus winnings returned. It comes from the third edition of the Fiscal Bulletin of Brazilian States, produced by Comsefaz — the National Committee of Secretaries of Finance — in partnership with the Celso Furtado International Centre for Development Policy, using Central Bank data and payment statistics from EPAE (Statistics on Payments by Economic Activity).
Brazil’s federal betting regulator, the Secretariat of Prizes and Betting (SPA), recorded a very different number. Its data shows regulated operators generated approximately BRL36.9 billion in gross revenue for the same period. The BRL25.6 billion difference between the two figures is not a rounding discrepancy. It is the size of a market the official record cannot see.
Measured against household income, the BRL62.5 billion loss equals approximately 0.68% of Brazil’s gross disposable household income — a proportion small enough to look manageable on paper, large enough to register as a real constraint on family spending across a country of 215 million people.
The Illegal Market Is Taking Close to Half the Revenue
The BRL25.6 billion gap between Comsefaz and SPA figures has an explanation, and it points directly at Brazil’s unlicensed betting sector. LCA Consultores, commissioned by the Brazilian Institute of Responsible Gaming (IBJR), estimated in June 2025 that between 41% and 51% of Brazil’s total online betting market operates on unregulated platforms. The BRL25.6 billion shortfall in official figures represents roughly 41% of the Comsefaz total — the precise lower bound of LCA’s estimate.
The black market is not only a revenue loss but a tax loss. The IBJR determined that platforms without regulation caused an estimated tax loss of BRL10.8 billion to Brazil every year – a tax loss that would have been enough, according to the institute, “to pay the yearly salary of 184,000 basic education teachers.” In addition, the survey behind the LCA report discovered that 73% of Brazilian gamblers had used at least one illegal betting platform in 2025, and 78% did not recognise licensing.
Authorities have not been passive. More than 11,000 unauthorised domains were taken down during 2025. A follow-up LCA study published this week found the illegal market’s share had narrowed slightly to between 38% and 44% in the first half of 2026, compared to the 41%-51% range recorded a year earlier. Progress, but not resolution: at its current pace, close to half of every real wagered in Brazil still bypasses the licensed market and its tax obligations entirely.
ANJL Challenges the Comsefaz Methodology
The National Association of Games and Lotteries (ANJL) rejected the Comsefaz conclusions. The trade body argued that the study failed to separate regulated betting companies from the wider range of arts, culture, sports and recreation businesses that also receive Pix transfers, inflating the apparent betting total. ANJL president Plínio Lemos Jorge has separately argued that betting volume figures are routinely misread, because money deposited on a platform is often placed as successive bets within a single session — cycling through the system several times before it leaves the operator’s hands.
The Comsefaz methodology accounts for this to a degree. Researchers projected the expected baseline volume of Pix transfers to businesses in the relevant sectors, modelled on what would have occurred without the regulatory change, and treated the deviation from that baseline as attributable to betting operators. The authors themselves noted the result is a statistical estimate, not a proven causal link.
Lemos Jorge’s broader criticism carries weight in a different register. He has repeatedly warned that imposing heavy taxes and advertising restrictions on licensed operators risks making legal platforms less competitive against the unregulated market — exactly the dynamic the Comsefaz gap illustrates.
How Pix Became the Window Into the Market?
The Comsefaz report examined Pix flows between October 2024 and March 2026. During 2025 alone, betting-related companies processed BRL350.97 billion in Pix transactions. The bulk of that circulated back to users as winnings; BRL62.5 billion represents what remained with operators. What the Pix data captured was a structural shift in payment patterns: after mandatory registration rules for betting operators came into force on 1 January 2025, transfers from individuals to companies in the arts, culture, sports and recreation sectors rose sharply against the projected baseline.
The scale of licensed market activity is visible in tax receipts. Brazil collected BRL9.95 billion in betting tax revenue across all of 2025. In the first five months of 2026 alone, the sector generated BRL5.89 billion — an 85.88% increase on the same period a year earlier. Those figures reflect the licensed market only. If the illegal share were brought into the regulated framework, official tax estimates suggest annual revenue could more than double.
The Welfare Data That Moved the Numbers
The most direct evidence in the Comsefaz report links lower-income households to the betting market. When Brazil banned Bolsa Família welfare recipients from accessing betting platforms in late 2025, the observed volume of Pix transactions fell closer to the researchers’ projected baseline. The statistical effect was measurable, confirming what previous Central Bank data had already made clear.
In August 2024, Brazil’s Central Bank found that approximately 5 million Bolsa Família beneficiaries transferred BRL3 billion to online betting platforms in a single month — around 20% of the programme’s total monthly disbursement. The Federal Court of Accounts reported that by January 2025, Bolsa Família recipients spent BRL3.7 billion on betting in that month alone, representing 27% of all benefits paid out.
Following a Supreme Federal Court ruling, the Ministry of Finance published Normative Ordinance No 2,217/2025 in October 2025, formally banning all Bolsa Família and BPC (Continuous Benefit Payment) recipients from fixed-odds betting platforms. Operators were required to cross-check registrations against a government CPF database at signup and at each daily login. By 1 December 2025, approximately 900,000 beneficiaries had been blocked from accessing betting platforms.
What the Gap Means for Regulation?
Brazil’s Supreme Federal Court resumed proceedings on the legal framework governing betting in August 2026, with Justice Luiz Fux’s vote suspended pending review. A staggered tax increase already in motion sets the GGR-based rate at 13%, rising to 14% in 2027 and 15% from 2028.
The fundamental conflict presented in the Comsefaz bulletin is not the clash of two different statistical data sets. Rather, it is the clash between two different markets, the first one being regulated, having tax payments and consumer protection measures and registering losses that the government can track and the second one working completely outside of these requirements and absorbing around fifty per cent of all bets. The BRL25.6 billion discrepancy cannot be bridged through modifying the calculation methodology.
Expert Analysis
The Comsefaz study lands at a moment when Brazil’s regulatory debate is pulling in three directions at once: higher taxes on licensed operators, stricter advertising rules, and intensifying legal scrutiny of the market’s architecture. Each pressure, taken alone, has a reasonable justification. Together, they risk making the licensed market less attractive relative to the unregulated alternative — widening the very gap the bulletin measures.
IBJR president Fernando Vieira put the contradiction plainly in June 2025: “Paradoxically, just five months after setting operating conditions with legal operators, the government rewards illegals with a tax increase for the regulated ones. Everyone ends up losing — operators burdened with taxes, bettors without the protection of formal market rules, and the government, which by stimulating illegality, will ultimately harm its own tax revenue.”
The slight reduction in the illegal market’s share — from 41%-51% in 2025 to 38%-44% in H1 2026 — shows enforcement is producing results, however slowly. Whether that trajectory continues, or stalls under the weight of competing regulatory pressures, is the question the next Comsefaz bulletin will answer.
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