Brazil’s Betting Ban Surfaced 543 Illegal Sites, But Most Were Already There

Key Points

• Of 322 flagged sites with known domain purchase dates, 320 were registered before September 25; only 2 came after the ban.
• 38-44% of online betting in Brazil was already estimated to be on illegal platforms before the provisional measure.
• The inter-agency enforcement committee was instituted on September 25 but had no operational framework until September 28.

Detected Does Not Mean Created

President Lula signed Provisional Measure 1,394 on September 25, and the numbers arrived fast. Bet Legal had already flagged 41 unlicensed betting sites within the first hour. By Monday afternoon, the tally reached 543, quickly framed across industry coverage as a surge of illegal operators moving in after the ban. The monitoring data makes a more precise case.

Bet Legal, operated by cybersecurity firm Iron Security, records three separate dates for every site it identifies. Those are the domain purchase date, the security certificate date and the first detection date. Of 322 sites with confirmed purchase dates, NEXT.io’sreporting on the underlying data shows 320 had domains registered before the provisional measure. Only 2 were purchased after the ban came into force. Those pre-existing domains averaged roughly 10 months old, with some dating to the late 1990s. Iron Security itself cautions that registration dates do not show when a domain became a betting platform; older domains can be repurposed long after their original purchase, sometimes years later.

Detection, domain registration and active operation are three distinct measurements, and conflating them produces a misleading headline. Continuous monitoring began September 20, five days before the ban, leaving no earlier baseline. Sites are verified individually as unlicensed operators and cross-checked against Brazil’s official licensed registry before they appear on the list. Affiliate pages, duplicate addresses and domains listed for sale are all excluded.

A separate BNLData survey, produced for an industry body using a wider capture methodology that does not individually verify each listing, found 6,401 new sites between September 22 and 28. Diego Terrani, CEO of Iron Security, explained the methodological difference clearly: “A count that multiplies to 3,000 on Sunday, while the other publishes 76, is recording a different event.” Both systems reflect real monitoring activity; they are simply not measuring the same thing.

Between 38% and 44% of Online Betting Was Already Outside the Law

An August 2026 study by LCA Consultoria Econômica estimated that 38-44% of online betting activity in Brazil was on illegal platforms in the first half of 2026. Commissioned by the Brazilian Institute for Responsible Gaming, the research drew on a survey of 2,291 bettors in May, finding that 77% had used a platform operating outside regulatory standards. By June, Brazil’s Justice Minister confirmed that 25.2 million Brazilians were still using unauthorised platforms, despite more than 40,000 illegal sites already blocked at that point. “We are talking about illegal betting representing something between 41% and 51% of the market operating legally,” the minister stated.

Enforcement had been growing throughout the year. In June, Lula signed a decree to freeze assets tied to illegal betting operators, directing frozen funds to Brazil’s National Public Security Fund. Between January 1 and September 22, Brazil’s regulator had already referred 57,691 web addresses to Anatel for blocking. The ban did not produce the illegal market it now has to police; it found one that years of enforcement had been unable to contain.

The Framework Was Instituted Before It Was Operational

Provisional Measure 1,394 took immediate legal effect on September 25 and, on the same date, instituted an inter-agency enforcement committee. A separate decree issued on September 28 then established the committee’s composition, responsibilities and operational procedures. As of September 25, discussions between the government and Anatel on how domain blocking would function had not yet taken place.

On September 27, a joint task force from the Ministries of Justice and Finance announced the takedown of 506 suspected illegal betting sites. Investigators from Ciberlab also identified roughly 1,960 Google advertisements linked to seven betting domains, served to Brazilian users between September 25 and 27. On Meta’s platforms, investigators documented seven individual advertisements; two had begun running on September 25 itself, after the prohibition was already in force. TikTok presented a distinct problem: its advertising library did not include Brazil as a searchable option, leaving that channel entirely outside the enforcement review.

By September 29, Brazilian authorities had formally requested the blocking of 5,209 betting sites, rising sharply from the 506 confirmed just two days earlier. According to secondary industry reporting, the Secretariat of Prizes and Betting had just four dedicated oversight staff covering both authorised and illegal operators simultaneously, though this figure has not been confirmed through a primary government source.

Courts Fill, Operators Count the Damage

ANJL and the Brazilian Institute for Responsible Gaming jointly petitioned Brazil’s Supreme Federal Court, asking Justice Luiz Fux to suspend the provisional measure while Congress reviews it. A third body, Anseja, filed a separate unconstitutionality action. Both argue the government did not demonstrate the urgency required under Brazilian constitutional law, noting that the regulatory framework now being dismantled was created by the same government in December 2023.

Listed operators moved quickly to set out their exposure. Flutter Entertainment and Entain both issued financial warnings about the ban’s impact. Per Flutter’s own SEC filing, the company projects an approximately $70 million reduction to 2026 revenue and a 20 million reduction in adjusted EBITDA if the ban holds through year-end. Entain, which had expected Brazil to represent roughly 5% of its online net gaming revenue this year, moved its full-year profit outlook to the lower end of its £910-£960 million guidance range. Operators had each paid R30 million for their federal licences, totalling R$2.55 billion across 85 authorisations. The provisional measure explicitly rules out refunds or compensation for those investments. Brazil’s regulated market had only existed since January 2025.

“The clandestine websites have expanded their offerings and continue to operate outside the law and oversight,” said ANJL President Plínio Lemos Jorge. “Now, they will take advantage of the prohibition of legal betting to attract bettors to the illegal market.” The ANJL warns that 31 million people currently using licensed platforms, each subject to age verification and taxpayer ID checks, could lose those safeguards entirely.

Expert Analysis: What the Evidence Supports and What It Does Not?

The Bet Legal data confirms that a large illegal betting market existed in Brazil well before September 25. What it does not establish is that 31 million licensed users have moved, or will move, to illegal platforms after October 6. That migration is what the regulated industry warns is probable, and the concern is grounded in the market’s documented history, but the actual movement of bettors had not been measured at the time of publication. The two should not be conflated.

The structural problem the evidence does raise is harder to sidestep. Between 38% and 44% of online betting was already on illegal platforms before the ban. The enforcement committee was instituted and made fully operational three days apart. By September 29, the blocking list had already jumped from 506 to 5,209 sites in 48 hours, illustrating both how rapidly the illegal side expands its address pool and how limited address-by-address takedowns are against operators running dozens of domains at once.

Speaking to journalists in São Paulo on September 25, Lula was blunt: “It’s like cancer, you take out the tumour, or the tumour will kill us.” We do not question the urgency behind that instinct. What we do question is the sequencing. The tumour already occupied 38-44% of the market before the procedure was announced. After October 6, the licensed operators disappear from the board. The illegal market, which held a substantial share before the ban, simply continues. Whether displacing the regulated operators first, before the enforcement machinery was fully assembled, reduces total illegal activity or just removes the portion that was operating within the rules is the question October will have to answer.