backOn June 2, 2025, Brazil’s National Consumer Secretariat (Senacon) and the Consumer Protection Secretariat of the State of Rio de Janeiro (Sedcon-RJ) released Joint Technical Note Sedcon-RJ and Senacon/DPDC/MJSP No. 01/2025 (“Joint Technical Note”), which had been previewed at an event in May. The document provides an overview of the current landscape of the fixed-odds betting market in light of consumer protection legislation and federal regulations, with a particular focus on advertising practices used by operators and third parties.
Identified risks and abusive practices
The Joint Technical Note highlights a number of irregular and abusive commercial practices that pose risks to consumers in the betting sector. Key concerns include:
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The operation of unauthorized platforms that exploit inexperienced or vulnerable consumers, contributing to over-indebtedness;
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The ineffectiveness of responsible gambling tools, such as loss limits, session time controls, self-exclusion features, and warning messages;
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Use of unrestricted bonus strategies without clear terms or adequate transparency, creating information asymmetries;
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Misleading or abusive advertising, including unrealistic claims of easy winnings, downplaying of risks, and encouragement of repeated betting as a strategy for success.
Advertising regulations for betting operators
Advertising in the fixed-odds betting sector is subject to strict regulatory constraints, particularly within the digital environment. According to the Joint Technical Note, key obligations include:
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Prohibition of advertising that suggests easy money, promotes excessive betting, or associates gambling with personal success, confidence, or popularity;
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Prohibition of involving minors in advertising campaigns or placing ads in environments primarily frequented by underage audiences;
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Mandatory inclusion of clear warnings regarding age restrictions and the risk of addiction to ensure informed consumer choice;
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Joint and several liability of operators for the advertising practices of affiliates, influencers, and third-party contractors;
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Requirement for operators to maintain advertising materials and contracts for inspection, enabling oversight of the full advertising dissemination chain and helping prevent abuses, especially in the digital context.
Institutional cooperation and next steps
The Joint Technical Note also references Technical Cooperation Agreement MF/MJSP No. 2/2025, signed between Senacon and the Ministry of Finance (through the Secretariat for Prizes and Betting – SPA), which establishes a framework for joint market supervision and enforcement.
Planned initiatives under this effort include:
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Joint public awareness campaigns and production of informational materials for consumers and members of the National Consumer Protection System (SNDC);
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Training programs and educational activities to strengthen understanding of the fixed-odds betting sector among SNDC authorities;
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Development of protective measures to mitigate over-indebtedness among bettors;
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Exchange of data and information between involved entities to support regulatory oversight;
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Creation of a direct communication channel between SPA and Senacon to facilitate cooperation and improve response to sector-related issues.
The Joint Technical Note underscores the growing importance of coordinated and proactive regulation of the betting industry, particularly in view of its expansion and the vulnerability of consumers exposed to aggressive digital marketing. Law firms and advisors working with betting operators, affiliates, or marketing partners should closely monitor these developments to ensure compliance and mitigate legal and reputational risks.
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