Provisional Measure No. 1.394/2026 has produced a measurable opposite effect to its stated purpose: Bet Legal identified 428 new illegal betting sites between the ban's announcement and Sunday, September 27 — roughly 143 per day, against a baseline of 13.7 new illegal domains daily recorded between June and August.
The enforcement picture behind that number is stark. Brazil's Prizes and Betting Secretariat runs its oversight operation with four employees, responsible for monitoring close to 200 authorized websites alongside thousands of illegal operators. Of the R$1 million allocated in 2026 for oversight, R$275,600 has been spent.
LCA Consultores estimates illegal operators already account for 38% to 44% of the market. The ban does not shrink that share — it removes the regulatory architecture that applied to the legal side: facial biometrics, deposit limits, credit-card restrictions, self-exclusion tools, and daily blocks on Bolsa Família and BPC beneficiaries. None of those apply to illegal platforms.
The fiscal exposure compounds the enforcement problem. Brazil collected R$9.9 billion from the sector between January and August 2026, up 69% in real terms year-on-year. The proposed 2027 budget carries R$5.3 billion in expected sector revenue. The government has said it will not refund the R$2.55 billion paid by 85 licensed operators for five-year concessions. Around 180 industry executives and lawyers are now moving toward a joint Supreme Court challenge.