Regulation

Brazil Moves to Ban Loyalty Programmes and Cashback: What Operators Need to Know

17 March 2026 · 5 min read · iGamingUK

A new bill introduced in the Brazilian Senate this week seeks to strip licensed betting operators of virtually every retention tool in their commercial arsenal — from loyalty schemes and cashback to gamification and personalised marketing. For operators active in Brazil, or considering market entry, the implications are significant.

What does Bill No. 1018 actually propose?

Senator Eduardo Girão — one of the most consistent critics of legalised gambling in Brazil — published Bill No. 1018 this week, seeking to amend Law No. 14,790, the legislation that legalised online betting in Brazil in December 2023.

The scope of the proposed restrictions is broad. If passed, the bill would prohibit licensed operators from establishing, maintaining or disclosing any mechanism designed to incentivise, retain or stimulate gambling. In practical terms, that means:

  • Loyalty, rewards and points programmes — banned outright
  • Cashback on losses or deposits — prohibited
  • Promotions conditional on deposit, balance maintenance or continued platform activity — not permitted
  • Gamification features including goals, missions, challenges and player rankings based on betting activity — prohibited
  • Personalised communications intended to encourage gambling based on a player's previous betting history — banned

Only communication described as "informative, institutional or educational" would remain permitted under the bill. Operators would have 90 days from publication to adapt their platforms and contracts if the legislation passes.

The context: welcome bonuses are already gone

It is worth noting that Brazil already prohibits welcome bonuses for licensed operators — a restriction that placed the market at odds with how most international operators approach customer acquisition. Girão's bill would go considerably further, targeting the retention side of the commercial equation that operators have leaned on since acquisition incentives were removed.

The cumulative effect of these restrictions, if enacted, would leave licensed Brazilian operators with fewer promotional tools than almost any comparable regulated market in the world. No welcome offer. No ongoing loyalty mechanics. No cashback. No personalised outreach. The commercial model being proposed is closer to a utility than a competitive consumer product.

Girão's rationale — and why the industry pushes back

Girão's justification is consistent with the position he has held since before legalisation. He argues that gambling's economic logic depends on the repeated financial loss of players, and that the state has a duty to limit mechanisms that accelerate that loss. The bill's framing explicitly targets what it describes as the "socially adverse effects" of the sector.

This argument has been made before, and the industry's counter-argument is equally consistent: retention tools in regulated markets are not the problem. The problem is unregulated operators, who operate without any of the consumer protections that come with a licence — responsible gambling tools, KYC, AML, complaints processes. Restricting licensed operators aggressively does not eliminate demand; it redirects players to platforms that offer no protections at all.

That dynamic played out visibly earlier this month when President Lula called for online betting to be banned outright. Industry observers were quick to point out that banning a legal product with documented demand does not make the demand disappear — it makes it harder to address responsibly.

Is this likely to pass?

Brazilian gambling regulation has been in a state of near-constant flux since Law 14,790 came into force. The legislative environment is polarised, with genuine political will both to protect the legal market that has been created and to restrict it further. Girão's bill is not the first of its kind and may not be the last.

The practical political calculus is complicated. Brazil's licensed betting sector represents significant tax revenue, employment, and technology investment. Operators have made material commercial commitments based on the framework established at legalisation. Substantially restricting the commercial toolkit available to those operators — particularly in ways that have no clear parallel in comparable regulated markets — creates a legitimate question about the viability of the licensed market itself.

That said, dismissing the bill as unpassable would be complacent. The broader political mood around gambling in Brazil has shifted in a restrictive direction, and legislators who might otherwise support a functioning legal market are under pressure to demonstrate responsiveness to harm concerns.

What should operators do?

For operators currently active in Brazil, the bill warrants active monitoring rather than immediate operational change. It has been introduced but not yet progressed through committee — there is a significant distance between a Senate bill and enacted law. However, the direction of travel in Brazilian gambling regulation is clear enough that prudent operators should be stress-testing their commercial models against further restrictions, not assuming the current framework is stable.

For operators considering Brazilian market entry, the regulatory uncertainty is a material factor in the investment case. The market is large, the growth trajectory is real, and the licensed framework provides a legitimate operating basis. But anyone entering Brazil now needs to do so with eyes open to the possibility that the commercial rules of the game could change significantly within their planning horizon.

The more fundamental question the bill raises is one of regulatory philosophy. Restrictions on retention mechanics do not, in themselves, reduce gambling participation — they shape where that participation happens. A licensed operator with no loyalty programme, no cashback and no ability to communicate with its player base is at a structural disadvantage against unlicensed alternatives that offer all three. Regulators and legislators who genuinely want to reduce gambling harm need to grapple with that reality rather than treat licensed operators as the primary problem to be solved.

Operating in Brazil or planning market entry?

iGamingUK provides operational consultancy and managed services for casino operators in regulated and emerging markets. If you are navigating the Brazilian market or evaluating entry options, get in touch — we respond quickly and are available 7 days a week.