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Ano XIX - nº 44

BETS – RESTRICTIONS TO THE BENEFICIARIES OF THE BOLSA FAMÍLIA AND CONTINUOUS CASH BENEFIT PROGRAMS – ORDINANCE SPA/MF NO. 2,217 AND NORMATIVE INSTRUCTION SPA/MF NO. 1,231

27 de October de 2025 | Publications

On September 30, 2025, the Secretariat for Prizes and Betting (SPA) of the Ministry of Finance (MF) published Ordinance No. 2,217, amending Ordinance SPA/MF No. 1,231 of July 31, 2024, to include item VIII to Article 8, which requires that betting operators must block registration or use of their betting systems by individuals who are beneficiaries of the social welfare programs known as Bolsa Família [1] or Continuous Cash Benefit (BPC) [2].

With this measure, SPA complies with the provisional remedies granted by the Federal Supreme Court in the Direct Actions for the Declaration of Unconstitutionality No. 7,721 and 7,723, as well as with the recommendations of the Federal Accounting Court (TCU) in the lawsuit TC 023.126/2024-8, in order to prevent the use of benefits received in the two social welfare programs mentioned above, to place bets in the fixed-odds format, also known as “Bets”.

On the same day, Normative Instruction SPA/MF No. 22 was also published. It outlines the procedures that betting operators must adopt to identify beneficiaries of both social welfare programs and prevent their registration on betting platforms or participation in betting activities. It also sets forth the rules for the possible removal of users from these platforms.

In this regard, betting operators must consult the Betting Management System (SIGAP) to verify whether a user is listed as a beneficiary of the Bolsa Família or the BPC programs [3]. The SIGAP query code is the user’s Individual Taxpayer Registry (CPF) [4] number, issued by the Ministry of Finance. This consultation must be performed upon registering the user in the operator’s betting system [5] or, if user is already registered, upon his first login into the system for the first time each day, after the implementation of the mentioned Normative Instruction. Every 15 days, betting operators must recheck SIGAP and maintain access logs to ensure no beneficiaries of the mentioned social programs are active in their databases.

In the case of registration, if a user is flagged as a beneficiary of one of the two social programs, his request must be denied [6]. And in the case of a user already registered, his account must be closed within three days [7] of the date the SIGAP query returns information that the person is a beneficiary of the mentioned social programs. If there are funds in the user’s betting system account, these funds must be withdrawn by the user within two days [8] or, if not withdrawn voluntarily, the betting operator must return these funds [9] to the user, to an account in his name.

It is worth noting that the identification of beneficiaries of the social programs mentioned above through consultation of SIGAP does not exclude other verification and control measures that betting operators may deem necessary to comply with the new regulations, as part of their compliance programs.

The SIGAP query will return the information “prevented – social program” or “not prevented”, without identifying the reason or the social program in which the beneficiary is enrolled.

Normative Instruction No. 22/2025 and Ordinance SPA/MF No. 2,217/2025 take effect immediately upon their publication. However, betting operators have 30 days to implement the required procedures [10] and 45 days to verify all CPF numbers registered in their systems [11].

As mentioned, Ordinance SPA/MF No. 2,217/2025 expands the list of individuals prohibited from betting which includes, in addition to the beneficiaries of the social programs indicated above, minors under 18; the owner, administrator, director, person with significant influence, manager or employee of betting operators; a person who has or may have influence on the outcome of the event on which the betting is based; the public agent with duties directly related to the regulation, control and supervision of the betting activity within the scope of the federative entity in whose staff he exercises his powers, among others [12].

In summary and In Practice, Ordinance SPA/MF No. 2,217/2025 makes it mandatory for betting operators to consult the SIGAP “Betting Restrictions Module” to identify beneficiaries of the Bolsa Família and BPC social welfare programs. The CPF number must be used to check individuals attempting to register on the betting platforms or those already registered. The goal is to prevent beneficiaries of the Bolsa Família and BPC social programs from using public funds credited to them in fixed-odds betting, which can worsen their families’ financial situation. Furthermore, excessive betting can lead to mental health problems (such as betting addiction), overloading Brazil’s Unified Health System (SUS) mental health units and increasing pressure on the public health system.

This article is for informational purposes only and does not constitute an opinion or legal advice.

BRENTANI RONCOLATTO ADVOGADOS

[1] Under the terms of the Law 14.601/203
[2] Under the terms of the Law 8.742/1993.
[3] Normative Instruction SPA/MF 22/2025, Art. 2
[4] INSPA/MF 22/2025, Art. 5, caput.
[5] Art. 6º
[6] Art. 6º
[7] Art. 7º, caput
[8] Art. 7, paragraph 2
[9] Art. 7, paragraph 3
[10] IN SPA/MF, Art. 15.
[11] IN SPA/MF, Art. 14
[12] Ordinance SPA/MF 1.231/2024, Art. 8