Recently, the Secretariat of Prizes and Betting of the Ministry of Finance (“SPA/MF”) published Technical Note SPA/MF n. 299/2025, addressing the accounting of rewards offered to bettors by online betting sites for the purpose of inclusion in the calculation basis of the Gross Gaming Revenue (“GGR”).
The Technical Note clarified that although betting sites cannot offer advances, prepayments, bonuses, or prior advantages to new bettors, they are allowed to give rewards after account creation and at least one bet has been placed, provided that such rewards are stipulated in the terms and conditions or that the bettor is part of a loyalty program.
These rewards may be financial or non-financial. If they are financial, they may be either withdrawable or non-withdrawable, depending on whether the bettor can cash out the respective rewards.
In this regard, the Technical Note explained that non-financial rewards will not be included in the GGR calculation basis due to their nature. Financial rewards, however, may or may not be included in the GGR calculation basis, depending on their type.
For withdrawable rewards, they will initially not be included in the GGR calculation basis, except when they are used by bettors to place new bets. On the other hand, non-withdrawable financial rewards will always be included in the GGR calculation basis, as the SPA/MF considers this type of reward a direct incentive for the operation of online betting sites, and its eventual non-use should be regarded solely as part of business risk.
Our team is available for further clarifications, as well as to provide assistance with the compliance with gaming regulation.
Gustavo Flausino Coelho – gustavo@bastilhocoelho.com.br
Fernando Naegele – fernando@bastilhocoelho.com.br