Brazil gaming license 2026: how to secure 1 of 25 integrated resort permits

The legalization of gambling in Brazil opens a market with billion-dollar potential, but access will be limited to a select group of participants. Instead of issuing licenses broadly, the government is adopting a controlled entry model in which casinos are permitted only within integrated resorts. This turns licensing into an investment-driven competition, where legal, financial, and strategic factors all play a role. In this article, we explain how this model works and what it takes to secure a license.

Brazil’s gambling reform: from prohibition to regulated market

Brazil remained a closed market for casinos for decades. The ban dates back to 1946, when the government shut down all gambling operations. As a result, the largest economy in Latin America stayed outside the global gaming market for years.

The situation began to change only recently. A key step was the adoption of Law No. 14.790/2023, which established a framework for regulating online betting and opened the path for further liberalization. At the same time, legalization of land-based casinos is being discussed through the integrated resort model, seen as the next stage of reform.

The government is focusing on controlled market development, prioritizing tax revenues, infrastructure investment, and tourism growth. This means licensing will not be open-ended but limited and structured.

The reform is evolving in two directions:

1. Online betting is already regulated and forms the market foundation
2. Land-based casinos are under legislative review and expected to operate via integrated resorts

This approach allows the government to gradually integrate gambling into the economy while limiting social and regulatory risks.

Importantly, Brazil is not following open licensing models like Curaçao or Malta. Instead, it is creating a restricted system where a license is not just a permit but part of a broader investment project.

Integrated resort model: what Brazil is actually licensing

Brazil does not plan to issue traditional casino licenses. Instead, it is introducing an integrated resort (IR) model, where gambling is allowed only as part of a large-scale tourism complex.

This fundamentally changes the market approach. A casino is not treated as a standalone business but as infrastructure designed to boost tourism, create jobs, and attract investment.

What qualifies as an integrated resort?

An integrated resort is a complex that includes not only a casino but also full tourism and commercial infrastructure. In this model, the focus is on the overall scale of the project rather than the gaming component itself.

Such projects typically include:

• Hotels and accommodation facilities
• Conference and exhibition centers
• Restaurants, retail, and entertainment areas
• Infrastructure for large-scale tourism

Within this structure, the casino plays a supporting role as a revenue driver rather than the core business.

Why the government limits the number of licenses

Limiting the number of licenses is a deliberate strategy. Instead of a mass market, Brazil is creating a premium segment with concentrated capital.

The main reasons include:

• Controlling social risks linked to gambling
• Attracting large investors capable of delivering infrastructure projects
• Ensuring market transparency and oversight
• Maximizing tax revenues

As a result, a license is not just a permit to operate but the right to develop a major investment project in partnership with the state.

Overall, the integrated resort model makes the Brazilian market inaccessible to small operators and geared toward large international groups ready to invest in long-term projects.

The “25 licenses” concept: how allocation is expected to work

A key feature of Brazil’s model is the strict cap on licenses. Unlike open markets where dozens of operators can enter, Brazil is moving toward a limited-entry system. In practice, this is expected to mean around 25 licenses for integrated resort projects.

It is important to note that this figure is not yet final but reflects current legislative proposals and the policy direction of the reform. However, the principle of limited licensing is already clear.

This structure means the market will be shaped through competitive selection rather than a standard licensing process. Approval will depend not only on legal compliance but also on the quality of the investment project.

Regional allocation and market balance

Licenses are likely to be distributed based on geography and regional economic potential. This approach supports balanced tourism development and avoids market concentration in a few cities.

Allocation may consider:

• Regional population size
• Tourism demand
• Economic value of the project
• Infrastructure readiness

This allows the government to use licensing as a tool for regional development, not just industry regulation.

Competitive selection instead of open licensing

Unlike traditional gaming licenses, where compliance is the main criterion, Brazil’s model is based on competition.

This means that:

• Not all qualified applicants will receive a license
• Projects will be assessed by their economic and investment value
• The state will select the most beneficial proposals

As a result, a license becomes a scarce asset available only to the strongest applicants.

Key eligibility requirements for applicants

Entry into Brazil’s integrated resort market starts not with filing an application but with meeting baseline requirements. Unlike standard licensing, regulators assess not only legal status but also the applicant’s investment and operational capacity.

The government targets large, financially robust players capable of delivering complex projects. As a result, entry criteria are high and span several key areas.

Corporate structure

A properly structured corporate setup is a core requirement. In most cases, this involves establishing a local entity or a joint venture with a Brazilian partner.

This is needed to:

• Comply with national legal requirements
• Facilitate interaction with regulators
• Ensure ownership transparency

A local partner is often not a formality but a factor that can influence licensing outcomes.

Financial capacity

Financial strength is a key selection criterion. Integrated resort projects require significant capital, so applicants must demonstrate sufficient funding and credible sources.

Assessment goes beyond current liquidity to the ability to finance all stages, from construction to launch and operations.

Review typically covers:

• Financial statements
• Funding structure
• Involvement of investors or banks
• Business model sustainability

Technical and operational experience

Regulators also assess experience in gaming, hospitality, or large-scale project management to reduce execution risk.

Key factors include:

• Track record in operating casinos or entertainment complexes
• Presence of experienced operating partners
• Understanding of compliance requirements
• Readiness to implement control and security systems

Companies without relevant experience often partner with international operators or form consortia.

Licensing process: step-by-step overview

Obtaining an integrated resort license in Brazil is not a standard administrative process but a multi-stage procedure with competitive elements. Applicants must not only meet formal requirements but also present an investment project subject to government evaluation.

The process can be broadly divided into several key stages.

Application and initial review

At the first stage, the company submits an application and a basic set of documents. In addition to corporate information, the applicant must present a project concept, including a description of the proposed integrated resort.

Regulators conduct an initial review, focusing on:

• Compliance with baseline requirements
• Transparency of ownership structure
• Availability of necessary resources

Applications that fail to meet minimum criteria are filtered out early. Even strong projects may not proceed without a clear and transparent structure.

Government evaluation of the project

The next stage is a detailed project assessment. Unlike standard licensing, the key factor here is investment value and economic impact.

The government evaluates:

• Scale and quality of infrastructure
• Contribution to tourism development
• Job creation
• Financial sustainability

This is where competition takes shape, with projects compared against each other. Successful applicants are those offering the highest economic and social value.

Final approval and licensing

Following evaluation, a decision is made on license awards. Selected companies gain the right to implement the project and proceed with operations.

However, licensing comes with additional conditions:

• Commitments to project timelines
• Investment requirements
• Compliance with regulatory standards

Thus, in Brazil, a license is not just a permit but a long-term commitment to the state, requiring strict compliance throughout the project lifecycle.

Strategic considerations for investors

Successful licensing in Brazil depends not only on meeting requirements but also on the chosen market entry strategy. With a limited number of licenses, investors compete not on formal criteria but on the quality and scale of their projects.

Choosing the right location

Location is critical, as the government views integrated resorts as tools for regional development. Priority is typically given to projects that enhance tourism appeal and economic activity in a specific area.

Investors must consider not only current tourist flows but also long-term potential, infrastructure availability, and support from local authorities. A poor location choice can significantly reduce the chances of approval, even with a strong financial model.

Partnering with local entities

A local partner often becomes a decisive factor. The Brazilian side provides not only formal compliance but also access to administrative processes, understanding of the regulatory environment, and interaction with authorities.

For foreign investors, this also helps reduce operational and legal risks. The choice of partner must be strategic, as it affects both the licensing stage and the project’s long-term execution.

Structuring investment and project model

The structure of investment and the project itself directly influences how the application is assessed. It is important to define the investment format, risk allocation, and financing model in advance.

The government evaluates not only available capital but also the sustainability of the model, the ability to complete construction, and long-term operational viability. Therefore, the project must be developed as a full investment case, not just a licensing application.

How Key2Law helps secure a Brazil gaming license

Obtaining an integrated resort license in Brazil is not a standard legal procedure but a complex investment and legal project. Success depends on the right business structure, regulatory compliance, and the quality of the application. Without professional support, companies risk rejection, delays, or the need to redesign the entire model.

Key2Law team supports clients at every stage of market entry, helping build a legally sound licensing strategy. We work not only with documentation but also with the project’s core structure, improving its competitiveness in the selection process.

Our experts provide comprehensive business support:

• Analysis of the business model and applicable regulation in Brazil
• Structuring of the integrated resort project and investment model
• Establishment of a local corporate structure and partner selection
• Preparation of the application and investment proposal for the tender
• Support in interactions with regulators and government authorities
• Implementation of compliance processes (AML, reporting, transaction control)
• Assessment and mitigation of legal and regulatory risks
• Support during licensing and project launch

If you plan to secure one of the limited licenses in Brazil, it is essential to define your strategy and legal structure in advance. Contact the Key2Law team for professional support and significantly increase your chances of success.