New Rules for Listing Betting Apps on Brazil's App Store: Valid SPA License Required

Overview

Apple recently issued an announcement updating its App Store distribution policy for betting apps in Brazil, in response to changes in Brazil's fixed-odds gambling regulations. Effective immediately, apps containing fixed-odds betting functionality must hold a valid license issued by Brazil's "Secretariat of Prizes and Bets" (Secretaria de Prêmios e Apostas, SPA) in order to be distributed on the Brazilian App Store.

This change directly impacts developers operating betting apps in the Brazilian market, who need to understand the compliance requirements and complete the necessary processes as soon as possible.

Fixed-Odds Betting and the Brazilian Market Context

Fixed-Odds Betting is a form of gambling where the odds are locked in at the time of placing a bet. Unlike pari-mutuel betting, players know their potential returns at the moment they wager. This model is widely used in sports betting and is the dominant format in the global online gambling market. In recent years, with the proliferation of mobile internet, fixed-odds betting apps have grown rapidly in emerging markets. As South America's largest economy, Brazil's betting market is estimated to exceed $2 billion, attracting numerous international operators.

Brazil's gambling regulation history has been complex. For a long time, Brazil prohibited most forms of gambling, until Law No. 13,756 was passed in 2018, officially legalizing fixed-odds sports betting. In 2023, the Brazilian government established the "Secretariat of Prizes and Bets" (SPA) under the Ministry of Finance, specifically responsible for licensing and regulating the betting industry. The SPA/MF Ordinance No. 1,231 of 2024 represents a major milestone in the maturation of this regulatory framework, marking Brazil's betting market transition from a legal vacuum to systematic regulatory management.

Core Requirements of the New Rules

Mandatory Licensing Requirement

Under the new policy, if a developer's app contains fixed-odds betting functionality—that is, if "Yes" was selected for the "gambling" question in the Age Rating Questionnaire on App Store Connect—a valid betting license issued by Brazil's SPA must be provided.

Notably, Apple's Age Rating Questionnaire is the core tool Apple uses to identify sensitive content categories. Developers must truthfully declare app functionality, and the system automatically generates region-differentiated age ratings accordingly. In recent years, Apple has implemented localized compliance requirements across multiple global markets, including the Netherlands' dating app payment policy and South Korea's third-party payment permissions. The Brazilian betting license requirement is a continuation of this series of localized compliance measures, reflecting Apple's strategic direction of deeply binding platform responsibilities to each country's regulatory requirements.

Once "Yes" is answered for the gambling question in the age rating questionnaire, the app's age rating in Brazil is automatically set to A18 (users 18 and older only). Developers need to consider both the implications of license acquisition and user base restrictions.

Submission Review Process

Apple has made clear that the license verification process must be initiated by submitting a new version. Simply updating the App Review Information section in App Store Connect will not trigger the review process. The specific submission steps are:

1. Fill in license information: Include license-related information in the App Review Information section of App Store Connect
2. Add notes with details: Enter the license details in the Notes field
3. Upload supporting documents: Use the file attachment field to upload relevant supporting documentation

This process design means developers cannot complete compliance through a simple metadata update—they must prepare and submit a new version of the app.

Compliance Obligations and Legal Responsibilities

Disclosure Requirements

Apple emphasized in its announcement that developers must ensure their apps comply with all disclosure and warning requirements, including but not limited to:

• Age restriction notices: Clearly indicate that the app is for users 18 and older only
• Gambling risk warnings: Fully disclose the potential risks of gambling activities to users
• Legal compliance statements: Meet other information disclosure obligations required by Brazilian law

Regulatory Background

This policy adjustment stems from Brazil's SPA/MF Ordinance No. 1,231 (Portaria SPA/MF nº 1.231), published on July 31, 2024, which systematically regulates the fixed-odds betting industry. The Brazilian government implements license-based management of the betting industry through the SPA, aiming to standardize market order and protect consumer rights.

From a broader perspective, this regulatory development is highly aligned with global trends. Agencies such as the UK Gambling Commission (UKGC) and Malta Gaming Authority (MGA) continue to strengthen KYC (Know Your Customer) and responsible gambling requirements; the EU is also discussing a unified digital gambling regulatory framework. For app platforms, cooperating with national regulatory requirements has become a necessary condition for maintaining market access. By front-loading license reviews into the distribution process, platforms like Apple and Google effectively assume partial regulatory enforcement functions—a trend equally prominent in fintech, healthcare, and other regulated industries.

Impact Analysis for Developers

Short-term Impact

For developers already operating betting apps in the Brazilian market, the immediate priorities are:

• Confirm whether they have obtained a valid license issued by SPA
• If no license has been obtained, apply to Brazil's SPA as soon as possible
• Prepare a new version submission to complete the license verification process

Apps that fail to obtain a license in time may face the risk of being removed from the Brazilian App Store.

Long-term Trends

This change reflects the broader global trend of tightening regulation of the online betting industry. Apple, as a platform operator, is actively cooperating with regulatory requirements in various countries, front-loading compliance reviews into the app distribution process. For developers planning to enter Brazil's betting market, obtaining an SPA license has become an unavoidable prerequisite. From the legalization in 2018 to the implementation of systematic regulation in 2024, Brazil's betting market is undergoing a critical transformation from unregulated growth to standardized operations, and compliance capability will become one of the core competitive barriers.

Recommendations and Action Guide

For affected developers, the following actions are recommended:

1. Immediately consult legal counsel to understand the specific compliance requirements of Brazilian betting regulations
2. Submit a license application to Brazil's SPA (if not already obtained)
3. Review app content to ensure all information disclosure and risk warning requirements are met
4. Prepare new version submission materials, including license documents and detailed explanations
5. Monitor any supplementary guidelines or deadline notices Apple may publish subsequently

Apple advises developers to contact professional legal counsel for guidance if they have questions about their legal obligations.

Key Takeaways

• Fixed-odds betting apps must hold a valid SPA-issued license to be listed on Brazil's App Store
• License verification requires submitting a new app version; metadata-only updates will not trigger review
• Selecting gambling functionality automatically sets the Brazil age rating to A18 (18+)
• Developers must ensure apps meet disclosure requirements for age restrictions and gambling risks
• The policy stems from Brazil's SPA/MF Ordinance No. 1,231 on fixed-odds betting regulation, published in July 2024
• This change is the latest manifestation of Apple's localized compliance strategy amid the global tightening of online gambling regulation