TRF3 suspends CDA Gaming order; Brazil left without authorised bookmakers

The president of the Federal Regional Court of the 3rd Region (TRF3), Judge Luis Antonio Johonsom Di Salvo, suspended on 6 November the order that had allowed CDA Gaming to operate in Brazil, leaving the country without any licensed bookmaker in operation. That extension applied the effects of the injunction issued in October against Stake; hours later the Prosecutor‑General of the Republic, Paulo Gonet, asked Supreme Federal Court (STF) Justice Luiz Fux to freeze nationwide all actions challenging Provisional Measure 1.394 until the STF rules.

The TRF3 suspension and its terms

Di Salvo granted the federal government’s request, communicated by the Advocacia‑Geral da União (AGU), and extended to CDA Gaming the suspension previously applied in the Stake case in October. The AGU’s statement cited a "concrete risk of serious harm to public order" and "regulatory instability" which, the court said, justify preventing isolated rulings from altering Provisional Measure 1.394 while the STF considers it in ADIs 8024, 8027 and 8028.

The act affecting CDA Gaming was the decision by Judge Adriana Pileggi, whose order was suspended by the TRF3 presidency. BNLData recorded that the decision applied to the Stake file — case number 5032238‑54.2026.4.03.0000 — was signed at 18:37 and that CDA will have five days to file an internal appeal, an appeal that does not suspend the measure.

Casa de Apostas, one of CDA Gaming’s three brands, had been operating since 5 November and was the only regulated bookmaker active after licences fell on 25 October; Betsul and Jogo Online displayed notices to the public, according to BNLData coverage.

The Prosecutor‑General’s petition and the STF’s role

On the night of 6 November Prosecutor‑General Paulo Gonet filed with Luiz Fux a request to suspend, throughout the national territory, the judicial actions that challenge Provisional Measure 1.394 until the STF issues a definitive decision. Gonet argued legal uncertainty and the "asymmetric application" of the measure, citing the provisional order in favour of CDA as an example.

At the time of first reports on the petition, Fux had not issued a ruling. BNLData counted 19 lawsuits from operators and associations in federal courts against the measure: 14 in the TRF3 and 5 in the TRF1. Following Di Salvo’s suspension there is no longer any injunction in force that authorises operators to accept bets.

The STF held a hearing on 4 November in ADPF 1212, concerning municipal lotteries, and the STF president, Edson Fachin, suspended it "at an opportune date"; the full court also agreed, at Minister Flávio Dino’s suggestion, to consolidate in a single trial the cases on the 2023 law that regulates betting, the ADIs on Provisional Measure 1.394 and RE 966177 on the prohibition of gambling. Fachin said he needs time; Minister Fux likewise said he will require time to draft his vote.

Legislative and fiscal calendar running in parallel

The parliamentary file on Provisional Measure 1.394 has not advanced: the joint committee that must deliberate has not been constituted and the initial 60‑day period expires on 23 November. The Senate record, updated to 6 November, shows 99 amendments filed; the urgency regime that affects one chamber’s agenda began on 9 November. Counting recess pauses, BNLData calculates the measure could lapse on 4 March 2027 if it is not voted. For context on regulatory process see [regulation](/regulation).

In parallel, the Presidency of the Republic published Provisional Measure 1.399 on 4 November, which sets selective rates for 2027; its Article 7 fixes a 0.5% rate for "concursos de prognósticos" under Complementary Law 214/2025, and BNLData interprets that definition to include fixed‑odds betting, with effect from 2 February 2027. The tax provisions intersect with payments planning in the sector [payments](/payments).

Police action and enforcement risks

Meanwhile enforcement of the prohibition continues. On 5 November the Civil Police of the Federal District executed Operation Azzardo against an unauthorised betting network, serving 50 warrants and obtaining a precautionary freeze of up to R$ 3.483 bilhões (a ceiling, not necessarily seized funds). BNLData converted that ceiling to dollars using a USD/BRL rate of 5.5037 on 6 November, resulting in approximately $633 million. The operation was widely reported in [news](/news).

What remains open legally

The TRF3 presidency has held that the harm is that one company operates while others are closed; that logic prevents an individual injunction from restoring the market. The effective reopening of the authorised sector now depends on a collective STF ruling or a congressional vote. With CDA also suspended, there is currently no licensed bookmaker operating in Brazil.

Miguel Sandoval, Regulatory correspondent.