In short: Brazil's Lei 14.790/2023 regulated fixed-odds betting and online gaming, created the SPA authorisation inside the Ministry of Finance, and made laboratory certification of the RNG, platform and each game a precondition. It did not open land-based slot machine operation, which remains a separate legislative question. Portugal does authorise land-based machines, but through a public tender concession for each gaming area rather than an import approval, and it requires two technical steps rather than one: certification by an SRIJ-recognised laboratory, then homologação by SRIJ's own technical team. In both markets the machine enters through a licensed operator; the factory is a supplier, not an importer.
Key takeaways
- Lei 14.790/2023 covers online betting and online gaming. Land-based slot machine operation is not authorised by it, and a supplier who reads the law as a casino opening is reading it wrong.
- Brazil routes authorisation through SPA, inside the Ministry of Finance, and requires certification of the RNG, the platform and each game by a laboratory the SPA recognises.
- SIGAP is the monitoring layer, not a certificate: authorised operators report into it, which is why integration is a launch task rather than a filing task.
- Portugal authorises land-based gaming by concession. Casinos run on ten-year concessions, bingo halls on twenty, awarded by public tender for a defined gaming area.
- Certification and homologação are two steps. A laboratory report does not end the Portuguese process; SRIJ tests the system itself afterwards.
What did Lei 14.790/2023 actually open in Brazil?
Online, and specifically. Law No. 14,790 of 29 December 2023 amended the 2018 fixed-odds betting statute to cover online gaming as well as betting, defined the authorisation regime, set the tax model, and gave the Ministry of Finance power to regulate by ordinance. The Secretariat of Prizes and Bets (SPA) grants the authorisations and supervises.
| Question | What the 2023 law says | What it means for a machine supplier |
|---|---|---|
| Is online betting authorised? | Yes, under a five-year federal authorisation granted to a Brazilian legal entity | Your buyer is an authorised operator, not a venue owner |
| Is land-based slot machine operation authorised? | No. Casino and bingo legislation is a separate track and was not settled by this law | A cabinet order presented as a Brazilian casino project has no licence behind it |
| Does a certificate from another market transfer? | No. The RNG, platform and each game must be certified by an SPA-recognised laboratory | An existing GLI or BMM report is a starting point, not the certificate |
| Who may hold the authorisation? | A legal entity incorporated in Brazil, headquartered and administered there, with at least twenty per cent of share capital held by a Brazilian-resident partner | The supplier's role is documentation and hardware, not the licence |
The distinction matters commercially. A Chinese cabinet maker receives Brazilian enquiries that read as venue projects, and the honest answer is that the law authorised a betting and online-gaming market first. Anyone quoting a land-based slot floor as a 2026 Brazilian opportunity is describing legislation that has not passed.
What does SPA require before a game can go live in Brazil?
Three things, in order: certification, integration, authorisation. Certification means the RNG, the platform and each individual game hold a valid conformity certificate from a laboratory the SPA recognises, covering RNG performance and fairness, game logic and expected payout, security protocols, responsible-gambling features and audit-trail integrity. Integration means reporting into the SPA's monitoring system, SIGAP, which receives transaction data. Authorisation is the federal act itself, granted for five years and capped at three commercial brands per authorisation.
The financial conditions are substantial and sit with the operator, not the supplier: a grant fee set at the statutory ceiling, minimum paid-up capital and net worth floors, and a technical reserve ring-fenced for player liabilities. A supplier quoting a Brazilian project should establish which of these the buyer has already satisfied, because none of them can be supplied from outside the country.
Do you need a Brazilian company to certify a game?
No for B2B product certification, yes for authorisation. A game studio can have its content certified through an SPA-recognised laboratory without incorporating in Brazil, and B2B providers supply certified content to authorised operators on that basis. What requires a Brazilian entity is the operating authorisation itself.
That split is worth stating precisely, because the two are usually conflated in supplier conversations. If the buyer is an authorised operator, the supplier's certification obligation runs to the game and platform certificate. If the buyer is a would-be operator asking the supplier to help it become authorised, no certificate substitutes for the corporate and financial conditions.
How does Portugal authorise land-based machines?
By concession, awarded through public tender. Land-based gambling in Portugal is carried out under a concession contract for an existing gaming area, with the tender setting qualification criteria, the location of the casino, the minimum financial payment and the guarantees due. Casino concessions run ten years and bingo hall concessions twenty, and the state may renew by decision.
Slot machines are a licensed game type within those areas, governed by their own instrument, Portaria-Lei n.º 310/2002. The regulatory framework for gaming is Decreto-Lei n.º 66/2015, with certification of technical systems set by Regulamento n.º 419-A/2015 (how a certifying entity gains recognition) and Regulamento n.º 903-B/2015 (the technical requirements the system must meet).
The practical consequence is that there is no route in which a supplier sells cabinets into Portugal and the venue then seeks approval. The concessionaire is fixed before the machine is chosen, and the machine is specified to the concession.
What does homologação add to a laboratory certificate?
The regulator's own test. Certification is performed by an independent entity that SRIJ recognises; homologation is SRIJ's technical team testing the gaming system after the certification reports are validated. It is a separate and chargeable procedure, and it is the step where a first filing most often loses weeks.
| Step | Who performs it | What it produces |
|---|---|---|
| Certification | An independent testing entity recognised by SRIJ | Reports confirming the platform and games meet the applicable technical requirements |
| Homologation | SRIJ's own technical team | Validation of the technical system after the reports are reviewed |
| Guarantees and fees | The operator, with an EU credit institution | Bonds for legal obligations and for the special online gambling tax, plus a dedicated transaction account |
| Licence | SRIJ | A three-year licence, renewable, for the categories and game types named in it |
For an online licence the applicant must be a company headquartered in an eligible EU or EEA state, with all filings in Portuguese and any foreign document carrying a legalised translation. A licence from another country is not valid, and an operator may offer only the categories its licence names.
Who may import machines into each market?
The licensed party. In Brazil that is an authorised operator or a B2B provider supplying certified content to one; in Portugal it is the concessionaire for a gaming area, or a licensed online operator for platform components. A manufacturer outside the country is the supplier in both cases, and the commercial relationship is a supply agreement rather than an import registration.
This shapes what a buyer should ask for. The useful package is a cabinet built to a specified standard, a hardware and peripheral list that survives a technical review, serial-number traceability per unit, and documentation structured so the licensed party can file it. What no supplier can provide is the concession, the authorisation, or a view on whether a given machine will be homologated.
What GOLDPRIME supplies — and what it does not
| GOLDPRIME provides | GOLDPRIME does not provide |
|---|---|
| Cabinet manufacture to a specified build standard, with the sheet metal enclosure produced at our cabinet partner in Foshan | The SPA authorisation, the Portuguese concession, or a licence of any kind |
| Technical documentation structured around what a laboratory and a regulator ask for | An accredited laboratory certificate, or a homologation result |
| Serial-number traceability, unit photographs and packing records | An appointment as importer, concessionaire or authorised operator |
| Wiring, peripheral and configuration lists that support a technical review | A statement that a machine will be approved in either market |
We do not hold operating authorisations in either country, and we do not present a supplier relationship as regulatory cover. What we control is the build, the documentation and the traceability that a licensed buyer needs in order to file.
Frequently asked questions
Did Brazil legalise slot machines in 2023?
No. Lei 14.790/2023 regulated fixed-odds betting and online gaming. Land-based slot machine operation was not authorised by it and remains a separate legislative question.
Can a foreign supplier get its game certified in Brazil without a local company?
Yes, for B2B product certification through an SPA-recognised laboratory. The operating authorisation itself requires a Brazilian legal entity with local headquarters and administration.
Is a GLI or BMM certificate enough for Brazil or Portugal?
No. Brazil requires certification from a laboratory the SPA recognises; Portugal requires an SRIJ-recognised entity plus homologation by SRIJ itself. An existing report is a starting point, not the certificate.
Can we sell cabinets into Portugal and let the venue handle approval?
No. Portuguese land-based gaming operates under a concession awarded by public tender before machines are specified. The concessionaire is fixed first, and the machine is specified to that concession.
What is SIGAP?
The SPA's monitoring system, which receives transaction data from authorised operators. Integration with it is part of going live in Brazil, not a document filed at the end.
Does GOLDPRIME hold a licence in Brazil or Portugal?
No. We supply cabinets, documentation and traceability to licensed parties. The authorisation or concession is held by the operator, and we do not present a supply relationship as regulatory cover.
Planning a build for a licensed Portuguese-speaking operator?
Tell us the market, the machine class and the quantity. We answer with the documentation and traceability we can provide and a production date — not with a licensing promise.
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