Note on the dossier by the Institute for Studies on Public Health Policy (IEPS)

Note on the dossier by the Institute for Studies on Public Health Policy (IEPS)

The Brazilian Institute for Responsible Gaming (IBJR) publicly challenges the methodology and conclusions presented in the dossier prepared by the Institute for Studies on Public Health Policy (IEPS), which has recently circulated in the press. While a debate on public health is both legitimate and necessary, the material released relies on speculative projections presented as absolute facts, as well as outdated market data collected before regulation came into force in January 2025. To clarify the discussion and correct distortions, the IBJR highlights the following points:

• This methodological weakness includes importing models from the United Kingdom without accounting for the Brazilian context, and indiscriminately mixing direct costs with subjective variables—such as theoretical calculations of “healthy life years” and productivity loss. This produces a supposed R$ 38.8 billion impact that falsely suggests immediate expenses for the public health system, while also failing to establish a direct causal link between betting and mental health conditions that may simply coexist with the activity.

• The study acknowledges using the UK as a benchmark due to similarities between the SUS and the NHS. However, when adapting the figures to Brazil, the dossier drastically inflates the values. While official estimates in the UK point to social costs of around £1.6 billion (approximately R$ 12 billion), the study projects a R$ 38.8 billion impact for Brazil. This discrepancy also ignores the economic and income differences between the two countries.

• The dossier seriously fails to distinguish between the safe environment of regulated betting platforms and the clandestine market. Licensed platforms (with the .bet.br domain) are required to use facial recognition and strict identity verification processes to prevent access by individuals under 18—unlike illegal betting sites, which do not require effective age verification and operate outside the law.

• The study overlooks that 51% of the market operates illegally, according to data from LCA Consultoria and Instituto Locomotiva. It is within platforms without the “.bet.br” domain—lacking mandatory tools such as facial recognition, time limits, and self-exclusion—that the real risks of fraud, algorithm manipulation, and indebtedness lie. By generalizing the sector, the study penalizes companies that follow compliance rules for harms caused by a parallel market.

• While the regulated market has already paid more than R$ 2.3 billion in licensing fees and is projected to contribute around R$ 10 billion per year in taxes to fund Social Security, the clandestine market evades roughly R$ 10 billion annually and offers no consumer protection whatsoever.

• The dossier misrepresents the sector’s economic contribution by relying on 2024 data, gathered before the regulated market was fully in effect. The updated study “Overview of the Fixed-Odds Betting Market,” conducted by LCA Consultores, shows a very different post-regulation reality: formal job links have tripled, totaling more than 15,000 direct and indirect jobs, with an average salary of R$ 7,000 and the creation of 67 new formal occupations. The market is projected to generate R$ 36 billion in operator revenue in 2025 alone.

• International experiences, such as the Dutch market, show that overly restrictive measures based on flawed diagnoses resulted in a 25% drop in regulated-sector revenue and a mass migration of players to illegal platforms.

The IBJR maintains that public policies must be formulated based on concrete and verifiable evidence, not on alarmist projections. The path to effective societal protection is the strengthening of regulation and a rigorous crackdown on the illegal market, ensuring that the sector operates with responsibility, transparency, and full compliance with the law.