Apple has introduced a critical update for developers operating in the South American market, establishing a strict Brazilian betting license requirement for App Store availability. Under new guidelines, applications featuring fixed-odds betting or gambling capabilities can only be distributed in Brazil if the developer possesses a valid license issued by the Secretariat of Prizes and Bets (SPA).
This move follows recent shifts in Brazil’s fixed-odds betting regulations, signaling a tighter integration between national legal mandates and digital storefront policies. For developers, the update means that simply having an app on the store is no longer sufficient; they must now proactively prove their legal standing to the Brazilian government and Apple’s review team to maintain or gain access to the region’s user base.
The requirement creates a clear divide between general gaming apps and those specifically designed for fixed-odds gambling. By leveraging the existing App Store Connect infrastructure, Apple is implementing a verification layer that ensures all gambling-related software complies with local laws, including mandatory age restrictions and risk disclosures.
The Role of the Secretariat of Prizes and Bets (SPA)
Central to these new requirements is the Secretariat of Prizes and Bets (SPA). The SPA is the governing body responsible for issuing the fixed-odds betting licenses required for legal operation within Brazil. Any app that provides gambling features—specifically those involving fixed-odds betting—must now provide documentation verifying their license from this specific entity.
This regulatory alignment ensures that only authorized operators can offer betting services to Brazilian citizens. By mandating a license from the SPA, Apple is shifting the burden of legal verification onto the developer, while providing a standardized pathway for those who have already complied with Brazilian law to remain available on the platform.
Submission Process via App Store Connect
The verification process is integrated directly into the App Store Connect workflow, but it requires specific actions from the developer to be triggered. It is not a passive update; developers cannot simply edit their app information and expect the license to be verified.
To initiate the process, developers must first navigate to the age rating questionnaire within App Store Connect. When prompted with the gambling question, developers must select “Yes.” selecting this option automatically sets the app’s Brazil age rating to A18, reflecting the legal age requirements for gambling in the region.
Crucially, updating the App Review Information section alone will not start the verification process. To trigger a review of the license, developers must submit a new version of their application. This ensures that the app’s current build is reviewed alongside the legal documentation provided.
Documentation and Compliance Requirements
When submitting the new app version for review, developers must provide comprehensive evidence of their legal authorization. Apple has outlined specific fields within App Store Connect where this information must be placed to avoid delays in the review process:
- App Review Information Section: Developers must include their license information here.
- Notes Field: Specific license details should be entered directly into the Notes field for the review team.
- File Attachment Field: Any supporting legal documents, such as the actual license certificate from the SPA, must be uploaded using the file attachment tool.
Beyond the license itself, Apple requires that apps adhere to all legal disclosures and warnings mandated by Brazilian law. This includes, but is not limited to, clear warnings regarding gambling risks and strict adherence to age restrictions. Failure to include these disclosures may result in the app being rejected during the review process, regardless of whether a valid license is present.
Impact on App Developers and Operators
This policy change creates a significant compliance hurdle for international operators who may have previously operated in a regulatory gray area or relied on licenses from other jurisdictions. Because the requirement specifically mandates a license from the Secretariat of Prizes and Bets (SPA), foreign licenses are not a substitute for the Brazilian mandate.
For developers, the primary risk is a loss of availability in the Brazilian market. Because a new version submission is required to verify the license, apps that are not updated to meet these requirements—or those that fail the verification process—may face removal or restrictions within the Brazilian App Store.
Developers are encouraged to consult with their own legal counsel to ensure their apps meet all the necessary legal obligations under Brazilian law, as Apple’s review process focuses on the presence of the license and basic disclosures rather than providing legal advice on the nuances of local gambling statutes.
For more detailed information on the submission steps, developers can refer to the official Apple Developer news update regarding Brazilian betting licenses.
The next confirmed checkpoint for developers is the submission of their next app version update to initiate the SPA license verification process. We encourage developers and industry stakeholders to share their experiences with the verification process in the comments below.