Amilton Noble: State lotteries in transformation
BiS SiGMA Americas 2025 promises to be a milestone for the iGaming industry in Brazil, bringing together top experts and industry leaders to discuss the present and future of betting and lotteries in the country. In a scenario of intense transformation, where regulation is progressing and new opportunities are emerging, state lotteries are becoming central players in a crucial debate on autonomy, innovation, and economic development.
With over three decades dedicated to the gaming, betting, and lottery sector, Amilton Noble is one of the most prominent figures in this market. As Executive Director of Hebara, he played a fundamental role in the creation and development of successful lottery products, always combining innovation, business analysis, and optimisation strategies to maximise results. His expertise and strategic vision have helped consolidate the company as a benchmark in the sector, making him an essential voice in discussing the challenges and opportunities for lotteries in Brazil.
To explore the impact of regulations, the balance between federal and state operations, and the future of this market, Lygia Rodrigues, Head of Conferences at BiS SiGMA Americas, interviews Amilton Noble, providing valuable insights into how lotteries can strengthen themselves and contribute to a competitive and sustainable environment.
Lygia Rodrigues: Amilton, it is a pleasure to talk with you about such a strategic and ever-evolving topic in Brazil. The recent Supreme Federal Court (STF) decision has introduced a new chapter in betting regulation in the country by imposing restrictions on the operation of state lotteries at the national level. This move reignites the debate on the limits of state autonomy and the role of the federal government in structuring this market. In your view, what are the impacts of this measure on state operations and the advancement of sports betting regulation in the country?
Amilton Noble: Lygia, the pleasure is mine to have the opportunity to discuss such a relevant and timely issue with you. Peaceful coexistence among regulators at all levels is imperative to establish a healthy regulatory environment that serves all interests.
The recent ruling by Minister André Mendonça, still in a preliminary stage, sets an important precedent by defining parameters for the operation of state lotteries, restricting their activities to their own territories, regardless of the betting sales method. The argument upheld by Loterj, which had prevailed for over a year, has now been overturned. This creates a sense of security for operators who opted for a federal licence, while simultaneously jeopardising the strategy of those who relied on Loterj’s licence as a means to operate nationwide.
The decision still needs to be ratified by the STF, and until then, uncertainty remains.
I believe all entities should seek consensus, working together to complement rather than compete with each other. Unfortunately, that has not been the case so far.
Lygia Rodrigues: Recently, we have seen small municipalities granting accreditations to betting operators, raising questions about the limits of existing regulation and the role of federal authorities. This scenario has exposed loopholes that could undermine the creation of a secure and well-structured market. Given this context, what challenges must Brazil overcome to establish clearer and more uniform regulation for online betting?
Amilton Noble: Reiterating what I mentioned earlier, I see a future for a healthy regulatory environment only if all regulators—regardless of their jurisdiction—work collaboratively and in a complementary manner. If the current regulatory approach persists, we will inevitably face problems and unnecessary legal disputes.
In my view, states play a complementary role in the regulatory process. If upheld by the STF, municipalities could also play a key role in increasing market channelling. As I always say, different entities should not be at odds with each other. The real “enemy” is something else. Everyone should focus their efforts on combating illegal gambling, which is truly harmful to the system.
If all stakeholders come to the table and define their roles in the regulatory process, there will be room for everyone. However, if they continue to clash, the illegal market will be the ultimate winner.
Lygia Rodrigues: Lotteries play a fundamental role in raising funds for social causes and driving economic development in various states. There is an increasing debate on how to ensure these funds are managed efficiently and transparently. What are the main challenges and opportunities for state and municipal lotteries in Brazil? How can local autonomy be balanced with the need for a more cohesive and secure regulatory model?
Amilton Noble: This is the crucial question. The federal government has never indicated that it would share revenue generated by federal lotteries with states and municipalities. It is undeniable that the funding from federal lotteries is allocated to noble causes, but these resources do not directly reach states, let alone municipalities.
Given this scenario, states realised they needed to fight for their autonomy to generate their own revenue without relying on financial transfers to the federal government.
After Supreme Court rulings on ADPFs 492 and 493, municipalities began to interpret the STF’s decisions as leaving gaps that suggested they could directly establish their own lotteries. This movement has become a reality, with some municipalities already operating, despite the legal uncertainty of this model.
What creates discomfort is the lack of a clear definition regarding the extent of state and municipal lottery operations. The current legislation on the matter dates back to 1944—long before the advent of the internet and online betting. This allows for multiple interpretations.
So far, we have witnessed a power struggle between different entities seeking a larger share of the concessions granted for fixed-odds betting regulation.
Lygia Rodrigues: While some licences to operate in the betting market require multimillion-dollar investments, other jurisdictions set significantly lower fees, creating a scenario of disparity among operators. How does this difference impact the competitiveness and fairness of the sector in Brazil? What steps can be taken to ensure a more balanced environment?
Amilton Noble: Lygia, I tend to separate the issue of licence fees from the conditions required to obtain them. In my view, the fee itself should be the last point of discussion. Let me clarify: more important than determining the fee (since each entity has the discretionary power to set these values) is establishing minimum regulatory principles, as well as clear governance and compliance criteria that all operators must follow, regardless of the regulator.
Currently, there is a significant disparity between the authorisation processes conducted by the federal government, states, and even municipalities, some of which have granted licences without clearly defining their scope. This discrepancy is evident in the licensing fees charged.
If all entities were required to implement adequate KYX levels, responsible gambling principles, and adherence to CONAR regulations, we would achieve regulatory uniformity. In this way, the licence fee would become less relevant, as all operators would be aligned in the same direction.
At present, this is not the case. Lower licensing fees suggest a reduced level of oversight from some regulators who do not impose the same operational rigour as the federal government.
To me, this is the key issue. Federal legislation should define mandatory parameters for all, leaving only a few aspects to local entities’ discretion. Until this happens, we will continue to witness a “price war.”
Lygia Rodrigues: The regulation of lotteries in Brazil has undergone significant changes, aiming to balance federal and state operations. With new guidelines emerging for market exploration, challenges arise in ensuring a transparent and sustainable environment. In this context of transformation, what actions are essential for lotteries to not only operate fairly and securely but also become more innovative and competitive?
Amilton Noble: I am an optimist by nature. I fought for many years for the STF to recognise states’ rights to operate their lotteries, as was decided in ADPFs 492 and 493. When Hebara operated Loterj, the battle was intense. The federal government always treated state lotteries as illegal and inferior to what they actually were. It took years of struggle to achieve recognition of state autonomy.
Now, municipalities are also seeking their place to generate their own revenue. However, this struggle has paralysed the market for decades. For nearly 50 years, few states took action to activate or reactivate their lotteries. Today, this scenario has changed, and this movement is extremely positive.
However, as disputes persist, the market shrinks. There is a lack of investment in innovation, and new forms of informal gambling are spreading.
I reiterate that it is crucial for all stakeholders to reach a consensus on their role in the regulatory environment. Without this, we will face endless legal battles—and in the end, the illegal market will be the real winner.
