SPORTS INTEGRITY AND FIXED-ODDS BETTING: STRATEGIES FOR COOPERATION AND MATCH-FIXING PREVENTION IN BRAZIL

1. Introduction: The Challenge of Integrity in the Current Betting Landscape

The global sports betting market has grown exponentially in recent decades, driven by digitalization, legalization, and regulation. Approximately 25 million people placed sports bets in the first seven months of 2024, representing around 48% of all Brazilian bettors over the past five years. The rise in smartphone users—who made up about 70.5% of the global population in 2025—combined with the accessibility of online betting platforms, has contributed to the massive adoption of this form of entertainment.

In Brazil, the regulation of this sector began with Law No. 13,756/2018, which legalized fixed-odds betting as a lottery modality. However, only with the enactment of Law No. 14,790/2023 was a structured and comprehensive regulatory framework established for the sports betting sector. This law aims to set parameters for the operation of betting services and impose advertising rules with a threefold purpose: to protect consumers, preserve public order, and mitigate the risks associated with gambling.

Nevertheless, regulation alone does not eliminate the challenges related to sports integrity, particularly match-fixing, or the manipulation of competition outcomes. Match-fixing is defined as the deliberate alteration of the result of a competition to serve the interests of bettors or other involved parties.

The increasing monetization of the sports environment, without corresponding investment in integrity initiatives, can undermine the credibility of competitions. The sector’s sustainability relies on consumer trust in the fairness of sporting events, making integrity a crucial asset.

International models highlight the importance of integrated fraud detection systems, cooperation between regulatory bodies, rapid alert platforms, and education for athletes and sports officials.

The Macolin Convention (formally known as the Convention on the Manipulation of Sports Competitions) is currently the only international regulatory instrument addressing this issue. It recognizes the need for a global response to the manipulation of sports competitions and emphasizes the importance of cooperation among sports organizations, betting operators, and competition organizers in identifying, analyzing, and assessing risks. It also encourages education, rule implementation, and the adoption of principles of good governance.

Public perception that sporting events are fair and free from manipulation is essential not only for bettor engagement but also for preserving the legitimacy of sport as a cultural, social, and economic good.

2. Brazilian Regulatory Landscape: What Law No. 14,790/2023 Says

Law No. 14,790/2023 marked a significant milestone in the Brazilian legal framework by providing more robust regulation for the commercial operation of fixed-odds betting, both in physical and virtual environments (Art. 3). Unlike previous regulations, this new legislation aimed to align the country with international best practices in integrity, transparency, and governance in the betting sector.

The operation of fixed-odds betting in Brazil depends on prior authorization from the Ministry of Finance. Under Law No. 14,790/2023, this authorization is personal, non-negotiable, and non-transferable. This is reinforced by the provision allowing for a review of the authorization in cases of mergers, spin-offs, acquisitions, transformations, or changes in corporate control of an already authorized legal entity (Art. 5, II and §1).

One of the most relevant provisions is Section III, which deals with betting integrity. It requires betting operators to implement security and integrity mechanisms and establishes the nullity of manipulated bets (Arts. 19 and 20).

Article 35 of the Law imposes a duty on operators to report any signs of manipulation to the Ministry of Finance and the Public Prosecutor’s Office within five business days of detection or knowledge of the incident.

These legal provisions bring the Brazilian model closer to systems adopted in the European Union and countries such as Australia and the United Kingdom, where the principle of shared responsibility for sports integrity is a key regulatory guideline.

Another regulatory advancement brought by Law No. 14,790/2023 is the creation of the Betting Management System (Sigap), which came into force on January 1, 2025. This system is responsible for monitoring and supervising the online gaming and sports betting sector in Brazil. Sigap allows for the detection of anomalous betting patterns by requiring operators to submit daily activity data. According to the Undersecretary for Monitoring and Supervision at the Ministry of Finance, the system provides detailed access to data that enables immediate and strategic action.

In terms of corporate governance, the law requires operators to implement customer service policies, internal procedures, control mechanisms, and an ombudsman (Art. 8). It also establishes a duty to monitor bettors' activities, which must begin from the moment an account is opened (Art. 23, §3).

The infralegal detailing of regulation has been carried out through ordinances issued by the Secretariat of Prizes and Betting (SPA), a body of the Ministry of Finance responsible for organizing and managing betting in Brazil, including fixed-odds betting.

For example, Ordinance No. 1,225/2024 from the SPA regulates the monitoring and supervision of operators and their activities. It establishes that such oversight must follow three main premises: i) evidence-based and risk-managed actions; ii) coordination and integration among public administration bodies and entities; andiii) proportionality to risks and coherence with operator conduct (Art. 4).

Despite these legal advancements, regulatory gaps remain, especially regarding the clear allocation of responsibilities in cases of integrity failures, the typification of sanctionable conduct, and the definition of objective criteria for automated betting monitoring systems.

International experience shows that infralegal regulation is crucial for the effective implementation of legal norms, as it enables adaptation to the complexities and dynamic nature of the betting market. In Brazil, it will be up to the Ministry of Finance and the regulatory authority not only to issue such rules but also to promote technical cooperation with other levels of government, police forces, sports confederations, and international institutions such as FIFA, Interpol, and the International Betting Integrity Association (IBIA).

3. International Experiences: Cooperation Models and Detection Systems

International experience has shown that combating match-fixing in sports betting requires a multisectoral, transnational, and technologically advanced approach, involving collaboration between sports entities, betting operators, regulatory agencies, and law enforcement authorities.

Countries that have faced crises involving match-fixing—such as the United Kingdom, Italy, and Australia—have developed legal and institutional frameworks capable of responding more effectively to the threats posed to sporting integrity.

In the United Kingdom, the Gambling Commission, established under the Gambling Act 2005, operates in coordination with sports bodies, licensed operators, and the police. A key component of the British model is the Sports Betting Intelligence Unit (SBIU), a unit dedicated to collecting and analyzing information on suspicious betting patterns, serving as a cooperation hub for rapid response. UK law criminalizes match-fixing and imposes formal reporting obligations on operators, which facilitates early fraud detection and real-time data sharing.

In Australia, the co-regulation model stands out. The federal government, through the Australian Communications and Media Authority (ACMA), oversees the sector in partnership with states and territories and requires operators to implement integrity programs. The National Platform, foreseen in the Macolin Convention, was adopted to foster information exchange and joint action between public and private stakeholders. The work of bodies like Sports Integrity Australia shows how regulatory structures can evolve into a national sports integrity platform with integrated technological and investigative capabilities.

Italy, in the aftermath of match-fixing scandals such as Calciopoli, implemented legislative reforms and strengthened the roles of the Autorità per le Garanzie nelle Comunicazioni (AGCOM) and the Polizia di Stato, employing computerized systems to track atypical behaviors in the betting market. The Italian experience highlighted that severe sanctions and international cooperation are essential for dismantling transnational criminal networks.

At the international level, the International Betting Integrity Association (IBIA) plays a central role. It brings together licensed betting operators and shares real-time alerts on anomalous patterns with sports and regulatory authorities. IBIA’s alert system has helped prevent hundreds of manipulation attempts in medium- and large-scale competitions. The effectiveness of this model lies in its anomaly detection technology and the use of predictive algorithms alongside statistical market behavior analysis.

Additionally, the Macolin Convention, promoted by the Council of Europe, offers an international legal framework for protecting integrity in sport. It recommends the establishment of national platforms, the criminalization of manipulation, and the creation of protected whistleblowing channels. Although not yet ratified by several countries, the convention serves as a benchmark for the development of public policies and legal frameworks.

Another noteworthy initiative is the formal agreement signed between the United Kingdom and France on January 19, 2018, aimed at sharing expertise and best practices in the fight against corruption and match-fixing in sports competitions. This agreement reinforced the strategic alignment between the two countries in addressing scandals such as doping and match-fixing, advocating for a global approach to protect sports integrity and restore public trust.

The agreement was well received by organizations such as ESSA (now part of IBIA), which described this model of cooperation as “exemplary” and encouraged other countries to follow suit by prioritizing integrity policies and international information-sharing in their sports betting markets.

These experiences demonstrate that successful models for combating match-fixing combine the following elements: a clear legal infrastructure and criminalization of match-fixing; integrated monitoring systems and detection of anomalous betting patterns; institutional cooperation among betting operators, sports bodies, law enforcement, and regulators; education and training for athletes, officials, and sports agents on the risks and ethical obligations involved.

4. Best Practices for Operators: Prevention, Transparency, and Dialogue with Sport

The consolidation of a reliable and ethical sports betting sector requires the adoption of policies aimed at preventing competition manipulation, transparency practices, and interinstitutional and international dialogues for sharing best practices.

Among the main elements of best practices is the implementation of internal integrity programs, which should include the creation and maintenance of data allowing for the monitoring of bets, conducting internal audits and corresponding risk assessments, the implementation of alert systems, and protected internal whistleblowing channels.

Competition monitoring can be carried out in various ways. Responsible operators have begun investing in specialized companies that utilize algorithmic analysis and Artificial Intelligence (AI) to identify unusual betting patterns, especially in lower-profile leagues where the risk of manipulation is higher.

According to research by the Swiss company Sportradar— a leader in sports data technology and a reference in sports integrity—around 71% of betting operators worldwide believe AI will revolutionize the betting sector. The research indicates that AI can be used by operators to analyze player data and create a detailed and accurate profile of their behavior, assisting in player risk assessments. Approximately 29% of operators see greater potential for AI application in negotiation and risk management areas.

Transparency is another fundamental pillar that operators must promote. This includes clear publication of operating rules, odds, refund policies, and customer service standards, as well as responsible advertising practices. In Brazil, SPA/MF Ordinance No. 1,231 of July 31, 2024, established rules and guidelines for responsible gaming and for communication, advertising, promotion, and marketing actions (Art. 1).

According to Article 3 of the Ordinance, fixed-odds betting operators are obligated to diligently structure their advertising, promotion, and marketing actions (Item I) and to promote awareness about risks by collaborating with educational campaigns aimed at society and at-risk groups for addiction and pathological problems related to gambling (Item II, a).

Many countries require operators to display responsible gaming warning messages and provide mechanisms for self-exclusion and spending limits. Brazil, for example, through SPA/MF Ordinance No. 1,231/2024, requires that two clauses be mandatorily included in all communication, advertising, promotion, and marketing actions: an age restriction clause and a clause on the risks associated with betting.

Another important aspect is active cooperation with organized sports. Many operators establish cooperation agreements with leagues, clubs, and federations to share data and promote awareness campaigns about match-fixing. Education for athletes, coaches, and sports agents is a highly impactful preventive measure, as recommended by the International Olympic Committee and the Macolin Convention.

In the United States, for example, the Coalition for Responsible Sports Betting Advertising was created, formed by sports leagues such as the National Football League (NFL), National Basketball Association (NBA), and Major League Baseball (MLB). They adopted six principles to ensure responsible sports betting advertising, including: 1) targeting only adults of legal betting age, 2) prohibiting misleading advertisements, 3) adopting internal procedures for advertising review, 4) taking consumer complaints seriously, 5) not promoting irresponsible or excessive gambling, and 6) adhering to standards of respect and ethical appropriateness.

Some internationally adopted best practices include the creation of internal integrity or compliance committees with independence to investigate irregularities; external certification of betting systems and algorithms by entities such as eCOGRA or GLI to ensure security and transparency; participation in international integrity associations like the IBIA, which securely share aggregated data with sports entities and authorities; and adoption of risk-based sports integrity protocols tailored to geographic context, sports disciplines, and bettor profiles.

Dialogue with the sports sector must also be ethical and responsible. Sponsorship of clubs and leagues by betting operators should respect integrity criteria, transparency in contracts, and compatibility with governance rules of the involved federations. In contexts where sponsorship blurs into indirect control over athletes or officials, there are risks of conflicts of interest and improper incentives, requiring specific regulation.

In the Brazilian case, such practices gain even more relevance given the lack of a regulatory history in the sector and the recent entry of several international operators into the country. The sublegal regulation provided for in Law No. 14,790/2023 may advance by requiring these operators to meet minimum integrity standards, including as a condition for maintaining their operating license. The adoption of compliance seals, certifications, and independent audits can also be encouraged as a form of positive market differentiation and as an incentive for sector self-regulation.

5. Proposals for Advancements in Brazil: Regulatory Cooperation and Sectoral Self-Regulation

Although Law No. 14,790/2023 represents a decisive step toward structuring the legal fixed-odds betting market in Brazil, the consolidation of a safe and integrity-driven environment requires complementary regulatory, institutional, and sectoral actions based on cooperation and self-regulation models.

The normative fragmentation and the current absence of a fully operational regulatory authority expose the sector to risks of uneven enforcement, regulatory evasion, and competitive inequality.

In this context, a promising complementary alternative to direct state intervention is the strengthening of sectoral self-regulation.

This model has proven effective in complex and dynamic sectors by allowing private agents themselves to develop and enforce specific rules. Within the sports betting context, this approach enables faster and more specialized responses, increasing operators’ commitment to ethical standards and internal compliance mechanisms.

Self-regulation has emerged as a complementary tool to state regulation in Brazil’s sports betting sector, especially in areas such as responsible advertising—for instance, through Annex X of the Brazilian Advertising Self-Regulation Code (CONAR), which establishes rules for betting advertisements aimed at protecting children, adolescents, and other vulnerable groups.

Other examples of self-regulation include implementing voluntary deposit limits, monitoring compulsive behaviors, risk communications, and warnings about time limits in sports betting.

However, the effectiveness of this institutional architecture depends on well-defined coordination between the regulatory entity—such as the Ministry of Finance—and regulated agents, encouraging participation by sports entities and sector representative associations, similar to existing frameworks in advertising (CONAR) and data protection (ANPD).

Within this logic, the most urgent institutional advance is the effective creation of the Brazilian regulatory authority, already provided for by law but still under development. International experience shows that specialized authorities with technical autonomy have greater capacity to coordinate monitoring systems, apply sanctions, and foster cooperation with sports organizations and operators. For this purpose, the future Brazilian agency is expected to be composed of specific integrity units, data analysis divisions, and multilateral cooperation channels, along with independent, transparent, and professional governance.

Concurrently, the implementation of a national sports integrity platform is proposed, inspired by the National Platforms foreseen in the Macolin Convention. This structure would bring together operators, oversight bodies, sports entities, and financial institutions, enabling real-time monitoring of bets, detection of suspicious patterns with artificial intelligence assistance, and preventive alerts sent to the involved parties.

Additionally, the integration of public and private databases—including athlete registries, competitions, bets, and complaint histories—emerges as an essential tool for cross-referencing information among operators, confederations, the Federal Revenue Service, the Financial Activities Control Council (COAF), and public security agencies. Such interoperability favors the construction of predictive risk systems and improves the State’s investigative and preventive capacity.

At the sectoral level, the strengthening of regulated self-regulation is equally relevant through the creation of a Brazilian Code of Integrity in Betting, collaboratively developed by operators, sports federations, the Ministry of Finance, and civil society representatives. This code would aim to establish minimum standards of conduct, compliance, reporting, and internal sanctioning, acting as a complementary instrument to state regulation.

Finally, it is recommended to encourage voluntary adherence by Brazilian operators to international organizations such as the IBIA to ensure access to global monitoring systems and cross-alert mechanisms. It is also proposed to include anti-corruption and integrity clauses in sports sponsorship contracts signed by operators, contributing to the establishment of a minimum ethical standard in relationships between companies and sports entities.

These coordinated measures form the pillars of a national strategy for sports integrity and betting in Brazil, adopting a systemic, regulatory, and educational approach. This is a necessary path to ensure sector sustainability, protect consumers, and preserve the credibility of national sports on the international stage.

6. Artificial Intelligence as a Tool for Promoting Sports Integrity

The growing complexity and internationalization of the sports sector, combined with the expansion of betting markets, pose unprecedented challenges to preserving the integrity of competitions. In this context, artificial intelligence (AI) emerges as a strategic ally in the prevention, detection, and investigation of match-fixing, corruption, and other illicit practices that threaten the credibility of sports.

One of the most established applications of AI in combating sports manipulation is the automated monitoring of betting markets. Systems based on machine learning and statistical analysis are capable of processing millions of transactions in real time and identifying anomalous patterns—such as unusual concentrations of bets on unlikely outcomes, abrupt changes in odds, or high-value bets on low-commercial-appeal matches.

Specialized companies like Sportradar and Genius Sports, contracted by organizations such as UEFA, FIFA, NBA, and national federations, offer AI-based fraud detection system (FDS) services that issue real-time integrity alerts. Sportradar, for example, recorded 1,212 alerts of suspicious matches in 2022 through its fraud detection system, with artificial intelligence contributing to the identification of 438 suspicious matches.

In Brazil, the Secretariat of Prizes and Bets of the Ministry of Finance has, through Ordinance SPA/MF No. 827/2024, required betting operators to maintain anti-fraud monitoring systems and share alerts with sports and law enforcement authorities, in accordance with Article 38 of Law No. 14,790/2023.

Moreover, AI enables the construction of predictive risk models that assign reliability scores to athletes, referees, teams, and competitions based on multiple variables: disciplinary history, statistically inconsistent performance, suspicious connections with bettors or officials, and financial data. This machine learning–based approach enhances the preventive and targeted actions of sports authorities.

Another relevant field is digital content analysis. Natural language processing (NLP) tools can monitor social media for suspicious conversations. When triangulated with betting information, such evidence can form a robust probative framework.

In the context of major events such as the FIFA World Cup, the Olympic Games, or the Club World Cup, AI scalability becomes essential. The high international exposure and diversity of agents involved make the existence of intelligent monitoring mechanisms indispensable to prevent scandals that could affect the competition’s credibility.

Artificial intelligence represents a watershed moment in sports integrity governance. Its ability to process large volumes of data in real time, identify hidden patterns, and support investigative and preventive decisions becomes crucial in light of the increasing sophistication of manipulation networks.

However, the effectiveness of AI depends on clear regulatory frameworks, data interoperability, and institutional capacity building—especially in countries like Brazil, where the betting market has been recently regulated and still faces structural governance challenges.

7. Conclusion: A Shared Commitment to Integrity

Recent data underscore the urgency and relevance of the proposals discussed throughout this work. In May 2025, a Technical Cooperation Agreement was formalized between the federal government and the company Sportradar, whose expertise in algorithmic betting monitoring is already internationally recognized. The agreement foresees, among other actions, the sharing of alerts through the Universal Fraud Detection System (UFDS) and the training of public agents to act in investigations related to sports integrity, based on structured data and artificial intelligence technologies.

Simultaneously, economic projections for the sector based on the most recent data from the Brazil Betting Market Report 2025, published in partnership with OKTO and H2 Gambling Capital, indicate that the regulated online betting market in Brazil will reach a gross revenue of approximately BRL 31 billion by 2025, with expectations of growth to BRL 64 billion by 2030. This reflects the strong potential for industry expansion under the new regulatory framework.

These figures illustrate both the economic potential of regulation and the urgency of implementing robust prevention, monitoring, and education tools.

However, the consolidation of an ethical, reliable, and sustainable fixed-odds betting market requires more than mere literal compliance with the provisions of Law No. 14,790/2023. It is a continuous and multifaceted process that demands effective coordination among different institutional actors—public and private—guided by principles such as transparency, interinstitutional cooperation, accountability, and risk prevention.

The Brazilian legal framework already establishes important parameters, especially by linking the operation of betting to mechanisms of integrity, governance, and fraud prevention. Nevertheless, as demonstrated throughout this work, the mere existence of formal rules is not sufficient to guarantee their effectiveness. Regulatory gaps, the absence of a fully functional regulatory authority, and the fragmentation of oversight systems create vulnerabilities to match-fixing and bad-faith operators.

In this scenario, self-regulation emerges as a promising tool to tackle the sector’s challenges. Inspired by successful experiences in areas such as advertising and data protection, this approach allows the combination of the private sector’s flexibility and specialization with the legitimacy and supervision of public authorities.

The promotion of integrity also involves a pedagogical dimension. Investing in education, training, and awareness is an essential preventive measure to mitigate the risk of match-fixing. Building a trustworthy, transparent, and ethical environment in sports betting depends on adopting robust regulation, self-regulatory instruments, and fostering an institutional culture oriented toward cooperation. This is the path to ensuring the credibility of Brazilian sports and the safety of bettors in a market that, if regulated responsibly, can bring significant economic and social benefits.

*Sobre o autor

Leonardo André Schilling

Diretor e Pesquisador do LABSUL

Mestre em Direito pela UNESC/BR com Co-orientação Internacional pela UPORTO/PT