The Senate plenary approved, on the evening of 17 December 2025, the bill reducing federal tax incentives by 10% across various economic sectors while increasing taxation on betting operators (bets), fintechs and interest on net equity (JCP). Complementary Bill No. 128/2025 passed by 62 votes in favour and 6 against, with Senator Randolfe Rodrigues (PT-AP) as rapporteur.
Note on status (updated)
PLP 128/2025 was subsequently sanctioned and became Complementary Law No. 224 of 26 December 2025 (LC 224/2025). The official text is available on the Planalto site at https://www.planalto.gov.br/ccivil_03/leis/lcp/lcp224.htm and should be treated as the controlling source, including for any provisions that were vetoed, amended in the final text or later regulated. The description below reflects the enacted narrative and the position as reported at enactment; where a figure or mechanism matters to a decision, confirm it directly against the statute.
Structural changes to fiscal policy
LC 224/2025 introduces changes to the Fiscal Responsibility Law (LC No. 101/2000), establishing stricter criteria for granting, expanding and extending tax, financial and credit incentives. Under the new Article 14-A of the LRF, a legislative proposal implying tax revenue waiver in favour of legal entities must include an estimate of the number of beneficiaries, a validity period (as a rule limited to five years), objective and measurable performance targets, and monitoring and evaluation mechanisms.
The main overall impact is a linear 10% reduction of federal tax incentives and benefits, affecting PIS/Pasep, Cofins, IPI, IRPJ, CSLL, Import Tax and employer social security contributions.
Impact on the betting sector
For the fixed-odds betting sector, LC 224/2025 is one of the most significant fiscal tightenings enacted since the market was regulated. The rate applied to the operator's gross gaming revenue moves from 12% on the following path: 13% in 2026, 14% in 2027 and 15% from 2028 onwards. As enacted, the additional revenue is allocated between social security and public health actions.
Timing and anterioridade
Increases of this kind do not take effect on publication. Brazilian constitutional law requires deferral before an increased charge may be demanded, and for social contributions the ninety day rule (anterioridade nonagesimal) applies counted from publication of the law, with the annual anterioridade rule applying to taxes to which it is applicable. The practical start date for each increased charge therefore depends on the nature of the charge, the effectiveness clause of LC 224/2025 and any implementing regulation from the Federal Revenue Service or the Secretariat of Prizes and Betting. Operators should map effective dates charge by charge rather than assuming a single commencement date.
Joint liability
LC 224/2025 contains joint liability provisions directed at intermediaries in the payment chain. As enacted, financial institutions, payment institutions, fintechs, payment service providers and other intermediaries may be held liable in respect of amounts connected to bets and prizes where they continue to facilitate transactions with unauthorised operators after formal notification by the competent authority. Provisions of this nature were also discussed in relation to parties engaged in advertising or promoting illegal betting. The scope of each liability rule, the trigger for it and the defences available depend on the wording of the enacted articles and on subsequent regulation, so the statute text should be read before assessing exposure for any specific intermediary, platform, agency or media counterparty.
Impact on fintechs and financial institutions
For fintechs, payment institutions and other financial sector entities, the principal impact reported at enactment is an increase in the Social Contribution on Net Income (CSLL). As reported at enactment, credit, financing and investment companies and capitalisation companies move from 15% to 17.5% until 31 December 2027 and 20% from 1 January 2028, while entities at 9% CSLL move to 12% until 2027 and 15% from 2028. Applicability turns on the precise classification of the entity under the statute, and readers should confirm the rate and the effective date for their own classification against the LC 224/2025 text on Planalto.
JCP taxation
Also as reported at enactment, the withholding income tax rate on Interest on Net Equity (JCP) rises from 15% to 17.5%, reducing the tax advantage of an instrument widely used to remunerate shareholders. Again, confirm the final wording and the effective date in the statute.
Summary
LC 224/2025 consolidates a structural shift in Brazilian fiscal policy, combining reduced tax incentives, direct rate increases and expanded liability provisions. For bets, fintechs and financial institutions the effect is a heavier tax burden, greater regulatory risk exposure and higher compliance demands from 2026 onwards. Companies in these segments should review business models, corporate structures, advertising policies and control systems against the enacted text rather than against reporting of the bill as approved.
For the pre-enactment policy analysis published before the Senate vote, see the companion article at /insights/betting-taxation-risks-senate-legal-certainty-regulated-market.