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He emphasised the new system would make burdens less demanding than before, but the new ‘exit plan’ requirement and sharper duty‑of‑care definitions do bring some added complexity.

The KSA said that applicants were previously required to detail corrective actions taken to address previous breaches and outline measures to prevent future violations.

All submissions must also now include an exit plan – a new obligation that applies across the board. This requirement, intended to ensure orderly market withdrawal, marked a move toward embedding long-term risk management into the licensing process.

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The difference is all about the risk function. A sportsbook employs traders to price bets and manage its exposure. An exchange provides an API through which firms compete to quote prices and supply liquidity.

“Here’s an API. Bernard and 88 other people can market-make all these request-for-quotes (RFQs),” Marantelli says. “Some people might come in and just do esports because they’re esports experts. Others do everything. Some focus on same-game parlays. But it’s a sportsbook.”

The institutional layer is largely invisible to customers presented with a P2P proposition. Retail users may technically trade against one another, but the depth required by a mass-market product cannot be supplied by occasional customers alone. Professional firms must be prepared to quote continuously and commit substantial capital.

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Lula said he intends to discuss the matter with his team and analyse potential measures to consider the social impact of online betting.

What the president does not acknowledge is that the government relies on revenue from the sector. In just the first seven months of 2026, BRL8.747 billion generated by sports betting has already flowed into public coffers. The Federal Revenue Service estimates the total could reach BRL16 billion by the end of the year. In 2025, nearly BRL9 billion was collected from sportsbooks.

The burning question is where such funds will come from if Lula shuts down the betting industry. Yet, no one points out to him that players will simply migrate to the illegal market. Betting will continue to exist, but without formal tax revenue, oversight or player protections.