Four agencies, no study: Planning, Revenue, and the Civil House confirm that the Provisional Measure on Betting was created without an impact assessment.
BNLData showed that the Ministry of Finance admitted, on the eve of Provisional Measure 1.394/2026, that there was no study on the impacts of the betting ban, and that the Ministry of Sport was not consulted ( read the report ). Responses to three other requests for access to information, filed on the same day, September 20th, complete the picture.
The requests were made to the Ministry of Planning and Budget (MPO), the Center for Tax and Customs Studies (CETAD) of the Federal Revenue Service, and the Civil House of the Presidency of the Republic. None of these bodies presented a study, technical note, or impact estimate of the prohibition.
These are not peripheral bodies. According to Estadão, Lula decided on the ban on September 23rd, at the Palácio da Alvorada, with ministers Dario Durigan (Finance), Moretti (Planning), and Miriam Belchior (Chief of Staff). The three ministries present at the meeting have no record, in their own documents, of any assessment of what they were deciding.
Planning: no evaluation, not even on betting in general.
The Ministry of Planning, Budget and Planning (MPO) responded on October 13, the last day of the deadline (NUP 03002.000745/2026-94), with the decision “Information Non-existent”. The Sub-Secretariat for Management of the Evaluation Cycle (SUAV) reported that, within the scope of the Council for Monitoring and Evaluation of Public Policies (CMAP), no evaluations “relevant to changes in the aforementioned public policy nor to bets in general” were carried out.
The request covered the period from January 1, 2025, until the date of the response. In those more than 21 months, the collegiate body responsible for evaluating public policies in the federal government did not address the betting sector even once: neither before nor after the Provisional Measure. The ministry concluded that it "does not have data or documents related to the evaluation of any changes in the federal public policy on fixed-odds betting."
Prescription: only previous documents, even after the Provisional Measure.
The response from CETAD is Note SIC Cetad/Coest No. 186 (NUP 18800.145988/2026-22). It was signed on September 29th, four days after the publication of the Provisional Measure. The Revenue Service's research center informed that Notes Cetad/Coest No. 009/2026 and No. 023/2026 are the "only documents produced by this Center, to date" on the subject. It added that it "is unaware of any other body or entity that has produced or is in possession of other documents".
In other words, with the ban already in effect, the technical area that measures federal revenue had not produced any new estimate of what the Union would fail to collect.
Chief of Staff: off-topic meetings and secrecy about the rest.
The Civil House, which coordinates the drafting of provisional measures, extended the deadline on September 29 and only responded on October 23 (NUP 00137.008286/2026-73), two days before the second round of voting. The decision was "Access Partially Granted".
The response lists six meetings of the Secretariat for Coordination and Monitoring (SAM) published on e-Agendas. None of them, prior to the Provisional Measure, dealt with prohibition:
The timeline shows that the government first prohibited gambling and then met to discuss oversight and advertising. The same applies to Decree No. 13.128, of September 28, which created the Interinstitutional Committee for Oversight of Illegal Gambling and Advertising, and to Ordinance SE/CC/PR No. 861, of September 29, which appointed its members. The guide “Children, Adolescents and Screens,” from March 2025, which is unrelated to the request, was also cited.
The Minister's Office merely indicated the public agenda and the links to the Provisional Measure and the forwarding order to Congress in the Official Gazette, documents that were already public.
The request explicitly asked whether the Civil House had requested, received, or analyzed studies, ex-ante evaluations , or impact estimates from other agencies. It also asked that any absence of such studies be declared. These questions remained unanswered directly.
The only document whose existence the Civil House admits is the legal opinion from the Special Secretariat for Legal Affairs (SAJ). This opinion was placed under seal based on attorney-client privilege (Law No. 8.906/1994) and the Civil Servant Statute (Law No. 8.112/1990). The SAJ extended the same restriction to all other documents in the process, arguing that they served to prepare the opinion.
The blanket secrecy contrasts with the general rule of the Access to Information Law itself. Article 7, § 3, ensures access to documents used as the basis for a decision from the moment the decision is issued, and the Provisional Measure was published on September 25th. If there had been an impact study on the process, the Civil House could at least have informed of its existence, as requested in the application. It did not.
The complete map
Combined with the responses from the Finance and Sports ministries, the answers show that none of the bodies with the competence or data to measure the effects of the ban presented any evaluation:
MP 1.394 blocks the Chamber's agenda on November 9th and will expire on March 4th, 2027 if it is not voted on. Congress and the Supreme Court will decide on a measure that, according to the government's own official records, was taken without anyone calculating how much it would cost, who it would affect, and where the gamblers would go. The illegal market is grateful.
