(H1): Comparison with Argentina and Brazil (Paraguay)

Brief conclusion

Paraguay (CONAJZAR/DNIT) is a centralized regulator with growing canons and a course to expand competition in verticals (tenders, refusal of exclusive concessions).

Argentina - mosaic model: 24 jurisdictions, where the provinces and CABA themselves regulate offline/online (with different terms and conditions of licenses). It is legal and dynamic, but legally more difficult for operators.

Brazil is a giant market in the regulatory restart phase: Law No. 14. 790/2023 legalized fixed rates (sports/e-sports) and launched a series of bylaws; casinos on the ground aren't legal yet, and the integrated resort bill is in the Senate.

Regulatory architecture

Paraguay

Regulator: CONAJZAR, integrated into DNIT. Model - concession and tender (quiniela, bets, casino/bingo); public reporting on fees. In 2024, a record PYG of 175.768 billion was collected (≈ USD 22.2 million). In 2025, further strengthening of administration is declared.

Argentina

Regulation - provincial (including separate rules for CABA). The terms and conditions of online licenses differ: for example, CABA - 5 + 5 years; Prov. Buenos Aires and Cordoba - up to 15 years; Mendoza - 10 + 1.

Brazil

Law 14. 790/2023 (12/2023) launched a fixed rate regime; In 2024, the Ministry of Finance issued orders with technical requirements for operators (online games, live studios, AML/responsible game). For work - submission for authorization, payment of a high fee and compliance with strict standards.

Offline casino: no legalization; the Integrated Resorts Bill (PL 2234/2022) is in the Senate.

Offline market: what is allowed

Paraguay: operating casinos/slot halls and retail betting under concession scheme; expansion of competition - part of the agenda 2025-2026.

Argentina: offline regulated at provincial level; large nodes - Buenos Aires (province and city), Mendoza, Neuquen, etc. (conditions differ, as do tax regimes).

Brazil: Land-based casinos are not legal, a possible permit only after the bill passes the Senate.

Online market: current status

Paraguay: Online verticals fall under CONAJZAR/DNIT perimeter; a course to clarify the framework and tenders (amid rising fees).

Argentina: legal and decentralized - online regulated by provinces/SAVA; for operators, this means multi-licensing and local compliance under each jurisdiction.

Brazil: in focus - fixed rates (sports/e-sports) with federal authorization and technical regulations; authorities are actively blocking unregulated and demanding applications/fees. The discussion about online games is wider than betting is carried out within the framework of the bylaw.

Taxes and fees: where the cash flow flows

Paraguay: a key indicator is the CONAJZAR canons, which reached an all-time high in 2024 (PYG 175.8 billion). These amounts are not equal to GGR, but reflect an increase in turnover and collection.

Argentina: Tax/licensing rules vary by province (including online GGR rates, license fees, and marketing restrictions). Planning requires local calculations for each jurisdiction.

Brazil: high input duty and comprehensive authorization requirements; the regulator announced the suspension of those who did not apply, and tight control over advertising, AML and payments.

Complexity of entry and speed of scaling

In Paraguay, centralized tender/concession + explicit linkage to DNITs simplify predictability and launch speed, with competition increasing as reforms take place.

In Argentina - a regulatory maze of 24 solutions: high legal and operational burden, but also flexibility - you can choose "fast" provinces and build a portfolio.

Brazil has enormous potential for scale, but tough bylaws and public pressure on the industry (blocking/sanctions) make the time-to-market sensitive to compliance and timing.

Comparison Table (2025)

What it means for Paraguay (practically)

1. Window for online growth: Against the backdrop of a tough reboot of Brazil and fragmentation of Argentina, Paraguay with an understandable centralized frame can quickly scale online verticals through transparent tenders and DNIT control.

2. Tourist interception: the lack of land casinos in Brazil makes the border nodes of Paraguay (Ciudad del Este, Encarnacion) more attractive for overnight stays and events. (Consequence of the status quo in Brazil.)

3. Invest signal: record fees and public canon metric - understandable KPI for investors, bankers and regional authorities.

Looking to 2030

Paraguay: multi-licensing and digital control of fees → a steady increase in canons/taxes and the exit of new operators.

Argentina: convergence of practices between provinces (tougher KYC/AML, unification of technical requirements) while maintaining a mosaic of rates and deadlines.

Brazil: full formation of the fixed rate market; the prospects for IR casinos depend on the passage of the project in the Senate - when adopted, they will change the tourism map of the entire region.

At the start of 2025, Paraguay looks like a more predictable and fast-starting market than Argentina (legal fragmentation) and Brazil (tight regulatory transition + lack of offline casinos). For LatAm portfolio strategies, this means: Paraguay is a fast go-to-market, Argentina is a portfolio assembly by province, Brazil is a bet on scale while paying extra attention to compliance and the political cycle.

Sources: CONAJZAR/DNIT public data on Paraguay fees; analytical reviews and handbooks on Argentina's regulated online markets; Law No. 14. 790/2023 and orders from the Brazilian Ministry of Finance; topical industry publications on the status of casino bills.