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Lesson 6 of 6 · 17 min

The Go-to-Market Plan and the Mistakes Already Made

Sequencing the region, the four business-case inputs entrants get wrong, organisation and local authority, the launch sequence, the list of failures the region has already produced, and what good looks like.

Fact-checked 23 September 2026 by iGaming Times editorial team · 11 sources

In this lesson

  • Choose and justify a market sequence and entry route
  • Build a business case on channelisation, local acquisition cost, effective tax and regional operating cost
  • Design a regional organisation with local authority
  • Sequence a launch from market study to full launch on the football calendar
  • Recognise the recurring failure patterns and avoid them

Sequencing the region

Few groups can enter every Latin American market at once, and those that tried have mostly regretted it. The sequencing decision is the first strategic choice, and there are three common patterns.

Brazil first. The largest market, the highest cost, the most competitive. Chosen by groups with the capital and the brand to fight for share, and by those whose existing grey-market presence gave them a base to convert.

Spanish-speaking first. Colombia as the training ground (the region's most mature online regime, regulated by Coljuegos since May 2016 with a levy of 15% of gross revenue less prizes, and an operating model that transfers), then Peru and the Argentine provinces, where licensing is provincial and the Province of Buenos Aires caps online licences at seven, then Brazil with a regional organisation already in place. Chosen by groups that want to learn the region before the most expensive exam.

Partner-led. Entering through a joint venture or acquisition with a local operator that already holds licences in several markets. Fastest to breadth, at the cost of shared economics and the diligence risk of a partner with grey-market history.

None is wrong. What is wrong is entering a market without a view on why it is first and what it teaches for the next.

The business case, honestly built

A Latin American business case has the same shape as any other and four inputs that entrants routinely get wrong.

Channelisation. The licensed market is a share of the total market, and the share depends on tax, restrictions and enforcement. Model the addressable licensed market, not the offshore total, and model it growing as enforcement bites, not as a step change on licensing day.

Acquisition cost. The grey years built brands. A new entrant in Brazil pays to reach customers who already hold accounts with established brands, and competes with those brands for football sponsorship and media. Acquisition cost assumptions should come from the market, not from the group's European experience.

Effective tax. Gaming tax plus corporate tax plus service and value-added taxes plus withholding administration plus cross-border payment taxes, modelled by a local adviser. The effective rate is what the lifetime value calculation uses, and it moves: Mexico, for example, set its special tax on games with wagers at 50% from 1 January 2026.

Payment and operating cost. Instant rails are cheap; everything else is not. Local hosting, certification, local staff and the compliance organisation are recurring costs that European entrants underestimate.

The output is a payback period per market. No regulator publishes payback periods, so treat any benchmark with caution and stress-test the four inputs above against the fixed costs of entry: in Brazil, the licence alone is a R$30 million payment for a five-year authorisation covering up to three brands.

Organisation

Successful entrants run the region as a region: a Latin American leadership team, local country managers with real authority, regional shared services for compliance, payments and trading, and a group relationship that provides capital and platform without imposing European product decisions. The failures are recognisable: a European head office managing Brazil as a remote market, a country team with no authority over marketing spend, or a partner joint venture where nobody has a clear mandate.

Local hiring is not optional. Regulatory relationships, media, payments and the football industry run on people who are known, and a group that parachutes in expatriates for the senior roles will be slower and worse informed than one that hires locally and supports them.

The launch sequence

For a direct licence entry, a realistic order:

  1. Market and tax study, business case, entry-route decision (six to twelve weeks).
  2. Local entity, banking, legal and tax advisers, local hires for compliance and country management (two to four months, overlapping).
  3. Platform selection or adaptation, certification, hosting, integrations with the regulator, payments, KYC (four to nine months, the long pole).
  4. Application submission and regulator engagement (timeline set by the regulator; in Brazil, under the May 2024 authorisation ordinance, the Secretariat has up to 150 days from filing to notify the applicant).
  5. Localisation of product, content, support and marketing; supplier contracts; sponsorship and media negotiations (in parallel with certification).
  6. Soft launch under the licence with limited marketing, to test payments, verification and support at scale.
  7. Full launch timed to the football calendar.

Compressing this sequence is how entrants end up with a licence and no product, or a product and no payments, on launch day.

The mistakes already made

The region's short regulated history has produced a consistent list of failures, and an entrant can learn from all of them without repeating any:

Treating the region as one market. One platform, one Spanish, one marketing plan. The customers noticed.

Assuming European margins. Higher tax, higher acquisition cost, thinner payment margins and heavier compliance produce lower margins, and business cases that carried European assumptions did not survive contact.

Under-investing in payments. Launching with cards and a wallet in a market that runs on an instant rail or on cash. In Brazil, deposits are limited to Pix, TED transfers, debit or prepaid cards and transfers within the same institution, with cash, boletos, cheques, crypto and credit cards barred; in Colombia, Coljuegos lists cash at physical payment points such as Efecty and Baloto among the ways to fund an account with a licensed site.

Ignoring the state. State lotteries and betting operators in several markets are competitors with a policy voice, and regulatory changes that favoured them surprised entrants who had not been paying attention. In Brazil, for example, the states and the Federal District may run the lottery modalities in federal law, fixed-odds betting included, within their own territory.

Bringing grey-market habits into a regulated market. Aggressive bonusing, influencer campaigns that ignored the new rules, loose KYC. Regulators in the region enforce: Brazil's law allows fines of up to R$2 billion per infringement, and the first penalties under a new regime are most likely to land on the operators that behaved as though nothing had changed.

Underestimating the political dimension. Tax rates, advertising rules and permitted products are decided by legislators who respond to public debate about gambling harm. Brazil's first year showed how fast that debate can move the rules: a year after the licensed market opened, a December 2025 law raised the public share of gross gaming revenue from 12% to 13% from April 2026, 14% in 2027 and 15% from 2028. An operator without a public affairs capability in the region is flying without instruments.

Buying a partner without diligence. Grey-market history, tax exposure, AML practice and licence conditions in the partner's existing markets all follow the acquirer.

What good looks like

The entrants that have done well share a profile: they chose a sequence and a route and explained it internally; they built the business case on local inputs; they hired locally and gave the local team authority; they invested in payments and localisation before marketing; they built compliance to the strictest standard in the group and engaged the regulator early and often; and they treated the region's regulatory and political movement as the environment rather than as a surprise.

The region will keep changing. Chile may license: its online betting bill passed a general vote in the Senate in August 2025 and in September 2026 was still being reworked with the Executive. Argentina's provinces will keep multiplying; Brazil's rules will move with its politics; Mexico will reform its federal gaming law eventually. An operator or supplier with the method this course has tried to teach, identifying the regulator, the licence, the tax, the enforcement posture and the payment reality for each market and verifying each against the primary source, will be able to read those changes as they come and decide what they mean.

Key terms

Payback period
The time for cumulative profit from a market to recover the cost of entering it.
Soft launch
Going live under the licence with limited marketing to test payments, verification and support at scale.
Public affairs
The capability to follow and engage with the legislative and political process that sets tax and advertising rules.
Country manager
The local leader of a market with authority over marketing spend, partnerships and regulatory engagement.

Key takeaways

  • What is wrong is entering a market without a view on why it is first and what it teaches for the next.
  • Model the addressable licensed market growing as enforcement bites, not a step change on licensing day.
  • Local hiring is not optional; regulatory relationships, media, payments and football run on people who are known.
  • Compressing the launch sequence produces a licence with no product or a product with no payments on launch day.
  • Treat the region’s regulatory and political movement as the environment, not as a surprise.

Sources

The legislation, regulator material and research this lesson was checked against.

  1. Lei nº 14.790, de 29 de dezembro de 2023 (consolidated text), art. 41 penalties, Presidência da República, Casa Civil (Planalto), accessed 2026-09-23
  2. Lei nº 13.756, de 12 de dezembro de 2018 (consolidated text), arts. 29 and 35-A, Presidência da República, Casa Civil (Planalto), accessed 2026-09-23
  3. Lei Complementar nº 224, de 26 de dezembro de 2025, art. 9 (amending art. 30 of Lei 13.756), Presidência da República, Casa Civil (Planalto), accessed 2026-09-23
  4. Portaria SPA/MF nº 827, de 21 de maio de 2024 (authorisation requirements), Diário Oficial da União (Imprensa Nacional), accessed 2026-09-23
  5. Portaria Normativa SPA/MF nº 615, de 16 de abril de 2024 (payment transactions), Diário Oficial da União (Imprensa Nacional), accessed 2026-09-23
  6. Acuerdo 08 de 2020, Title 1: reglamento de juegos operados por internet (compiling Acuerdo 04 de 24 de mayo de 2016), Coljuegos, accessed 2026-09-23
  7. Operadores de Juegos Online Autorizados por Coljuegos, Coljuegos, accessed 2026-09-23
  8. Ley 15.079 (Provincia de Buenos Aires), Título VIII, art. 152, Sistema de Información Normativa, Provincia de Buenos Aires, accessed 2026-09-23
  9. Decreto por el que se reforman y adicionan diversas disposiciones de la Ley del Impuesto Especial sobre Producción y Servicios (DOF 7 November 2025), Diario Oficial de la Federación, accessed 2026-09-23
  10. Apuestas en línea: comisiones unidas de Economía y Hacienda analizarán el proyecto en particular (14 August 2025), Senado de la República de Chile, accessed 2026-09-23
  11. Apuestas en línea: senadores piden regular y transparentar el mercado (8 September 2026), Senado de la República de Chile, accessed 2026-09-23

Check your understanding

3 questions · answer them all, then check.

  1. 1. A business case for Brazil uses the group’s European customer acquisition cost. The most likely error is:

  2. 2. Which organisational pattern is associated with failure in the region?

  3. 3. Why should a full launch be timed to the football calendar?

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