Brazil expands ECA Digital enforcement

Update September 23, 2026: ANPD has called a public hearing for September 24 on its updated enforcement rules and administrative sanction process, with comments due through October 26 via Brasil Participativo. New developments also emerged in the Discord case, including the rejection of the company’s request for suspensive effect, demands for explanations, and talks over a possible compliance plan.

Brazil’s ANPD said its public consultation on the updated Enforcement Regulation and Administrative Sanctions Process Regulation will remain open until October 26, 2026. At the same time, the authority said it is consolidating comments for a guide aimed at providers of technology products and services on the scope and general obligations of the ECA Digital, while it expands monitoring of platforms and services covered by the law.

What is ANPD reviewing?

ANPD is adjusting its enforcement and sanction framework to support the application of the ECA Digital, which governs the treatment of technology products and services aimed at children and adolescents, or likely to be accessible to them. According to the authority, the regulatory review remains open to public input until October 26, 2026.

In parallel, ANPD said it is in the consolidation phase for comments on a guide for technology providers. The document is intended to define the scope of the ECA Digital and explain the general obligations that apply to companies offering those services.

The authority also formally announced a public hearing for September 24, 2026, on the updated Enforcement Regulation and Administrative Sanctions Process Regulation, with submissions accepted through October 26 on Brasil Participativo.

What monitoring has the authority opened?

ANPD said that in June 2026 it launched two monitoring processes to verify age-assurance mechanisms in Apple App Store, Google Play Store, Microsoft Windows, and pornographic content websites. In August 2026, it opened two more processes covering digital platforms, app stores, and generative AI tools.

According to the authority, those checks include permanent complaint channels, workflows for handling inappropriate content, risk mitigation by design, protective default settings, and controls to block minors from illegal or inappropriate content.

Convergência Digital reported that, beyond the regulatory update, ANPD still needs to publish for consultation the Dosimetry and Administrative Sanctions Application Regulation, which will incorporate its new powers tied to the ECA Digital.

In August, ANPD opened enforcement actions against major digital platforms, app stores, and generative AI tools to verify compliance with the ECA Digital and the updated regulation of Brazil’s Marco Civil da Internet.

What is the scope of ECA Digital enforcement?

Brazil’s Ministry of Justice and Public Security said that, since the ECA Digital took effect, ANPD has regulated and overseen compliance with Law No. 15.211/2025. Within that framework, the authority monitored 37 companies that offer technology products or services aimed at children and adolescents, or likely to be accessible to them, and opened monitoring processes covering 22 other digital platforms.

That official follow-up sits alongside other compliance obligations. Digital platforms aimed at minors, or likely to be accessible to them, with more than one million users under 18, were required to publish their first semiannual transparency report. That report must explain how the platform protects children and adolescents and how it manages risks and complaints.

ANPD said that deadline expired on September 17, 2026, according to a decisive order published in the Diário Oficial. In addition, the exclusive complaint channel for ECA Digital cases, created in June 2026, had received about 200 reports of possible violations.

The Ministry of Justice also said ANPD adopted enforcement measures, including a preventive injunction and an administrative sanction against platforms that failed to meet child and adolescent protection requirements.

What did the first reports and other official actions show?

A document review found that Roblox and Kwai published specific materials on child and adolescent protection under the ECA Digital. Official coverage also showed that the Brazilian government asked for investigations into chatbots that simulate friendship or romantic relationships and said the ECA Digital covers technology products and services aimed at children and adolescents, or likely to be accessed by them.

With that set of measures, ANPD now has authority to regulate part of the law and enforce compliance, while monitoring processes, rule updates, and transparency reporting requirements remain in force for covered platforms.

What happened with Discord?

ANPD ordered the suspension in Brazil of Discord’s video streaming function and equivalent video-sharing features in August, citing deficiencies in controls meant to prevent and mitigate serious risks to children’s and adolescents’ rights.

Specialized coverage said the investigation into Discord includes possible failures to prevent the exposure, recommendation, or facilitation of contact between minors and content linked to self-harm and suicide, along with shortcomings in age verification, content removal, and reporting to authorities.

According to Metrópoles, ANPD’s Enforcement Superintendency rejected Discord’s request for suspensive effect against the preventive measure. The authority said restoring livestreaming and equivalent video sharing before adequate controls are in place could repeat the conduct under review and cause new harm.

Correio Braziliense reported that the dispute also led to action by Brazil’s Attorney General’s Office, which is seeking to make the platform adopt specific protection measures in Brazil while the temporary suspension of livestreaming imposed by ANPD remains in effect.

Canaltech reported that Discord may have kept a technical path to bypass the livestreaming ban, after which ANPD demanded explanations. The enforcement process covers, among other points, mechanisms to prevent minors from being exposed to content related to self-harm and suicide, age verification, content removal, and notice to authorities about violations.

R7 added that the Brazilian government is discussing a possible compliance plan with Discord, with stages, deadlines, and verifiable outcomes to strengthen age verification and parental supervision. The authority said the livestreaming suspension is not considered final and will remain in place until the company shows controls capable of protecting children and adolescents.