Digital ECA: Digital platforms accessed by children and adolescents must publish Transparency Reports by September 17

The Brazilian National Data Protection Agency (“ANPD”) has clarified that providers of internet applications directed at children and adolescents, or likely to be accessed by this audience, must publish their first Semiannual Transparency Report, pursuant to article 31 of the Law No. 15,211/2025 (“Digital ECA”) by September 17, 2026.

The requirement applies to platforms with more than one million registered users under the age of 18 and constitutes one of the transparency measures established under Brazil’s new regulatory framework for the protection of children and adolescents in digital environments. According to the ANPD, the reporting deadline must be calculated from the date on which the legislation entered into force, on March 17, 2026. The report must be made publicly available and easily accessible, containing information regarding the measures adopted to ensure the safety, privacy, and protection of the rights of children and adolescents in digital environments.

Among other matters, the report must include:

– information regarding reporting channels and investigation procedures;

– the number of notices and notifications received, by category, and the actions taken in response;

– statistics concerning content and account moderation activities;

– measures adopted to identify child and adolescent accounts and detect unlawful conduct;

– technical measures implemented to protect children’s and adolescents’ personal data and privacy;

– technical mechanisms to verify parental consent; and

– results of impact assessments and risk identification and management measures relating to the safety and well-being of children and adolescents in digital environments.

The ANPD further clarified that the first report should, as a general rule, cover the period from January 1 to June 30, 2026. However, platforms that do not maintain systematized data for January and February may limit the scope of the first report to the period between March 17 and June 30, 2026, considering that the Digital ECA entered into force on March 17, 2026. In either case, the publication deadline remains September 17, 2026.

The publication of the guidance reinforces the regulatory expectation that digital platforms adopt robust governance, transparency, and accountability mechanisms regarding the measures implemented for the protection of children and adolescents. In this context, companies potentially subject to the Digital ECA should promptly assess their internal content moderation practices, risk management procedures, personal data protection practices, parental supervision mechanisms, and compliance documentation in order to ensure timely compliance with the new regulatory obligations.

The initiative represents another important step in the implementation of the Digital ECA and highlights ANPD’s increasingly active supervisory and enforcement role concerning obligations imposed on digital service providers accessed by children and adolescents.

Our Intelectual Property and Data Protection time remain at your disposal to clarify any questions and assist in assessing the impact of these obligations on specific activities and business models.