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Brazil
digital protection
global government advisory
online safety
Regulation
On August 27, 2025, Brazil’s Senate approved Bill PL 2628/2022, establishing one of the world’s most comprehensive digital child protection frameworks. Nearly three years after its initial filing, the legislation now awaits President Lula’s signature. If enacted, it could fundamentally reshape how tech companies operate in Brazil, and even globally, given Brazil’s position as the fifth-largest internet market.
Legislative focus: comprehensive digital safeguards for children and adolescents
The Senate plenary approved Bill 2628/2022 in a symbolic vote, following the release of a revised text by the Chamber of Deputies, with the analysis and text of Deputy Jadyel Alencar (REP-PI). Originally authored by Senator Alessandro Vieira (MDB-RS) and backed by a broad coalition of civil society organisations working to protect children and adolescents in Brazil, the legislation has been dubbed “ECA Digital” (Digital Child and Adolescent Statute).
The bill sets out a series of obligations for digital platforms, including:
- Mandatory content removal: Companies must remove content that violates children’s rights, including sexual abuse, exploitation, violence, kidnapping and grooming.
- Enhanced parental controls: Platforms must offer tools that allow parents to limit communication between children/adolescents, set time-of-use restrictions, and control or deactivate personalised recommendation systems, among other features.
- Age verification requirements: Operating systems and app distribution platforms (stores) must implement age verification systems and provide APIs (Application Programming Interfaces) to signal age verification to internet applications providers.
- Advertising restrictions: The use of profiling techniques to target minors with commercial advertising is prohibited, as well as emotional analysis, augmented reality, extended reality, and virtual reality for the same purpose.
- Loot-boxes and player interaction limitations: Games destined for children and adolescents may not include loot boxes and must, by default, limit interaction features between users.
Debate over loot boxes and new digital authority
One of the most controversial provisions that drew particular attention upon the bill’s return to the Senate was Article 20, regarding loot boxes. After strong opposition from Senate Rapporteur Senator Flavio Arns, the prohibition of loot boxes “in electronic games that are directed at children and adolescents or are likely to be accessed by them, according to age rating” was reinstated, after modifications were made in the Chamber of Deputies.
Earlier requirements had included mandatory reward guarantees, disclosure of probability rates, prohibition of virtual item commercialisation, and limiting mechanisms such as purchase caps and warning alerts. Now, the matter will likely fall under the responsibility of the Age Rating Policy Coordination Office within the Ministry of Justice and Public Security, which is currently reviewing updates to the Age Rating Policy Ordinance.
More broadly, the Bill also aims to create an independent administrative authority – upon specific regulation – to oversee the protection of minors’ rights in the digital sphere. This new body would monitor compliance throughout Brazil and issue supplementary rules. However, some senators opposed creating a new authority, suggesting instead that Anatel, the national telecommunications agency, could oversee implementation.
Lasty, the Bill requires foreign companies to maintain a legal representative in Brazil with powers to receive notifications and sanctions related to lawsuits and administrative proceedings.
Public pressure for approval and upcoming enforcement
The legislation’s rapid progression reflects unprecedented public pressure, triggered after YouTuber Felipe Bressanim Pereira (Felca) published a video denouncing the exploitation of minors – labelled as adultification (adultização) – and drawing national attention to the risks of child exposure on social networks.
The bill moved through Congress at an unusually fast pace after Chamber President Hugo Motta approved an urgency request on 19 August, followed by plenary approval of the text in a symbolic vote on 20 August. When the bill
returned to the Senate, it advanced in the same way, with urgency granted and the final vote held on the same day, 27 August.
Once signed into law, the legislation will take effect one year after publication. The new independent administrative authority – still to be defined – will have broad powers to monitor compliance, issue supplementary regulations, and apply significant penalties for non-compliance.
Our view
The approval of Bill 2628 positions Brazil at the forefront of global efforts to protect children in the digital space, but its implementation and oversight will be challenging. The comprehensive nature of the regulation goes well beyond content moderation, tackling fundamental platform design and business models, and represents a significant shift from voluntary self-regulation to mandatory compliance frameworks. Companies should begin preparing for substantial operational changes, including product redesigns with child safety as a priority and the establishment of robust age verification systems.
Given the legislation’s broad scope and Brazil’s market size, global platforms may find it more efficient to implement these protections worldwide rather than maintain separate systems for different jurisdictions. Companies operating across Latin America should also closely monitor discussions on implementation, as Brazil’s approach could influence similar legislation throughout the region. Proactive engagement with regulators, coupled with investment in child safety technologies, will be essential for ensuring compliance and maintaining market presence in this rapidly evolving regulatory environment.
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