ANPD regulates Digital ECA transparency reports
First transparency report due by September 17
In brief
On August 11, 2026, the Brazilian Data Protection Agency (ANPD) issued Decision Order CD/ANPD No. 122/2026, which addresses requirements of the semiannual transparency reports required under the Children and Adolescents Online Safety Act (Digital ECA – Law No. 15,211/2025), such deadlines, the reporting period and minimum content. The obligation covers internet application providers that are directed at children and adolescents, or likely to be accessed by them, that have more than 1 million users in that age group registered in Brazil.
In more detail
As a general rule, the first report will cover the period from January 1 to June 30, 2026, though providers that do not have the relevant data for January and February 2026 may exceptionally limit this first report to the period from March 17 to June 30, 2026. Until further regulation is published, ANPD also set forth minimum content of the reports (complaint channels, number of complaints received, content and account moderation, personal data protection and privacy measures, parental consent mechanisms, and risk assessments). The decision also confirmed the exemptions and recommended that, in addition to publish the report at the website, providers should send a copy of the report to the ANPD upon publication. The measure provides greater predictability to the affected agents while additional and more comprehensive regulation is awaited.
Internet application providers potentially subject to the obligation should, from now on, (i) confirm whether they are subject to the reporting obligation, which applies to providers with more than 1 million children and adolescents registered as users in Brazil, or whether they fall under any exemption scenario provided in Article 39 of the Digital ECA; (ii) structure the collection and consolidation, in a single document, of the minimum content information defined by the ANPD; (iii) publish the first report on their own website by September 17, 2026, covering the period from January 1 (or March 17, in the exception) to June 30, 2026; (iv) send a copy of the report to the ANPD upon publication, as recommended by the Agency; and (v) monitor the issuance of specific regulation, which may change deadlines and content.
