ANPD Clarifies Deadlines and Requirements for the First Transparency Report Under Brazil’s Digital Child Protection Act

Brazil’s National Data Protection Authority (ANPD) has published Decision Order No. 122/2026, providing important guidance on compliance with the obligation to prepare and publish Semiannual Transparency Reports established under the Digital Child Protection Act (Law No. 15,211/2025).  

The decision offers practical clarification for digital platforms and internet application providers subject to the reporting obligation while specific regulations are still under development.  

Who Must Publish the Report 

The obligation applies to internet application providers directed at children and adolescents, or likely to be accessed by them, with more than 1 million registered child and adolescent users connected to the internet in Brazil.  

The following entities remain exempt: 

• providers that do not reach the threshold of 1 million child and adolescent users; and 

• certain editorial-content providers and licensed content providers, provided they meet the statutory exemption requirements.  

Deadline for the First Report 

The ANPD clarified that the reporting obligation became effective on March 17, 2026, pursuant to Article 41-A of the Digital Child Protection Act.  

The first report must cover: 

• the period from January 1 to June 30, 2026; or 

• exceptionally, for providers that do not have information available for January and February 2026, the period from March 17 to June 30, 2026.  

The first report must be published by September 17, 2026. 

 

Required Content of the Report 

Until further regulation is issued, the ANPD has established that the report must contain, at a minimum: 

• available reporting channels and internal investigation procedures; 

• the number of reports and complaints received; 

• the number of content moderation actions and account moderation actions, categorized by type; 

• measures adopted to identify child accounts and unlawful activities; 

• technical improvements aimed at protecting children’s and adolescents’ personal data and privacy; 

• technical measures adopted to verify parental consent; 

• results of impact assessments, risk identification processes, and risk management activities related to the safety and well-being of children and adolescents.  

Additionally, the report must include: 

• the number of notifications received by category; and 

• proportional data regarding the actions taken in response to those notifications.  

Future Reporting Cycles 

Beginning with the second report, reporting periods must align with regular calendar semesters: 

• January 1 to June 30, with publication required by August 1; 

• July 1 to December 31, with publication required by February 1 of the following year.  

The ANPD also recommends that covered providers submit a copy of the report to monitoramento@anpd.gov.br at the time of publication, in addition to making it publicly available on their websites.  

Why It Matters? 

The decision represents another important step in the implementation of the Digital Child Protection Act (ECA Digital) and reinforces transparency and accountability obligations applicable to digital platforms accessed by children and adolescents.  

For social media platforms, content-sharing services, streaming providers, app developers, and other covered entities, compliance will require the development of internal processes capable of producing reliable metrics regarding: 

• content reporting and moderation activities; 

• child protection mechanisms; 

• risk assessment and management practices; 

• personal data protection measures; 

• age assurance and parental consent verification systems.  

The decision also provides an early indication of the ANPD’s regulatory expectations regarding governance, monitoring, and transparency, highlighting the increasing convergence of data protection, online safety, and child protection obligations in Brazil’s digital regulatory landscape.  

Peck Advogados continuously monitors regulatory developments involving the Digital Child Protection Act, the LGPD, and the legal framework applicable to digital platforms, providing specialized support to organizations in assessing regulatory impacts and implementing compliance measures. 

For further information, please contact contato@peckadv.com.br. 

Peck Advogados supports the social and educational initiatives of the Peck Institute for Digital Citizenship. Learn more at: www.ipcd.org.br 

Prepared by: Dr. Giovanna Bortoto, Head of Government Relations, and Caroline Morata, Legal Assistant at Peck Advogados.

AUTHOR

• Caroline Morata
• Giovanna Bortoto