The future doesn’t wait. In 2026, the Brazilian regulatory landscape reaches a new level of maturity. We’re no longer just talking about “being compliant,” but about Third-Generation Compliance: proactive, integrated into product design, and focused on algorithmic management.
Below, we summarize the 4 pillars that should top your strategic agenda:
1. AI: From Theory to Civil Liability
With the AI Legal Framework (PL 2338/2023) consolidated, the focus shifts to explainability.
The challenge: Define criteria for Algorithmic Impact Assessments (AIA) and mitigate biases in sensitive sectors like health and credit.
Key point: The right to human review in automated decisions will become the new legal battleground.
2. Cybersecurity: The Era of Resilience
The Cybersecurity Legal Framework (PL 4752/2025) will require a mindset shift: from passive defense to systemic resilience.
The challenge: Risk management in the supply chain and new duties to report incidents to authorities.
Key point: Digital security is now a component of sovereignty and business continuity.
3. Digital ECA: Protection “By Design”
After the adaptation deadline of Law No. 15.211/2025, which will be on March 17, 2026, enforcement will be absolute. We now enter a new phase of ANPD oversight, which has become an agency.
The challenge: Implement robust age verification mechanisms and eliminate advertising profiling of minors.
Key point: Severe sanctions may include suspension of digital activities.
4. Financial Sector: Rigor and Governance
The Central Bank is intensifying oversight of IPs and PSTIs to ensure the stability of Pix, Drex, and Open Finance.
The challenge: Strict transactional limits and requirements for higher minimum capital to operate.
Key point: Governance and independent auditing become mandatory for survival in the ecosystem, especially regarding suppliers. The rise in deepfake fraud promises to be the year’s biggest concern.
How Peck Lawyers supports your 2026 journey?
To tackle this “regulatory convergence” scenario, our multidisciplinary approach includes:
Strategic Consulting:
We conduct risk mapping and process redesign (Privacy & Ethics by Design) for new products.
Specialized Litigation: Technical defense in high-complexity disputes involving AI, data protection, and cyber incidents.
Corporate Training: Executive and technical training to prepare your team for Algorithmic Compliance.
Social Impact: Through the Peck Institute for Digital Citizenship, we promote the education needed to make innovation inclusive and safe for future generations.
What to expect from 2026?
We anticipate a year of enforcement consolidation. Authorities (ANPD, BC, MP) will act in a coordinated manner. 2026 will be the year when Digital Law stops being an isolated department and becomes the core business of any company using data and technology.
The question for your leadership is: Is your company just following the law, or is it designing the future with it?
Count on us. Let’s talk.
Prepared by: Profa Dra. Patricia Peck, CEO; Dra. Giovanna Bortoto, Business Manager and Relgov; and Caroline Morata, Researcher in Relgov and Digital Law.
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