Reglab

Atlas of the Brazilian Digital Ecosystem Regulation

Reglab presents the Atlas of the Brazilian Digital Ecosystem Regulation, a comprehensive and systematized guide to the legal and governmental landscape of technology in Brazil. This exploratory and descriptive mapping brings together the main federal regulations, laws, and decrees that impact the functioning of the Brazilian digital market.

The study is divided into essential thematic pillars, such as Artificial Intelligence, Competition Regulation, Content Moderation, and Data Protection. Focusing on the developments of 2025 and key trends for 2026, the Atlas highlights milestones such as the enactment of Law 15.211/2025 (Digital ECA) and the Supreme Court (STF) rulings regarding the Brazilian Civil Rights Framework for the Internet (Marco Civil da Internet).

Developed to assist companies, policymakers, and trade associations, the Regulatory Atlas offers a clear snapshot of national digital governance, promoting a qualified public debate and data-driven decision-making.

Citar

NOMURA, D. N. S.; ANDRADE, A. B. Atlas da Regulação do Ecossistema Digital Brasileiro. Formatos Especiais Reglab. n. 2. São Paulo: Reglab, 2026.
Nomura, D. N. S., & Andrade, A. B. (2026). Atlas da Regulação do Ecossistema Digital Brasileiro (Formatos Especiais Reglab, n. 2). Reglab.
Nomura, Daniela Naomi Shimabukuro, e Andressa Bizutti Andrade. Atlas da Regulação do Ecossistema Digital Brasileiro. Formatos Especiais Reglab, n. 2. São Paulo: Reglab, 2026.

Autores

  • Daniela Naomi Shimabukuro Nomura
  • Andressa Bizutti Andrade

Tags

Introduction: Why do a mapping

The digital environment in the country is regulated by a broad set of standards that form a consistent governance structure, and the Atlas of Regulation of the Brazilian Digital Ecosystem aims to give visibility to this structure. Inspired by the work developed byCenter for European Policy Studies (CEPS), which identified and cataloged dozens of legal instruments and governance mechanisms in the European Union, the study adapts this proposal to the Brazilian context.

Our objective is to bring together, on a public and visual basis, normative instruments that shape the functioning of the Brazilian digital ecosystem, such as laws, decrees, acts of the Executive and Judiciary Powers and self-regulation instruments; and identify

the institutions responsible for its preparation, implementation and supervision. By systematizing this information, the mapping offers a clear and accessible portrait of digital governance in Brazil, contributing to public debate and the formulation of evidence-based policies.

Considering the dynamic and constantly updated nature of the topic, the study is a work in progress, reflecting the continuous evolution of the regulatory system. The database is made up of two tables:

  • Table 1: normative instruments relevant to the regulation of the digital governance ecosystem. The survey considered normative instruments promulgated until November 6, 2025, which constitutes the formal cutoff date for the research. After this date, we punctually included some approved instruments that are widely recognized as relevant to the Brazilian digital ecosystem. These inclusions do not represent a systematic review of all thematic axes, but targeted updates, restricted to standards of high regulatory materiality.
  • Table 2: bodies, institutions and associations that contribute to the formulation, implementation and supervision of the normative instruments identified in Table 1 and related to digital governance.

Our database was developed by classifying regulatory and governance instruments into 17 thematic areas. In the section “Scenarios and Trends”, we present legislative movements, such as bills and regulatory proposals that deal with central themes on the digital agenda and which, if approved, could significantly change the regulatory structure of the Brazilian ecosystem.

EXPLANATIONS ABOUT THE SURVEY AND METHODOLOGICAL SAVAGES

This mapping was conducted as an exploratory and non-exhaustive research. Searches were carried out using keywords on Google, using only official sources. The objective was to bring together a representative set of standards and acts with a direct impact on the regulation of the digital environment, without claiming to be exhaustive. There were no analytical inferences or value judgments on the content of the standards, so the result reflects a merely descriptive mapping. Documents of an interpretative or administrative nature, such as technical notes, statements and communications, were excluded from the database as they did not establish normative obligations, with the exception of those with a relevant impact on market orientation, which were kept in the mapping. Ordinances that establish regulatory agendas or planning (due to their temporal and dynamic nature), judicial decisions or control bodies, and internal management acts, such as those dealing with electronic systems, administrative structures or institutional websites, were also outside the scope. An important caveat refers to ANATEL: practically the entire set of normative acts of the agency deals with connectivity, a specific thematic axis of this project, and the full inclusion of this collection would artificially expand it, producing asymmetries that would compromise comparability. with other themes. For these reasons, only direct and material impact standards were prioritized.

Scenarios and Trends

Overview of proposals that could transform the regulatory environment in the coming years

AI regulation

Brazil does not yet have specific federal legislation on AI. However, in December 2024, the Federal Senate approved PL 2,338/2023, currently the main proposal under discussion in the National Congress on the regulation of technology in Brazil (Senate Agency, 2024).

PL 2,338/2023 establishes an extensive set of measures to regulate the development and use of artificial intelligence. The text adopts a risk-based approach, defines an extensive list of rights for users affected by these technologies and establishes regulatory governance mechanisms aimed at implementing and supervising practices related to AI.

The project has been in progress since May 2025 in the Special Committee of the Chamber of Deputies. Currently, the process awaits publication of the rapporteur’s opinion, which must be voted on in the Plenary and, if approved, will return to the Senate for final deliberation (Kaufman, 2025). PL 2,338/2023, therefore, still must go through some stages before its potential approval in the National Congress.

Competition regulation

The scenario of regulating digital markets in Brazil has gained a lot of relevance in recent months. In October 2024, the Secretariat for Economic Reforms of the Ministry of Finance (SRE/MF) published the report “Digital Platforms: economic and competitive aspects and recommendations for regulatory improvements

in Brazil”. Based on international experiences and contributions received in the Subsidy Collection held between January and May 2024, the document points out that the tools of the Competition Defense Law (Law 12,529/2011) are insufficient to deal with the dynamics of digital markets (Ministry of Finance, 2024).

As a result of this diagnosis, in September 2025, the Federal Government sent PL 4,675/2025 to the Chamber of Deputies, which proposes the economic and competition regulation of large technology companies. Prepared by SRE/MF and a technical group coordinated by the Civil House, the text suggests the reform of Law 12,529/2011, incorporating new instruments aimed at “systemically relevant” economic agents (Ministry of Finance, 2025). These agents, characterized by substantial economic power and influence on the dynamics of digital markets, would be subject to specific compliance duties, such as maintaining an office in the country, registration with CADE, prior submission of mergers and disclosure of information about the offer and use of their services.

Currently, PL 4,675/2025 awaits dispatch from the President of the Chamber of Deputies, with the urgent request still pending deliberation (Chamber of Deputies, 2025).

Content moderation

The main legal instrument that guided content moderation in Brazil was article 19 of the Marco Civil da Internet, which restricted the civil liability of platforms to the existence of a specific court order to remove content published by users. On June 26, 2025, the Federal Supreme Court (STF) declared the device partially unconstitutional, and created new rules for content moderation, reformulating the legal bases for accountability and governance of online content in the country. The decision represents a recent milestone

and of great systemic impact, whose practical consequences and jurisprudential consolidation are still ongoing.

On September 23, 2025, the Superior Court of Justice (STJ) decided not to immediately apply the STF’s new understanding, highlighting that the ruling had not yet

final and could have its effects modulated in motions for clarification (Brazil, 2025). With the publication of the ruling on November 5, 2025, the deadline for possible appeals began, and the definitive scope of the decision, as well as its effects on the content moderation regime, still depends on subsequent definitions by the STF.

Furthermore, on September 17, 2025, Law 15,211 was sanctioned, which establishes the Digital Statute of Children and Adolescents (ECA Digital). The rule imposes expanded duties of moderation and active removal of content on platforms likely to be accessed by minors, regardless of a court order. Scheduled to come into force in March 2026, the law adds a new layer of complexity to the regulatory landscape of content moderation in the country, which now combines proactive intervention obligations with a jurisprudential framework that is still being consolidated.

Digital Creators

In the last ten years, the National Congress received more than 80 bills aimed at regulating the activity of digital influencers, addressing topics such as content rules, advertising and digital marketing, recognition of the profession and protection of minors in online environments (Branches; Garrote; Brombine, 2025).

Among the proposals, PL 3,444/2023 stands out, approved by the Chamber of Deputies in October 2025 and currently being processed in the Federal Senate (Piovesan; Miranda, 2025). The project amends the Child and Adolescent Statute (ECA) to establish that artistic representation activities involving children and adolescents depend on court approval, while other forms of economic exploitation in the digital environment are prohibited.

Bet advertising

In Brazil, bills that seek to further restrict online betting advertising are gaining prominence. In May 2025, PL 2,985/2023 was approved in the Senate, proposing to prohibit advertisements and advertising actions for fixed-odd bets involving athletes, artists, communicators, influencers or public authorities. The measure, which is subject to consideration by the Chamber of Deputies, reflects a growing concern about encouraging gambling and its potential addictive effects, especially among young people and vulnerable populations (Senate Agency, 2025).

Audiovisual regulation

The debate on the regulation of streaming and video on demand services advanced significantly in the National Congress in 2024 and 2025. In April 2024, the Federal Senate approved PL 2,331/2022, which regulates the provision of video services under

demand, of platforms for sharing audiovisual and television content via internet protocol (Senate Agency, 2024).

In the Chamber of Deputies, PL 2,331/2022 was attached to PL 8,889/2017, which was already being processed and dealt with the same topic. Both were analyzed together, and the Plenary approved a favorable opinion on all the attached projects. As the text approved by the Chamber revisits and substantially incorporates the matter approved by the Senate in PL 2,331/2022, the Senate Presidency determined the assessment of the matter as a Substitute of the Chamber of Deputies to PL 2,331/2022, with the filing of PL 8,889/2017 (Federal Senate, 2025).

With this, legislative deliberation will continue with PL 2,331/2022 as the main proposition, consolidating the discussion on the establishment of rules for streaming services and videos on demand, with the expansion of the Contribution for the Development of the National Cinematographic Industry (Condecine) for these platforms with the aim of promoting the Brazilian audiovisual sector.

Protection of children and adolescents in the digital environment

On September 17, 2025, Law 15,211/2025 was sanctioned, which establishes the Digital Statute of Children and Adolescents (ECA Digital). The standard establishes unprecedented rules to protect children and adolescents in the online environment, but depends

of specific regulations not yet published to define compliance and inspection procedures.

With this objective, the Intersectoral Committee, composed of the Ministry of Justice and Public Security (MJSP), Ministry of Human Rights and Citizenship, Secretariat of Social Communication and CONANDA, carried out Public Consultation between October and November 2025 to collect subsidies for ECA Digital regulation.

In the same period, the MJSP opened another Public consultation on measurement mechanisms age in information technology products and services, seeking contributions from users, companies and civil society organizations. The two consultations brought together more than 130 contributions, reflecting broad public interest in regulating digital environments aimed at minors.

Still in this context, the National Data Protection Agency (ANPD), the authority responsible for supervising ECA Digital, opened a socket of subsidies to identify which concepts of the Statute require clarification additional. The objective is to reduce ambiguities that could hinder the implementation of the standard and compromise its effectiveness in protecting children and adolescents in the digital environment. This movement reinforces the government’s effort to consolidate minimum operational guidelines before definitive regulation.

Annex 01

Standards Overview

Annex 02

Governance Mechanisms