Reglab

From the Feed to the Planalto: Governance of the Relationship Between the Federal Executive and Influencers

Reglab is proud to launch the highly anticipated second edition of its Radar series: “From the Feed to the Planalto,” presented at Engage.hub. This new report deciphers the complex dynamics between the Brazilian Federal Executive Branch and digital influencers.

This in-depth study contrasts executive actions with the findings from Part I (“From the Feed to the Plenary”), which focused on the Legislative Branch, providing a 360-degree view of influencer governance at the federal level.

Instrumental Use: Creators as a Tool for Public Communication

Reglab’s research reveals that the Federal Executive has systematically incorporated digital creators into its public communication strategies. Analyzing data from 2018 to 2025, the report identifies a primarily instrumental approach. The leading justification for these partnerships (47% of the discourse) classifies creators based on their “popularity, reach, and influence.”

Research Highlights:

  • Growth: The total number of initiatives involving influencers has doubled under the current administration.

  • Key Players: The Ministry of Health and the Ministry of Justice and Public Security lead the list of federal agencies with the most strategic actions involving digital creators.


The Policy Gap: Risk vs. Recognition

Despite the expansion of these communication efforts, the report highlights a critical failure: Brazil lacks a structured and comprehensive public policy for the digital influencer sector. While use for advertising grows, the Executive has yet to:

  • Provide adequate professional recognition for the sector.

  • Create policies dedicated to digital entrepreneurship.

  • Ensure labor protections for content creators.

Furthermore, a significant portion of Executive action (42% of the discourse) views creators through the lens of risk and legal liability, focusing on enforcement and regulatory surveillance rather than sectoral incentives and structuring.

Citar

RAMOS, P. H. R.; BALBY, L. BROMBINE, G. Do Feed ao Planalto: o Executivo Federal e os Influenciadores Digitais. Radar Reglab.n. 4. São Paulo: Reglab, 2025.
RAMOS, P. H. R., BALBY, L., & BROMBINE, G. (2025). Do Feed ao Planalto: o Executivo Federal e os Influenciadores Digitais (Radar Reglab, n. 4). Reglab.
Ramos, Pedro Henrique, Luiza Balby, e Giulia Brombine. 2025. Do Feed ao Planalto: o Executivo Federal e os Influenciadores Digitais. Radar Reglab, n. 4. São Paulo: Reglab.

Autores

  • Pedro Henrique Ramos
  • Luiza Balby
  • Giulia Brombine

Tags

Engage.hub is Reglab’s applied research hub that investigates the social, economic and regulatory impacts of influencer marketing and digital creative. Our objective is to qualify the market and public policies with more data and evidence.

SUGGESTED QUOTE, P. H. R.; BALBY, L. BROMBINE, G. DoFeed to Planalto: the Federal Executive and Digital Influencers. Radar Reglab. n. 4. São Paulo: Reglab, 2025.

influencers are a government strategy, but they are not yet state policy.

  • The Executive mobilizes influencers mainly as a public communication tool. Almost 50% of the actions analyzed use creators to expand health, human rights and tourism campaigns – but without professional recognition or specific policies for the sector;
  • Ministry of Health and Ministry of Justice and Public Security lead the use of influencers in strategic actions. During the Lula government, this movement intensified,

and the total number of initiatives doubled compared to the previous government, with significant growth in health campaigns, human rights and emergency actions spread across different bodies.

  • Brazil does not yet have a public policy for digital influencers.Although its instrumental use has grown, digital creators still do not have a specific CNAE, dedicated cultural policy, digital entrepreneurship initiatives or labor protection guidelines, failing to

recognize these professionals as part of the creative economy,

information infrastructure or digital work

contemporary.

Brazil is the country with the most digital influencers in the world. There are 3.8 million content creators – almost 16% of all influencers on the planet. To get an idea of the magnitude of this phenomenon: there are more influential professionals in Brazil than doctors, lawyers or engineers with active professional registration. This is not just a curious fact, but the portrait of a profound transformation in society.

This study integrates a new Reglab series, produced by the Engage.hub research center, dedicated to understanding how the Brazilian State responds to the growth of the influencer economy and the strategic role that digital creators have started to play in public, political and cultural mediation.

In October 2025, our first report, “From Feed to Plenary”, mapped the activities of the National Congress,

examining bills and narrative disputes that shape the regulation of creators, revealing a reactive Legislature, marked by a predominantly negative and moralizing view of digital influence.

In this new stage, we move to a different terrain: the federal Executive Branch.Unlike the Legislature, the Executive produces direct actions – programs, campaigns and implementation mechanisms that affect the lives of influencers and the

broader dynamics of public communication.

Investigating the Executive is crucial because it is through it that public policies become concrete.

With this, we offer a complementary vision, allowing us to understand not only what the State says, but above all what the State does in the face of digital influence. This is a relevant contribution for companies, policy makers and researchers interested in more coherent regulation, based on evidence and sensitive to the complexity of this ecosystem.

Who are digital influencers?

Who, after all, are Brazilian digital influencers? Contrary to the popular image of young people in their 20s, the majority are in their 30s. Cisgender women largely dominate the sector, and ethnic diversity also shows up in the numbers. In terms of interaction, nano-influencers (1K-10K followers) engage more than twice as much as large profiles, and in Brazil we have the highest global purchase rate based on recommendations from influencers.

It is a 20 billion reais market, which grew around 43% in the last year

Sources: Census of Creators (Squid, 2023); Hypeauditor (2025); Influencer Marketing Benchmark Report (2025).

adherence to primary sources, we recognize that this choice can reproduce the gender asymmetry present in legal texts and, therefore, should not be

understood as neutral, it is also necessary to problematize how normative language can reinforce invisibility. Because of this, we chose to alternate

the use of masculine and feminine in the sections of the report that involve analysis and comments.

the researched universe

For this study, we used publications in the Official Gazette of the Union and in Portal Gov.br fromJanuary 1, 2018 and until November 15, 2025, including not only official acts and communiqués, but also news that disclosed actions by the Federal Direct Administration on the topic. This is a non-exhaustive analysis, but with corpus robust enough to the evaluation proposed in this work.

[IMAGE 1 — replace with the corresponding image from the PDF]

period we carried out in the research “From Feed to Plenary” (2015 -2025). However, mentions during this period were minimal, not affecting the conclusions and findings of this research.

Digital creators are integrated as a communication tool, but they also emerge as a source of risk

The federal government has regularly incorporated digital influencers into its public communication strategies, using them as intermediaries to reach different audiences. Furthermore, they are included in future strategic plans and are also targets of police operations and security actions. enforcement.

The plateau perceives influencers as…

41% 21% 18% 21%

The Executive’s actions focus on health and safety, revealing usefulness and risk

The Ministry of Health uses influencers mainly for public communication campaigns, while the Ministry of Justice and Public Security carries out risk awareness, surveillance and enforcement actions. Tourism, Economy and Human Rights appear next, demonstrating that content creators are also incorporated into economic, cultural and inclusion agendas. SECOM, in turn, consolidates guidelines for its institutional use.

there was an accelerated expansion of actions involving digital influencers from 2023 onwards

Until 2022, the federal government’s work with digital creators was concentrated in just 8 bodies, with more than half of the actions carried out by the Ministries of Health and Tourism. From 2023 onwards, a significant change is observed: actions not only increase but also involve 14 different bodies, showing greater institutional dispersion and transversal use

The importance of digital creators for government strategy has increased from 2024

Until 2023, actions involving influencers were isolated and dispersed, without demonstrating a coordinated institutional strategy. From 2024 onwards, especially with the reformulation of the government’s Social Communication Secretariat, a qualitative change will be observed: the use of digital creators will become more structured, intentional and incorporated across federal public policies.

Ministry of Health uses influencers for campaigns and adopts digital logic in its public communication

The work of the Ministry of Health, with actions since 2018, reveals a standard of maturity when integrating influencers as amplifiers of national campaigns on topics such as dengue fever, breastfeeding, organ donation and HIV. The case of Zé eotinha “digital influencer” demonstrates the institutional appropriation of the creators’ logic, incorporating formats, languages ​​and strategies typical of social networks to expand the reach and adherence of messages, consolidating a model in which influence is seen as a tool to guide behavior and disseminate public policies more efficiently.

Influencers enter the Ministry of Justice’s security and consumption radar

The actions of the Ministry of Justice and Public Security are mostly concentrated from 2023 onwards and show a pattern of framing influencers as actors subject to legal accountability and regulatory surveillance. Police operations were announced with a focus on the role of influencers, while Senacon publishes technical notes and alerts that reinforce obligations of transparency and co-responsibility in digital advertising. Furthermore, campaigns such as “Don’t Wait 24h” show that the agency also uses communication to guide consumers.

With the growth of influencer marketing, more and more companies and brands have turned to digital influencers to promote their products and services. However, when there is any type of commercial relationship involved — whether through direct payment, shipping of products, bonuses or other forms of benefit — the content needs to be labeled as advertising. This applies to posts, videos, reels, stories, live broadcasts or any other format With the growth of influencer marketing, more and more companies and brands have turned to digital influencers to promote their products and services. However, when there is any type of commercial relationship involved — whether through direct payment, shipping of products, bonuses or other forms of benefit — the content needs to be labeled as advertising. This applies to posts, videos, reels, stories, live broadcasts or any other format
Official Communication from Senacon, 06/17/2025

Importance of influencers in tourism peaked in 2019–2020 and today combines communication with international soft power

The actions of the Ministry of Tourism show that the use of influencers was more intense and structured between 2019 and 2020, when EMBRATUR budget resolutions explicitly mentioned creators as part of the country’s promotion strategy – documents that were later revoked or no longer appeared. At the same time, initiatives such as the International Tourism Acceleration Program reinforce that influencers can not only be vehicles for campaigns but also instruments of soft power, capable of projecting the country abroad and supporting economic agendas.

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Tourism today is a social and digital experience. Those who travel are influenced by what they watch and what people share on YouTube, but also in series and gamesMarcelo Freixo, president of Embratur, 11/13/2025

The Treasury’s operations combine financial education, supervision and growing regulatory impact on influencers

At the Ministry of Finance, influencers appear both as partners in financial education actions – such as in the Olympics conducted by the National Treasury – and as targets of Federal Revenue operations. Although it is not the direct focus of this study, it is worth highlighting the role of the CVM, an agency linked to the Ministry, which has so far produced the only Regulatory Impact Analysis of the Federal Executive dedicated to influencers, specifically to finfluencers.

The partnerships aim to create a support network to publicize the initiative and engage school communities, including principals, teachers and students. Influencers will also be able to associate their personal brands with a cause of great social impact, with positive gains in image and exposure.

Human Rights uses influencers to expand protection, inclusion and creation of networks of social communicators

The work of the Ministry of Human Rights and Citizenship shows a consistent use of influencers as mobilization agents on sensitive agendas, such as protecting children, combating violence, institutional celebrations and inclusion campaigns. In addition to public communication pieces, the Ministry created a specific form for communicators and creators, formalizing a network of partners capable of disseminating content aligned with human rights agendas.

Ambassadors of media education: articulation and collaboration with digital influencers to produce and carry out campaigns on social media, in a project that will involve the appointment of “ambassadors of media education”, as well as engagement with social movements and children and adolescents who can act as ambassadors in their schools and communities.Estratégia Brasileira de Educação Mediatica, 10/2023

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SECOM consolidates its own agendas and expands the use of influencers in national campaigns

The Social Communication Secretariat assumes a central role in the government’s digital strategy, guiding the actions of all ministries. Last year, there was also a significant increase in the presence of influencers in paid media campaigns coordinated by SECOM, demonstrating a growing institutionalization of the use of creatorsin government communication. In its own initiatives, it is worth mentioning the Brazilian Media Education Strategy and the Guide on children, adolescents and screens, which structure guidelines for the responsible use of digital influence.

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Recommendations for Digital Influencers:(…) Be transparent about advertising messages contained in their speeches or programs, using forms of identification of the commercial link that are not restricted to written text.Restrict the work of children and adolescents in the digital environment, being aware of the exception nature, as well as the legal requirements for children’s artistic activity in the country.Contribute to the dissemination of guidelines and good practices for the healthy use of electronic devices (…)Children, adolescents and screens, 03/2024

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Ministry of Education uses influencers occasionally, but recognizes emerging educational role

What a joy to welcome @Debora Aladim and present behind the scenes of Enem, an exam that she has worked and defended for so many years! Débora is one of our recipients of the National Order of Educational Merit. Congratulations!Camilo Santana, Minister of Education, 11/18/2025

The Ministry of Education’s initiatives involving influencers are still sparse and poorly organized, indicating that creators are not, for now, considered a structuring part of either educational policies or the Ministry’s institutional communication. However, the recent award of some influencers with the “National Order of Educational Merit” suggests a gradual opening by the Ministry to validate and incorporate creators as relevant pedagogical agents.

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Scattered actions reveal emerging fields, but also expose low presence

The initiatives grouped under “others” show how different bodies treat influencers in a specific manner and for different purposes. The inclusion of the digital influencer in the CBO formalizes state recognition of the occupation; AGU actions highlight legal responses, while events such as CRIA G20 and the Science Caravana mobilize creators in cultural, diplomatic and scientific agendas. In this context, the low expression of the Ministry of Culture and the Ministry of Science and Technology draws attention, indicating that the cultural and scientific sector may still impose barriers to the symbolic recognition of digital creators in these spheres

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and what do these actions reveal about the Executive’s speech about influencers?

To answer this question, we used the same methodology and semantic categories of discourse analysis that we used in the analysis of the Legislature.

We found that, behind the concrete actions, the Executive’s speech locates influencers as “popularity, reach and influence”, a instrumental use oriented towards campaigns, public communication and massive engagement.

The framing of these professionals as potential vectors of harm is also relevant, especially in matters of childhood and consumption.

It is also surprising that no action was identified within the field “Vulnerability and Precariousness” which, together with the very low presence of the “Commodification and

Economy of Influence” (1 entry), may indicate that the federal government still does not incorporate the socioeconomic dimension of the activity in its actions.

there are changes in the discourse between Bolsonaro and Lula, but it is not possible to establish causality

In the Bolsonaro government, creators appeared mostly as communication tools, while in the Lula government the discourse moves them to a more complex field, in which they are also regulated agents and subjects of

accountability. This contrast suggests discursive changes, but cannot be interpreted exclusively as an effect of the change in presidency, since the Lula government has twice as many incidents as the Bolsonaro government, and there has been a greater social presence of digital influencers in recent years, especially in a post-pandemic context.

Executive and Legislative branches converge by not valuing influencers as a profession nor recognizing their social function

In comparison with the findings of the Feed to Plenary study, we see that the Executive treats influencers especially as public policy communication and management tool, while the Legislature predominantly constructs them as moral problem and object of criminalization. Despite this difference – consistent with their constitutional roles – both powers share a gap: institutional recognition of influencers’ professional activity remains marginal.

The Executive turns to creators when it needs to communicate, but rarely recognizes them as subjects of law or recipients of policies

The predominance of actions aimed at public communication is natural and expected given the professional activity of digital creators, and It is interesting to see how the Executive has made positive progress by recognizing them as operational extensions of institutional campaigns and initiatives.

But this presence should not be confused with a recognition of the professional activity, the social function of these actors or their specific regulatory demands. Advertising use is, in most cases, functional and instrumental

– and does not necessarily point to the consolidation of

influencers as agents with rights, political voice or

structured participation in state decisions.

The substantive absence of specific normative frameworks, governance mechanisms, specific indicators, interministerial guidelines or coordinated policies reinforces that Brazil is still does not have regulatory, supervisory or institutional infrastructure sufficient to deal with the phenomenon, including to protect influencers from abuse by the very market structures to which they are linked.

The State sees influencers more through the prism of risk and accountability

An important part of the Executive’s set of actions occurs based on discursive and content categories associated with risk and enforcement, in which influencers appear as agents potentially involved in illicit practices, irregular advertising, tax fraud, dangerous conduct or risks to children and responsible consumption.

The absence of substantive initiatives in areas such as entrepreneurship, creative economy, culture, work policies or formalization shows that the Executive rarely builds influencers as a legitimate part of the economy, or even as a possible solution.

This does not necessarily reveal a conscious or deliberate choice on the part of public managers, but may reflect the still incipient regulatory stage surrounding the influence economy, A scenario that is also no exception to Brazil – many countries are still building their institutional responses to the growth of the influencer economy.

Absences also say a lot – and reveal strategic gaps

The cross-sectional analysis of the data shows that, while bodies such as Health and Justice consolidate the use of influencers, dozens of ministries and central departments did not present any structured action related to the topic in the period analyzed. Although not all areas of public administration have an immediate affinity with the sector, certain absences reveal strategic bottlenecks in the recognition of digital influence as an economic and cultural vector.

The invisibility of the topic in the Ministry of Entrepreneurship, Microenterprise and Small Businesses is particularly symptomatic. By not framing content creators from the perspective of microentrepreneurship, the Executive postpones fundamental agendas, such as the necessary coordination with IBGE to define a specific National Classification of Economic Activities (CNAE) for the category.

The absence of this formal recognition is not just a bureaucratic issue: the definition of a CNAE is the indispensable initial step to guarantee legal certainty in the tax sphere and,

crucially, to unlock the creation of public policies for fiscal incentives and development at federal, state and municipal levels.

Another significant vacuum is found in the Ministry of Communications: in addition to the expansion of physical infrastructure, the department could integrate influencers as strategic vectors in inclusion and digital literacy programs, using the capillarity of these actors to educate the newly connected population about the safe and civil use of the network.

Finally, draws attention to the discretion of the Ministry of Culture. Although the creative economy sector is central to the department and a few actions have been identified, the data indicates that public policies specifically designed to promote digital audiovisual native to social networks are still little explored, which may reveal how digital influencers are not yet fully understood as an integral part of the Brazilian cultural infrastructure.

Thousands of influencers play a key role in promoting regional and traditional cultures.

Eduinfluencers help with student learning experiences, motivation and engagement. Niche creators have helped increase perceptions of public trust with scientific information.

Even in light of this, the survey shows that positive framings – such as educational actor and soft power instrument – are still an exception in the Executive. And the absence of consistent policies in these fields reveals an institutional gap between the real strength of the phenomenon and the way the government incorporates it – and reveals a missed opportunity.

China, for example, has integrated fashion and lifestyle creators as part of itssoft powerr to reshape its global image and cultural influence, taking advantage of the viral dynamics of digital platforms. South Korea has transformed digital creators into components of its international policy, aligning influencers with cultural diplomacy, the entertainment industry and internationalization strategies.

Caution and planning are fundamental – as is the inclusion of digital creators as recipients of public policies

Despite its growing visibility and performance, it is necessary to recognize the limits of digital influence, thus avoiding exaggerated diagnoses or disproportionate expectations. The very heterogeneity of the sector – which includes everything from highly professional creators to actors associated with disinformation – reinforces that this diversity requires caution, criteria and governance. In this sense, it is necessary to recognize how several Executive initiatives have sought this advancement in a prudent manner, increasing transparency, adopting criteria and testing formats.

However, recognizing the structural limits of this sector does not mean accepting its precariousness as immutable data, nor reducing the debate to risk diagnoses. On the contrary:

precisely because the actions of influencers are volatile, heterogeneous and marked by strong asymmetries, it becomes even more necessary for the State to move beyond the instrumental use of these agents and start to include them as explicit recipients of public policies.

  • What do we seek to answer with this study? We investigated how the Executive Branch defines and operationalizes its governance over digital influencers, analyzing documents, campaigns, operations and guidelines produced between 2018 and 2025.
  • And what did we find? The Brazilian Executive mobilizes influencers mainly as functional instruments of public communication, at the same time that it frames them as potential vectors of risk and subjects of accountability. Positive recognition appears, but remains punctual and unstructured. And, across the board, there remains an absence of specific public policies aimed at the sector, indicating a State that is more reactive than strategic.
  • And why does this matter? The economy of influence already encompasses health, human rights, tourism, education, consumption and culture, but the recognition of male and female creators as subjects of rights and economic agents has not yet kept pace with this expansion. By mapping discursive and institutional patterns, this study offers a basis for discussing regulatory paths, capable of recognizing influencers such as workers, cultural agents and actors relevant to public policies.

Digital creators are no exception nor noise: are part of the social and cultural infrastructure, and sound public policy begins when we recognize this.

Based on the results and discussions of this work, as well as its methodological limitations, we highlight the following directions for new studies, which can continue to improve this research:

  • Interviews with public managers. Conducting semi-structured interviews with ministries’ communication and planning teams would allow understanding internal motivations, decision criteria and institutional barriers not visible in official documents.
  • Survey with influencers.Apply a national questionnaire with creators from different niches would help to capture perceptions about public policies, vulnerability levels, labor relations and regulatory expectations, also identifying regional barriers and the Executive’s actions at the state and municipal level.
  • International comparison. Mapping policies from other countries (South Korea, China, United Kingdom, USA, Argentina) would allow identifying stages of maturity, governance models and paths for Brazil.
  • Sector Case Studies. Developing in-depth investigations in areas such as health, education, tourism and consumer protection would allow us to observe how the use of influencers varies depending on the sector.
  • Mapping budget flows for influencer campaigns. Analyzing federal expenses involving influencers would make it possible to understand hiring patterns, sectoral distribution and selection criteria, allowing for the assessment of transparency, efficiency and strategic coherence.
  • Network analysis of interactions between the State and influencers. This approach would allow us to visualize how information, partnerships and agendas circulate – offering a structural diagnosis of the instrumental use of influencer marketing in public communication.

methodology annex

Methodology

Reglab research adheres to strict methodological standards to ensure objectivity and transparency. All data and findings are available for independent verification, reinforcing the credibility of our studies.

Collection and analysis took place from November 7th to 23rd, 2025, with double validation to reduce bias, and use of software to organize the results.

  • Bias Reduction Procedures

From Feed to Planalto: the Federal Executive and Digital Influencers

How does the Executive Branch define and operationalize its governance over digital influence and content creators?

This study analyzes how the Federal Executive Branch approaches digital influencers in administrative acts, official campaigns, guidelines and operations. enforcement. The methodology is qualitative, deductive and descriptive, based on documentary research in the Official Gazette of the Union and Portal Gov.br. Content analysis applied

descriptive coding, based on pre-established categories; discourse analysis used semantic categories previously defined in a previous study (Feed to the Plenary).

KARPPINEN, K; MOE, H. Texts as Data I: Document Analysis. In VAN DEN BULCK, H. et al. (eds.), The Palgrave Handbook of Methods for Media Policy Research. Palgrave Macmillan: London, 2019.

Data collection

Data collection was carried out through documentary research, on the website of Official Gazette of the Union and in Portal Gov.br. The collection covered all entries that satisfy the following conditions:

Methodological CaveatDuring the collection, the searches returned around 700 entries, many of them duplicated between keywords or replicated on different portals. Most of it dealt with news, indirect mentions or content that did not constitute direct state action. Therefore, we adopted criteria of relevance and materiality that, inevitably, involve analytical interpretation. To mitigate bias, a researcher reviewed all entries and her selection was validated by another researcher. In the face of any doubts, it was decided to keep the entry in the database. The materiality analysis was especially flexible due to the low number of results that exceeded this filter. Still, it is possible that government actions not published on Gov.br were not captured. For this reason, the sample, although methodologically robust for the purposes of this study, should not be understood as exhaustive.

  • Keywords: (i) “digital influencer”, “digital influencers”, “digital creator”, “digital creators”.
  • Responsible Body: Bodies of the Federal Executive Branch (direct public administration).
  • Temporal Range: January 1, 2018 to November 15, 2025;
  • Relevance Analysis:Does the document show the State acting on the issue (not merely describing it, as in news)?
  • Materiality Analysis: Does the document impose rules, allocate resources, create obligations or generate rights that directly or indirectly affect digital influencers?

Data analysis

Data evaluation was carried out in two parts: the first, using the content analysis, and the second, through the technique of discourse analysis.

  • Content analysis

The content analysis, with a descriptive approach, focused exclusively on the official text presented by the respective body (e.g. normative text, official statement, etc.), without analyzing possible intentions or motivations of the body, which allowed a more objective systematization, adapting to the purpose of the study.

The basic descriptive codes defined deductively were:

  • Date
  • Keyword
  • Responsible Body
  • Type of Action – Judicial or Administrative Actions, Normative Acts, Communication Campaigns, Official Announcement, Official Event, Manuals and Guides, Police and/or Enforcement Operation, Strategic Plans and Agendas, Awards

Data analysis

  • Influencers are…

The classification of “influencers are treated like…” used as

reference on slide 10 and the following, was carried out based on semantic coding at three levels, divided at the end as follows:

actions in which the Executive Branch mobilizes digital influencers as strategic extensions of its institutional communication, using them to expand reach, translate public policies, engage specific audiences or humanize government campaigns.

Inclusion Criteria: pparticipation of influencers in health campaigns,

education, human rights, tourism or social policies; official partnerships, invitations,

awards, campaigns and events in which influencers act as spokespersons;

creation of public communication material adapted to creators.

Exclusion Criteria: situations of regulatory or criminal liability (classify

as “subject of legal liability”); documents that deal only with

protective guidelines, without active use of the influencer (classify as “risk and object of

regulation”).

Situations in which the digital influencer is classified as a legal agent responsible for illicit or irregular conduct, being the target of investigations, fines, proceedings, administrative, civil or criminal punishments.

Inclusion Criteria: Police operations involving influencers; Actions of

enforcement (Federal Revenue, Ibama, PF); Legal proceedings brought by the Union (e.g.:

AGU asking for right of reply); Environmental, tax, criminal or

consumers aimed at creators.

Exclusion Criteria: General warnings that do not bind a specific case; Educational campaigns about risks (classify as “agent for public communication” or “risk and object of regulation”).

Actions that treat influencers as potential vectors of social, cultural, economic or rights protection risks — requiring guidance, containment, surveillance or state regulation.

Inclusion Criteria: Documents that mention risks to children, adolescence, health, human rights or digital security arising from the activity of

influencers; Guides, technical notes, alerts and regulatory guidelines; Campaigns combined with platforms (e.g., against scams) focused on mitigating damage.

Exclusion Criteria: Use of influencers for positive campaigns (classify as “agent for public communication”); Cases of concrete punishment (classify as “subject to legal liability”).

2.1 Data analysis

Cases in which influencers are recognized by the State as agents

pedagogical skills capable of supporting educational policies, forming social skills,

transmit literacy (financial, media, scientific) or promote learning

public.

Inclusion Criteria: Actions in which influencers integrate marketing strategies

media, financial, scientific or civic education; Invitations and initiatives in which creators are treated as educators or knowledge facilitators; Events or programs that associate creators with scientific dissemination.

Exclusion Criteria: Information-only campaigns with no pedagogical purpose

(classify as “agent for public communication”); Regulations on

misinformation or risks (classify as “risk and object of regulation”).

Situations in which influencers are incorporated by the Executive as agents of

international projection, cultural representation, country image or multilateral relations

— composing soft power strategies.

Inclusion Criteria: International events (e.g. G20, COP, multilateral meetings); Cultural promotion strategies, international tourism or national branding using influencers; Diplomatic actions that mobilize creators as representatives of the country or cultural amplifiers.

Exclusion Criteria: Domestic campaigns without interface with international projection; Events restricted to internal public communication.

Cases in which the Executive Branch recognizes digital influence as a relevant social phenomenon that demands institutional structuring, standardization,

registrations, official rankings, administrative procedures or formal regulatory mechanisms — even when there is no punishment or public communication involved.

Inclusion Criteria: Creation of registries, bases or official systems aimed at

influencers; Inclusion of influencer activity in classifications, internal regulations, notices or cultural policies (e.g. CBO, classifications, notice categories); State guidelines that organize the relationship between influencers and the State (e.g.: SECOM with formal guidelines); Occupational, tax, social security or cultural recognition through technical instruments.

Exclusion Criteria: Cases of legal liability (classify as “subject of legal liability”); Public communication actions (classify as

“agent for public communication”).

2. Data analysis

Discourse analysis

This study uses the perspective of Critical Discourse Analysis (ACD), a methodology that understands discourse as a social practice and examines the relationship between language and ideological constructions. The choice of this approach arises from the need to transcend the mere counting of propositions to investigate how the Executive constructs and disputes meanings about the figure of the digital influencer.

To enable a systematic and comparative interpretation, we grouped the codes into the same semantic dimensions (professionalization, popularity, commodification, vulnerability, social risk and criminalization) used in the study Feed tothe Plenary, which emerged from the qualitative analysis of around 153 different propositions. This method allows mapping the predominant discursive cores, their contradictions and absences, ensuring transparency in the transition from empirical data to critical interpretation.

ALI, C. Analyzing Talk and Text III: Discourse Analysis. In VAN DEN BULCK, H. et al. (eds.), The Palgrave Handbook of Methods for Media Policy Research. Palgrave Macmillan: London, 2019.

Bias reduction procedures

We recognize that all research, especially qualitative in nature, is subject to inherent biases and we seek, as best as possible, to exercise continuous reflexivity throughout the study, questioning possible influences from our own perspectives or understandings of the data. Furthermore, we adopted a series of measures to mitigate subjectivity in the interpretation and analysis of data:

  • Double Validation in Critical Stages

For the data analysis stages, a cross-validation process was adopted. Two researchers reviewed the selection of inputs and argument codings.

  • Registration and Transparency in the Coding Process

During the coding stage, we kept detailed records of all file versions, preserving history and allowing for more systematic review.

  • Adoption of Predefined Criteria

The criteria for classifying item 2.1 were previously established, based on theoretical references. These criteria were shared among researchers before the actual classification began, and adjusted only in cases where deductive classifications were notably insufficient.

Other information

Other methodological limitations

Interface Limitations: The structure of official websites may impact the availability or visibility of documents throughout the analyzed period. Sometimes results were repeated when browsing between results pages. No manual counting of the number of resulting entries was performed.

Actions not implemented: The study analyzes published documents, not their execution. The presence of a normative act does not guarantee that the action

corresponding has been implemented.

Personal data protection

This research did not directly involve the processing of personal data. The documents used consisted exclusively of bills,

available on the Brazilian legislative websites.

SOFTWARE USE IN RESEARCH
MS Office Suite editing text, spreadsheets and graphics
Chat9PT 4th brainstorm, information systematization, data structuring, graphics editing, organization of pre-textual elements, ABNT review, adaptation to the Reglab Writing Manual.
Notion text editing, data and file organization, graphics editing
Perplexity additional search for sources and reduction of bias.
Wordclouds creating word clouds

Ethical Guidelines

This research was funded by YouTube Brasil Ltda. To ensure the integrity of this work, the authors developed, conducted and analyzed the study independently, without any contribution or interference from the company, which also did not influence or interfere in the interpretation of the results. The authors maintain full professional independence and responsibility for the content and conclusions of this work.

Respect for Privacy and Confidentiality: The data used is in the public domain and was obtained from
accessible sources, without violating the privacy or confidentiality of any individual or institution.
Responsible Use of Public Data: Although the data analyzed is public, its use was made in a responsible and ethical manner, with the sole purpose of independent research.
Methodological Transparency: The research methodology was detailed to ensure transparency and replicability, contributing to scientific integrity and allowing the results to be validated independently.
Non-discrimination and Respect for Diversity: The research was conducted in a way that respects diversity and avoids any form of discrimination.