ANPD Prioritizes Children’s Data, AI, and Digital Governance

Published: December 24, 2025

Brazil’s National Data Protection Authority (ANPD) has taken a major step toward regulatory transparency and enforcement predictability by publishing two cornerstone instruments that will guide data protection policy and supervision over the next several years: the Priority Topics Map for Supervision (2026–2027) and the updated Regulatory Agenda for 2025–2026. These documents lay out the themes that will shape rulemaking, guidance, and enforcement actions under the Brazilian General Data Protection Law (LGPD) and the Digital Statute of Children and Adolescents (ECA Digital). 

The official list of ANPD resolutions, confirming the approval of the Priority Topics Map for the 2026–2027 biennium (via Resolution CD/ANPD No. 30, dated December 23, 2025), is available on the ANPD’s regulatory database: ANPD Regulatory Resolutions: Mapa de Temas Prioritários 2026–2027 & Agenda Regulatória 2025–2026.

A Coordinated Regulatory and Enforcement Strategy

By publishing both instruments jointly, the ANPD is emphasizing a synchronized approach to regulation, guidance, supervision, and sanctions. This is particularly important as Brazil implements the recent changes introduced by the ECA Digital, which expands protections for children and adolescents in the digital environment.

Key issues—such as age verification mechanisms for minors—will be first addressed through guidance and stakeholder engagement, with supervisory and sanctioning activities to follow once the regulatory framework is fully established. 

Priority Topics for Enforcement (2026–2027)

The Priority Topics Map sets out four major areas that will guide ANPD’s supervisory focus:

1. Data Subject Rights – Ensuring transparency and enforceability of rights such as access, correction, deletion, and portability.
2. Protection of Children and Adolescents in the Digital Environment – Aligning supervisory priorities with the ECA Digital framework to safeguard younger internet users.
3. Processing of Personal Data by the Public Sector – Scrutiny of government data sharing and processing practices.
4. Artificial Intelligence and Emerging Technologies – Oversight of algorithmic systems and automated decision-making that involve personal data.

These priorities derive from extensive analysis of incident reports, complaints, and compliance data collected by the ANPD’s supervisory teams. 

Enforcement Focus Areas

The ANPD has outlined several concrete supervisory actions aimed at reinforcing compliance:

• Monitoring secondary use of personal data for targeted advertising
• Assessing adoption of privacy by design and privacy by default principles
• Evaluating technical and organizational safeguards to prevent minors’ exposure to harmful or illegal content

Supervisory activities will incorporate monitoring, guidance, and preventive measures, with enforcement timelines adjusted to respect necessary rulemaking processes linked to Law No. 15,211/2025. 

Updated Regulatory Agenda for 2025–2026

The Regulatory Agenda has been expanded with themes that reflect emerging priorities related to the ECA Digital:

• Age-Verification Mechanisms
• Scope and Obligations of IT and Technology Service Providers under the ECA Digital
• Revision of Enforcement and Sanction Rules (including updates to ANPD Resolutions No. 1/2021 and 4/2023)

Additionally, the agenda includes enhancements to the ANPD’s procedural framework, such as improved rules for inspections, sanctions, stakeholder participation, and Regulatory Impact Assessments (RIA). 

Implications for the Market and Compliance

For organizations operating in Brazil—or planning to enter the Brazilian market—the ANPD’s latest publications signal a shift from high-level principles to concrete, enforceable compliance expectations. Entities in sectors such as AI, AdTech, EdTech, HealthTech, GovTech, and analytics platforms should reassess their data governance models to ensure alignment with these newly prioritized regulatory themes.

Final Takeaway

The simultaneous publication of the Priority Topics Map for 2026–2027 and the updated Regulatory Agenda for 2025–2026 reinforces Brazil’s progression toward a mature and transparent data protection regime. By clarifying enforcement priorities and regulatory milestones well before they take effect, the ANPD is enabling proactive compliance and strategic planning across industries.

For the official list of resolutions validating these updates, see the ANPD’s regulatory repository here: ANPD Regulatory Resolutions: Mapa de Temas Prioritários 2026–2027 & Agenda Regulatória 2025–2026.