News

ANPD sets deadline for the first semiannual transparency report under the ECA Digital

The Board of Directors of the Brazilian Data Protection Authority (ANPD) published Decision Order CD/ANPD No. 122/2026, regarding the obligation to publish semiannual transparency reports under Article 31 of Law No. 15,211/2025, known as the ECA Digital. The decision organizes the initial compliance with this obligation while no specific ANPD regulation on the matter has been issued.

 

The obligation applies to internet application providers directed to children and adolescents, or likely to be accessed by this audience, provided that they have more than 1 million registered users in this age group with internet access in Brazil.

 

The first semiannual report must be published by September 17, 2026, generally covering the period from January 1 to June 30, 2026. Exceptionally, if data for January and February is not available, the report may be limited to the period from March 17 to June 30, 2026. As of the second report, the reporting cycle will follow the calendar semesters, with publication due by August 1 for the first semester and by February 1 for the second semester.

 

Until specific regulation is issued, the report must be consolidated into a single document and include, at a minimum, the following information:

 

• channels available to receive reports and the respective review processes;
• number of reports received;
• number of content or account moderation actions, by type;
• measures adopted to identify child accounts on social media and unlawful acts;
• technical improvements aimed at protecting children’s and adolescents’ personal data and privacy;
• technical improvements to verify parental consent, as provided under the LGPD;
• details of the methods used and presentation of the results of impact assessments, identification and management of risks to the safety and health of children and adolescents;
• number of notices received, by category;
• proportional data on the follow-up given to the notices received.

 

The ANPD also recommended that obligated agents send a copy of the semiannual report, upon publication, to the email address monitoramento@anpd.gov.br , without prejudice to publication on the provider’s website.

 

From an operational perspective, the decision reinforces the need for a prior regulatory scoping assessment. Before preparing the report, companies should verify whether the service is subject to the obligation, whether it is likely to be accessed by children and adolescents, whether the user threshold is met, and what information is available to compose the first transparency cycle.

 

For covered agents, the September 17, 2026 deadline becomes the main internal organization milestone. Preparing the report will likely require coordination among the teams responsible for the relevant topics, especially in consolidating data on reports, moderation, parental consent, data protection and risk management involving children and adolescents.