This Thursday, April 30, the Brazilian Data Protection Agency (ANPD) launched a Call for Contributions regarding the draft Guidelines on IT Products and Service Providers: scope and general obligations under the ECA Digital. The call will remain open until June 15.

The initiative is part of the regulatory agenda for the implementation of Statute #15,211/2025 (the Digital ECA), which establishes a comprehensive framework for the protection of children and adolescents in the digital environment and appoints the ANPD as the competent authority to issue complementary guidelines and oversee enforcement.

The draft Guideline aims to clarify core concepts and legal definitions that define the scope of application of the Digital ECA, with a particular focus on identifying which entities qualify as “providers of information technology products or services” subject to the statute.

Key concepts analyzed and discussed in the draft include:

• Providers of IT products or services targeted at or likely to be accessed by children and adolescents;
• Social media networks;
• Internet application stores;
• Operating systems; and
• Service providers with editorial control.

By delineating these concepts, the Guidelines seek to enhance legal certainty, predictability, and consistency in the interpretation and enforcement of the Digital ECA.

The purpose of the Call for Contributions is to collect inputs from society regarding the draft Guidelines, including requests for clarification and the necessity of further guidance. This consultation represents an important opportunity for digital platforms to anticipate enforcement expectations and participate in the regulatory interpretation of critical points of the Digital ECA. Interested parties may submit contributions until June 15.

Our team is closely monitoring the regulatory developments related to the Digital ECA and is available to assist companies in assessing the impacts of the draft Guideline, preparing contributions to the consultation, and designing compliance strategies. Should you have any questions or require assistance, please contact us at info@lickslegal.com.