The Global Network Initiative (GNI) has submitted a statement to Brazil’s National Data Protection Agency (ANPD) in response to its preliminary Orientative Guide on Age Assurance Mechanisms, published in May 2026. The Guide translates obligations under Law No. 15,211/2025, the Digital Statute for Children and Adolescents (ECA Digital), and Decree No. 12.880 into operational detail.
In the submissionGNI emphasised that protecting children and adolescents online is an important aim, but that measures pursuing it must be clearly defined, carefully crafted, and proportionate, in line with international human rights law, to ensure the privacy and freedom of expression of all individuals, including adults. GNI commends ANPD for grounding the Guide in proportionality, necessity, and data minimization – including its preference for verifiable credentials and its prohibition on secondary use and traceability of assurance data.
At the same time, GNI’s submission identifies gaps in the treatment of adult impact, scope, biometric defaults, accuracy safeguards, data retention, and centralization risk that leave room for the Guide’s strong underlying principles to be undermined in implementation. Among its recommendations, GNI encourages ANPD to treat impact on adult users as a standalone factor in the proportionality assessment, state explicitly that biometric methods are a last resort rather than a default, require at least one assurance pathway accessible without a smartphone camera, broadband connectivity, or an official identity document, and guard against age assurance systems evolving into broader identity infrastructure.
GNI is keen to engage further with ANPD throughout this consultation and welcomes opportunities to share its multistakeholder perspective in support of a rights-respecting final Guide.
The Global Network Initiative is the preeminent multistakeholder organization dedicated to advancing freedom of expression and privacy in the ICT sector, bringing together leading companies, civil society organizations, academics, and investors around a shared framework grounded in the UN Guiding Principles on Business and Human Rights and international human rights law.