Data Protection Atlas

Brazil

Tier 2 Comprehensive law Americas

Principal framework: LGPD (2018). Regulator: ANPD. Mutual EU adequacy announced 27 Jan 2026 — the newest adequacy partner. The ANPD has an active regulatory agenda (transfers 2024, breach rules, AI overlap).

At a glance

Principal law
LGPD
Regulator
ANPD
Breach notification
3 working days to the ANPD (Resolution 15/2024) and affected subjects
Maximum penalty
Up to 2% of Brazil revenue, capped R$50m per infraction
DPO required
Encarregado required as a rule; flexibility for small processors
Digital consent age
Parental consent for children under 12; best-interests rule for adolescents
Extraterritorial reach
Yes — offering goods or services in Brazil

Structure

Structural pattern
Not assessed
Sub-jurisdictions
None — no sub-national axis
ISO code
BR

A Pattern 4 jurisdiction has no sub-national layer to model. Devolution elsewhere in the legal system does not imply it here — check each Act rather than reasoning from the country.

Transfers and adequacy

EU member
No
EEA member
No
Holds EU adequacy
Yes
Granted
26 January 2026
Review
4-year periodic review

GDPR Art.45; mutual adequacy announced 27 Jan 2026. CORRECTION: Brazil now HOLDS adequacy (previously did not).

Instruments

How the concepts differ here

The governance concepts are written from a GDPR-family default. These are the recorded departures for this jurisdiction, including those inherited from its legal family. An absent entry means nobody has checked, not that the position matches the default.

Concept How it differs Position here Scope
Choosing and documenting a lawful basis Works differently Ten legal bases rather than six, including credit protection and health protection as free-standing grounds. This jurisdiction
The rights, and how they interact Additional requirement Includes a right to information about public and private entities with which the controller has shared data, and an explicit right to review of automated decisions. This jurisdiction

Sources

Never independently verified — seeded from the prototype.