On August 11, 2026, Brazil's National Data Protection Authority (ANPD) published Despacho Decisório CD/ANPD n. 122/2026 in the Diário Oficial da União, confirming that digital platforms with more than one million under-18 users must publish their first ECA Digital transparency report by September 17, 2026. The date marks one year since Lei 15.211/2025, the Digital Statute for Children and Adolescents (ECA Digital), was signed, and it activates the Article 31 reporting duty that has sat in the law since it entered into force on March 17, 2026.
The obligation binds internet application providers directed at children and adolescents or likely to be accessed by them. In practice it reaches Meta, Google and YouTube, TikTok, Discord, Snap, Roblox, Kwai and any peer service with a large minor user base in Brazil. The first report must be published on the platform's own website as a public accountability document, with optional filing to [email protected].
Who has to publish the first report, and by when?
Article 31 of ECA Digital makes publication mandatory for providers with more than one million registered users under 18. The ANPD despacho clarifies that the deadline runs to the law's first anniversary, so the first report is due on September 17, 2026, roughly 37 days from the clarification.
The first report must cover the period from January 1 to June 30, 2026. Platforms that do not yet hold systematized data for January and February may limit the initial report to March 17 to June 30, 2026, because the law only entered into force on March 17. In both cases the publication deadline remains September 17, 2026.
What must the transparency report contain?
Under Article 31, each report must disclose the complaint channels and the systems and processes for investigating them; the number of notifications received, broken down by category, and the actions taken; the volume of content and account moderation; measures to identify illicit acts and child accounts on social networks; technical improvements for the data protection and privacy of children and adolescents; and the measures used to secure parental consent.
The document must also detail the methods applied and present the results of impact assessments and of the identification and management of risks to the safety and health of this audience. The detail load is significant: trust and safety teams need moderation, age-assurance and parental-consent metrics that hold up under the ANPD's enforcement lens, not a marketing transparency note.
What is the reporting calendar going forward?
After the first report, the cadence aligns with civil semesters. The second report covers July 1 to December 31, 2026 and is due by February 1, 2027. From 2027 onward, the first-semester report is due by August 1 and the second-semester report by February 1 of the following year.
| Report | Reference period | Publication deadline |
|---|---|---|
| First report | January 1 to June 30, 2026 (or March 17 to June 30, 2026) | September 17, 2026 |
| Second report 2026 | July 1 to December 31, 2026 | February 1, 2027 |
| First semester, 2027 onward | January 1 to June 30 | August 1 of the same year |
| Second semester, onward | July 1 to December 31 | February 1 of the following year |
This first deadline lands before the ECA Digital enforcement and sanctions phase, which ANPD Technical Note 2/2026 schedules for January 2027. A missed Article 31 publication now becomes evidence the regulator can weigh when that sanctions regime opens, where fines can reach BRL 50 million or 10 percent of Brazil revenue.
What should compliance teams do now?
- Confirm whether the platform crosses the one million under-18 user threshold in Brazil, and document the methodology used to count minors.
- Pull moderation, notification, age-identification and parental-consent metrics for the January 1 to June 30, 2026 window (or March 17 to June 30 where January and February data is not systematized).
- Draft the Article 31 disclosures, including impact assessment and risk management results, and stand up the public-facing publication page on the platform's site.
- File the report to [email protected] by September 17, 2026, and lock in the February 1, 2027 slot for the second-semester report.
Take advantage of this real-time watch
Verify applicability against your Brazilian user base, brief trust and safety and legal on the September 17 deadline, and prepare the February 1, 2027 follow-up. Continuous, per-jurisdiction real-time monitoring surfaces this kind of anniversary-driven change the moment a regulator clarifies it, which is how Obsidian keeps the ECA Digital file current between milestones.
