Submission to the ANPD’s Call for Contributions on the Draft Guidance Document for the Digital ECA
June 2026
In June 2026, the Working Group on Gaming and Regulation submitted comments to Brazil’s National Data Protection Authority (ANPD) in response to its Call for Contributions on the Draft Guidance Document for the Digital ECA (Law No. 15,211/2025). The submission addresses how the law’s scope should apply to providers of information technology products and services, including online games with social features, and offers recommendations for clarifying the “likely access” criterion that determines which services fall under the law’s protections for children. It also raises a set of additional questions for ANPD guidance, including the treatment of randomized reward mechanisms and parental consent requirements for social interaction in games.
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