Digital ECA in Effect: What Changes for Technology Companies

On March 17, 2026, Law No. 15,211/2025, known as the Digital ECA, came into effect, regulating the protection of the rights of children and adolescents in the digital environment. The new legislation establishes relevant obligations for companies that offer digital products or services intended for or likely to be accessed by children and adolescents.

Who is subject to the rules of the Digital ECA?

Among the main regulated entities are:

•    App stores
•    Video games and gaming platforms
•    Social media
•    Video platforms

What are the main obligations set forth?

The Digital ECA imposes a series of obligations on regulated entities, including:

•    Adoption of reliable age verification mechanisms
•    Implementation of parental control tools
•    Providing accessible and effective reporting channels
•    Prohibition of the use of loot boxes targeted at children and adolescents
•    Adoption of measures to prevent excessive or compulsive use of digital products and services
•    Prohibition of profiling practices targeting children and adolescents

What are the risks of non-compliance?

Failure to comply with the requirements of the Digital ECA may result in administrative, civil, and criminal penalties, including:

•    Formal warnings.
•    Fines of up to 10% of revenue or up to R$ 50 million per violation.
•    Temporary suspension of activities.
•    Prohibition from conducting certain operations.

Recent regulatory updates

Following the law’s entry into force, regulations and guidelines detailing its practical application were published:

Decree No. 12,880/2026

Establishes, in a clearer and more practical manner, the obligations already present in the Digital ECA.

Preliminary Guidelines “Reliable Age Verification Mechanisms”

Document published by the ANPD on March 20, 2026, to provide regulated entities with preliminary guidance on reliable age verification mechanisms.

Decision Order CD/ANPD No. 35/2026

Schedule defining the implementation and enforcement phases for age verification solutions.

Recommendations

The Digital ECA ushers in a new way for companies to operate in the digital environment, reaffirming the comprehensive and priority protection of children and adolescents. Thus, the market must adapt to its requirements, making this the time to establish risk mitigation measures and review existing practices.

The goal is to immediately begin implementing measures that demonstrate diligence in seeking compliance with the law and combating violations, even before the end of each phase of the timeline. This is because, with the law already in effect, the early adoption of measures helps provide greater legal certainty for the company, especially in the face of potential inquiries from authorities.

Lobo de Rizzo’s Intellectual Property, Technology and Data Protection team is available to advise clients on adapting to the new requirements of the Digital ECA.