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Brazil's ANPD Is Coming for App Stores: What You Need to Know About the New Child Data Rules

NakedPact Editorial Committee
Reviewer: Carmelo G.
Comitato Editoriale NakedPact
July 3, 2026
10 min read
Brazil's ANPD Is Coming for App Stores: What You Need to Know About the New Child Data Rules

What Is the ANPD Monitoring and Why Should You Care?

The Brazilian National Data Protection Authority (ANPD) has launched a monitoring initiative to check whether app stores and operating systems comply with the Digital ECA (Estatuto da Criança e do Adolescente). This law imposes strict data protection obligations for minors. If your app or platform is accessible to children in Brazil, you need to pay attention.

The Digital ECA requires app stores and OS providers to implement measures that protect children's data, such as age verification, parental consent mechanisms, and restrictions on data collection. Non-compliance can lead to fines and operational bans in Brazil.

Who Is Affected?

This isn't just about Brazilian companies. Any global app store (Google Play, Apple App Store) or operating system (Android, iOS) that operates in Brazil must comply. If you distribute apps through these stores, you're indirectly affected because the stores may impose new requirements on developers.

What Are the New Obligations?

  • Age Verification: App stores must verify the age of users before allowing downloads of apps that collect personal data.
  • Parental Consent: For users under 18, explicit parental consent is required for data processing.
  • Data Minimization: Only data necessary for the app's functionality can be collected from minors.
  • Transparency: Clear privacy notices tailored to children's understanding.

What Should Companies Do Now?

First, audit your app's data collection practices. If you target children, implement robust age verification and parental consent flows. Second, review your app store listings to ensure compliance with their updated policies. Finally, consult Brazilian legal counsel to align with the ANPD's expectations.

Think of it like this: complying with the Digital ECA is like cleaning your room before your mom checks – it's annoying, but way better than the alternative. The ANPD has teeth, and they're not afraid to bite.

FAQ

Does the Digital ECA apply to apps that don't target children?

Yes, if your app is likely to be accessed by minors (e.g., social media, games, educational tools), you must comply. The ANPD considers actual usage, not just intended audience.

What are the penalties for non-compliance?

Fines can reach up to 2% of the company's revenue in Brazil (capped at R$50 million per violation), plus potential suspension of app distribution.

How can I implement age verification without collecting too much data?

Use third-party age estimation services that don't store personal data, or rely on self-declaration with parental confirmation for younger users.

Your Compliance Checklist

  • Audit data collection practices
  • Implement age verification
  • Set up parental consent flow
  • Update privacy policy for minors
  • Review app store compliance requirements
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NakedPact Editorial Committee

Article created by the NakedPact editorial team. Our mission is to analyze, simplify, and expose unfair terms and hidden risks in everyday contracts to protect citizens and consumers.

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