Regulatory adaptation is a project, not a single decision. This checklist gathers the essential steps for an international platform to fulfill its obligations under ECA Digital and the Brazilian legal representation framework, ordered by criticality and natural implementation sequence.
1. Regulatory diagnosis
The first step is to understand exactly which obligations apply to your platform. That involves analyzing the type of service provided, the audience effectively reached in Brazil, the monetization model, the volume of child and adolescent users, and current moderation, advertising, and age-verification policies.
- Mapping of applicable obligations under Law No. 15.211/2025
- Applicability of Decrees No. 12.880/2026 and No. 12.975/2026
- Estimate of exposure to fines and sanctions
- Identification of gaps between current policies and Brazilian requirements
2. Legal representative and headquarters
With the diagnosis in hand, the structural step is to formalize legal representation — a legal entity based in Brazil, with sufficient powers to answer to every obligation of Article 40 of Law No. 15.211/2025 and Decree No. 12.975/2026. Without this foundation, the other controls do not sustain institutional accountability.
This is usually where the platform engages a specialized partner — see how we structure the formalization of representation.
3. Notice and response channel
Structure a formal flow to receive, triage, and respond to subpoenas, notices, and judicial orders, with clear regulatory deadlines and defined owners. A dedicated Brazilian email address (for example, displayed on the site and app) and an internal escalation process are minimum elements.
4. Reports, policies, and transparency
Platforms reached by Article 31 must produce semiannual reports in Portuguese. Every platform must maintain public policies on moderation, age verification, advertising to minors, parental controls, and complaint channels. These pieces must be produced or reviewed by those who know Brazilian regulation, not simply translated.
- Age verification and parental controls policy
- Moderation and complaint-response policy
- Policy on advertising directed at minors
- Semiannual transparency report (where applicable)
- Public complaint channel accessible from Brazil
5. Internal governance and cooperation
Establish internal responsibilities inside the group for Brazilian compliance: an executive focal point, a legal contact, and an operational owner for the notice channel. Document decisions and keep an audit trail — in administrative or judicial matters, that documentation is decisive.
Compliance is iterative: reassess the checklist every six months and whenever material product, audience, or regulatory changes occur.