ECA Digital is not a decorative rule. Law No. 15.211/2025 establishes a robust sanctions regime designed to force global platforms to take Brazilian regulation seriously. Understanding the applicable sanctions is the first step to calculating the real cost of non-compliance.
Fines of up to 10% of revenue
The most visible sanction is the administrative fine, which can reach 10% of the group's revenue in Brazil, capped at BRL 50 million per infraction. For companies with material local revenue, this cap is quickly reached; for global groups, the calculation base can include indirect revenue attributed to the Brazilian market.
The fine applies per infraction — multiple violations generate independent enforcement actions. In practice, a platform simultaneously breaching representation, transparency, and notice-response obligations can accumulate sanctions in parallel.
Suspension and prohibition of activities
Beyond fines, authorities can order the temporary suspension of platform activities in Brazil or, in serious cases, prohibition of operation. This sanction is especially sensitive for platforms whose revenue depends on the Brazilian market — interruption can be financially devastating and generates immediate reputational impact.
Suspension can be enforced by administrative decision (app blocking, store removal) or judicial order (blocking through internet access providers). Brazilian authorities have already shown, in prior cases, willingness to use these tools.
Executive liability
A dimension frequently underestimated by foreign companies is the personal liability of executives for non-compliance with Brazilian judicial orders. Directors and legal representatives can be personally targeted, with implications ranging from personal fines to travel restrictions and professional reputation damage.
Having a formally constituted legal representative mitigates this risk — see how we structure this protection.
Total cost of non-compliance
The rational calculation is simple. The cost of structuring legal representation, formal headquarters, and notice channel is substantially lower than the combined risk of fines, operational suspension, legal costs of defending Brazilian administrative and judicial proceedings, and reputational damage affecting global partnerships.
For platforms with any material revenue in Brazil, non-compliance is no longer a saving — it is a liability under construction.