Article 31 of Law No. 15.211/2025 is one of the operationally heaviest obligations of ECA Digital. It creates the duty for platforms to produce, semiannually and in Portuguese, public transparency reports on their practices of protecting children and adolescents in the digital environment.
Who is obliged
The obligation reaches platforms with more than one million child and adolescent users in Brazil. This threshold does not exempt smaller platforms from other ECA Digital obligations — it only defines who produces the formal semiannual report. Platforms close to the threshold should maintain equivalent documentation, since audience growth can trigger the obligation at any moment.
The count considers effectively active users on the platform in Brazil, not occasional visitors. The counting methodology must also be reported — part of the required transparency is about how the company itself measures its audience.
Language and format
The report must be published in Brazilian Portuguese, with clarity accessible to a lay audience, and made available on a public channel — typically a dedicated page on the platform's institutional site. Automatic translations of global reports do not meet the obligation: the text must reflect the Brazilian regulatory context.
Periodicity is semiannual, with cut-off dates defined by regulation. Delays, omissions, or superficial reports are subject to administrative sanction.
Expected content
The report must inform, at a minimum: number of child and adolescent accounts on the platform; age verification policies and results of their application; volume of notices and complaints received relating to minors; moderation actions executed; incidents reported to authorities; and changes in algorithms, policies, and products with impact on the children's audience.
The operational production of the report requires coordination between global teams and legal presence in Brazil — learn about our compliance support.
Risks of inadequate reports
Generic, superficial, or context-free translated reports expose the platform to three risks: direct administrative sanction for formal non-compliance, reputational escalation in press and advocacy coverage, and use of the report itself as evidence against the company in subsequent judicial proceedings.
Best practice is to treat the transparency report as an institutional piece — built with legal rigor and coordinated by those who understand the Brazilian regulatory framework.