Skip to content
BR LGPD · BR-ECA-DIGITAL-DESIGN-OBLIGATIONS

BR LGPD ECA Digital Art. 7 and Art. 18 §2 - protective defaults and non-manipulative interfaces

Use protective privacy defaults and prevent interfaces that compromise autonomy or safeguards

CRITICALRequirementDesign defaultsBinding regulationIn forceApplies from 17 March 2026

Where this comes from

Provision: ECA Digital Art. 7 and Art. 18 §2 - protective defaults and non-manipulative interfaces

Instrument: Estatuto Digital da Criança e do Adolescente (Lei nº 15.211/2025)

Citation: Lei nº 15.211/2025, Art. 7; Art. 18 §2; Decreto 12.880/2026 Art. 10; Art. 41-A (Lei nº 15.352/2026); Lei 15.211/2025 Art. 39 caput and §§1-3

Text version: Lei nº 15.211, de 17 de setembro de 2025, compiled text; Art. 41-A inserted by Lei nº 15.352/2026; Decreto nº 12.880/2026

Checked against the source: 6 September 2026

Read the official text ↗

Who it applies to

It applies when all of these are true:

  • Brazil ECA Digital assessed fact Q_BR_ECA_CHILD_ACCESS: YES

What engineering work it implies

Sample acceptance criteria Landfall generates for this obligation:

  • Assess Lei 15.211/2025 Article 39's service-specific modulation and conditional dispensation. Record the exact eligible editorial-control or previously licensed-content provider class and every cumulative §1 condition: applicable classification rules (or required alternative age adequacy and harmful-content signalling), transparent age classification, accessible parental mediation restricting age-based content, personal data processed, interaction with other users and commercial transactions, and accessible reporting channels for misclassified or rights-violating content. A generic service label, a single safeguard or an asserted exemption is insufficient. Do not extend relief beyond the listed provisions, actual provider/service scope and established conditions. Record qualified review of current implementing criteria; synthetic checks and minimized records must preserve replacement safeguards and unresolved gaps.
  • Record the assessed Brazilian child/adolescent scope and actual Lei 15.211/2025 Art. 7, Art. 18 §2 and Decreto 12.880/2026 Art. 10 requirements.
  • Use the most protective available privacy and personal-data defaults from conception, considering progressive autonomy and development and recording the justified best-interest assessment.
  • Provide clear, accessible and age-appropriate information for informed choices about less protective settings; assess the lawfulness of each such choice separately.
  • Identify and redesign interfaces that compromise autonomy, decisions or choice, including obstruction, cognitive-vulnerability exploitation and obstacles to privacy, supervision, consent or revocation controls.

Evidence an auditor expects

  • Assessment documentDocument review

    ECA Digital scoped safeguards and conditional Article 39 assessment

    Assess Lei 15.211/2025 Article 39's service-specific modulation and conditional dispensation. Record the exact eligible editorial-control or previously licensed-content provider class and every cumulative §1 condition: applicable classification rules (or required alternative age adequacy and harmful-content signalling), transparent age classification, accessible parental mediation restricting age-based content, personal data processed, interaction with other users and commercial transactions, and accessible reporting channels for misclassified or rights-violating content. A generic service label, a single safeguard or an asserted exemption is insufficient. Do not extend relief beyond the listed provisions, actual provider/service scope and established conditions. Record qualified review of current implementing criteria; synthetic checks and minimized records must preserve replacement safeguards and unresolved gaps. Record the assessed Brazilian child/adolescent scope and actual Lei 15.211/2025 Art. 7, Art. 18 §2 and Decreto 12.880/2026 Art. 10 requirements. Use the most protective available privacy and personal-data defaults from conception, considering progressive autonomy and development and recording the justified best-interest assessment. Provide clear, accessible and age-appropriate information for informed choices about less protective settings; assess the lawfulness of each such choice separately. Identify and redesign interfaces that compromise autonomy, decisions or choice, including obstruction, cognitive-vulnerability exploitation and obstacles to privacy, supervision, consent or revocation controls. Use synthetic journeys and proportionate assessment methods to verify usable protective choices; retain necessary configuration/test evidence and unresolved gaps without default child-level behavioral histories.

Questions people ask

Does BR LGPD ECA Digital Art. 7 and Art. 18 §2 - protective defaults and non-manip… apply to my service?
It applies when Brazil ECA Digital assessed fact Q_BR_ECA_CHILD_ACCESS: YES.
From when does this apply?
BR LGPD ECA Digital Art. 7 and Art. 18 §2 - protective defaults and non-manip… applies from 17 March 2026. Its current status is: in force.
What evidence does an auditor expect?
ECA Digital scoped safeguards and conditional Article 39 assessment.

Find out whether this one lands on you

Landfall's pre-scan answers the applicability question above for your product in minutes, then turns every obligation that applies into traceable engineering tickets with a citation chain your auditors can follow.

Not legal advice. Landfall maps regulatory obligations to engineering work for planning purposes. Its verdicts are not legal advice and create no attorney-client relationship — verify with qualified counsel before relying on them.

What Landfall Is NOT

Critical Boundaries

Understanding these boundaries is essential before using this product. Misuse of this tool for purposes outside its scope may create legal, regulatory, or commercial risk for your organization.

NOT Legal Advice

This product does not provide legal advice and does not create an attorney-client relationship.

Interpretations are informational analysis, not legal counsel. Always consult qualified legal professionals for compliance decisions.

NOT a Risk Score

We do not quantify, calculate, or certify your compliance risk level.

No numerical risk rating, compliance percentage, or safety score. Risk assessment requires human judgment about your specific context.

NOT Runtime Enforcement

This is a planning and mapping tool, not a runtime enforcement system.

Does not integrate with your production systems. Does not block, filter, or enforce compliance in real-time. Implementation is your responsibility.

NOT Regulatory Approval

Using this tool does not mean you are compliant with any regulation.

No certification, seal of approval, or compliance guarantee. Regulators will evaluate your actual implementation, not your use of this tool.

NOT Authoritative Interpretation

Our interpretations are not binding and may differ from regulatory guidance.

Only regulators and courts provide authoritative interpretation. Our analysis reflects our reading of requirements, which may be incomplete or incorrect.

NOT a Safe Harbor

This tool does not shield you from enforcement actions or liability.

Documentation of your process is valuable, but does not constitute a legal defense. Compliance is ultimately your organization's responsibility.

NOT an AI Compliance Agent

AI features assist analysis but do not make compliance decisions for you.

AI-generated interpretations require human review and approval. Automated suggestions are starting points, not final answers.

NOT Complete Coverage

We do not cover all regulations, all obligations, or all jurisdictions.

Regulatory landscape is vast and evolving. Gaps in our coverage do not mean those requirements don't apply to you.

What This Tool IS:

  • A structured workflow for mapping regulatory requirements to implementation tasks
  • A documentation system for compliance decisions (audit trail)
  • A collaboration platform for compliance, legal, and engineering teams
  • An informational resource for understanding regulatory obligations