Key information
The Electronic Frontier Foundation (EFF) is actively engaging with Brazil’s National Data Protection Agency (ANPD) to shape the enforcement of new digital platform regulations. Throughout this year, the organization has submitted comments and held meetings to advocate for guardrails that protect fundamental rights, specifically regarding Law n. 15.211/2025.
The EFF warns that mandatory age assurance mechanisms, while intended to protect minors, pose significant privacy and free expression risks. The organization argues that current verification technologies are often inaccurate and invasive, potentially leading to overbroad site blocking. They urge the ANPD to avoid blanket requirements, suggesting instead that restrictions should be narrowly tailored to services unsuitable for children.
Regarding technical implementation, the EFF asserts that zero-knowledge proofs are insufficient for user privacy. They recommend incorporating additional safeguards like selective disclosure, unlinkability, and on-device processing to prevent data collusion. Furthermore, the organization emphasizes that regulations must clearly distinguish between major platforms and smaller entities, such as federated networks, to avoid unintended negative impacts.
Finally, the EFF addressed Brazil’s evolving internet intermediary rules. They cautioned against notice-and-takedown mechanisms and duty-of-care obligations that might facilitate censorship. The organization advocates for robust appeal processes, transparency, and accountability, warning that enforcement must not normalize platform blocking or rely excessively on automated content moderation.
