The Global Network Initiative raises privacy and access concerns over Brazil’s age assurance guide

The Global Network Initiative (GNI) has submitted comments on Brazil’s preliminary Orientative Guide on Age Assurance Mechanisms, published by the National Data Protection Authority in May 2026.

The guide explains how to implement age assurance obligations under Brazil’s Digital Statute for Children and Adolescents and a related decree. GNI welcomed its emphasis on proportionality, data minimisation, verifiable credentials and limits on the secondary use of verification data.

However, GNI argued that the guide should give greater attention to the effects of age checks on adults. It said identity and biometric requirements may discourage people from accessing lawful content and create security risks if sensitive documents are exposed.

The organisation also raised concerns about the guide’s broad application to services “likely to be accessed” by children. According to GNI, this could affect general-purpose infrastructure, operating systems, non-profit services and smaller providers that may have limited capacity to conduct reliable age checks.

GNI recommended that biometric methods be treated as a last resort rather than a standard option. It also called for generative AI services to be assessed based to their specific features and risks, rather than being placed in a single category.

The submission further recommends at least one verification method that does not require an official identity document, smartphone camera or stable broadband connection. It also calls for clear appeal procedures when users are incorrectly denied access, limits on repeated verification and safeguards against age assurance systems developing into broader identity infrastructure.