The Global Network Initiative calls for stronger safeguards in Brazil’s age assurance guidance
The Global Network Initiative has welcomed parts of Brazil’s proposed guidance on online age checks but called for clearer limits on biometric methods and stronger protections for privacy and access to lawful content.
The Global Network Initiative (GNI) has submitted comments on Brazil’s preliminary Orientative Guide on Age Assurance Mechanisms, published in May 2026 by the National Data Protection Authority, known as ANPD.
The guide explains how obligations under Brazil’s Digital Statute for Children and Adolescents and a related decree should be applied. GNI welcomed its emphasis on proportionality, limited data collection and restrictions on the reuse of information gathered during age checks.
However, GNI said the guidance should pay greater attention to its effects on adults. It argued that requests for identity documents or biometric data could discourage some users from accessing lawful content and could create additional privacy and security risks.
The organisation also raised concerns about the broad scope of the rules, which apply to services directed at children or likely to be accessed by them. According to GNI, this could affect operating systems, digital encyclopaedias, non-profit services and smaller providers that may have limited capacity to carry out reliable age checks.
GNI recommended that biometric age checks be treated as a last resort. It said less intrusive options, including age credentials and document checks without facial matching, should be considered first.
The submission also calls for at least one verification option that does not require an official identity document, a smartphone camera or stable broadband access. GNI said such requirements could exclude people who do not have access to these resources.
GNI further recommended clearer appeal procedures for users who are wrongly denied access, including timely reviews and the option of human reconsideration. It also called for clearer rules on when services may rely on an age check already completed by another provider, to avoid repeated requests for sensitive information.
The organisation warned that systems introduced to distinguish adults from minors should not later develop into broader identity or authentication systems. It urged ANPD to address these issues before publishing the final guidance.
