Brazil Advances Toward GDPR Alignment: ANPD’s 2026–2027 Priority Topics

Summary: Brazil’s data protection authority (ANPD) is signaling a clear move toward stronger, more GDPR-aligned enforcement and rulemaking through its 2026–2027 Priority Topics Map and updated Regulatory Agenda. The selected priorities mirror familiar EU themes—data subject rights, children’s data, public-sector processing, and AI—while adding practical predictability for organizations planning compliance. For European businesses operating in Brazil, the direction of travel suggests increasing convergence in governance, risk assessment, and transparency expectations. This trajectory may also strengthen the long-term case for Brazil to pursue an EU adequacy decision.

A maturing authority with a strategic alignment to GDPR

While European regulators refine enforcement mechanisms for mature frameworks, Brazil is quietly building one of the world’s most GDPR-aligned data protection systems outside the EU. The release of Priority Topics Map for 2026–2027 and its updated Regulatory Agenda by the National Agency of Personal Data Protection (ANPD) reveals an authority no longer in its infancy, but one strategically positioning itself as a credible counterpart to European supervisory bodies.

ANPD’s priority topics for 2026–2027

The four priority topics chosen by Brazil’s National Data Protection Authority („ANPD“) tell a familiar tale to anyone working with GDPR compliance: data subject rights, protection of children and adolescents in digital environments, processing by public authorities, and artificial intelligence with emerging technologies.

Why these priorities feel familiar to GDPR practitioners

These are not arbitrary choices but deliberate alignments with the core concerns that have shaped European enforcement over the past seven years, from the fundamental rights guarantees in Articles 12 through 22, to the heightened scrutiny of processing involving minors, to the evolving regulatory treatment of algorithmic systems that now spans both GDPR recitals and the EU AI Act itself.

Children and adolescents: new authority and converging expectations

Brazil’s recent Digital Statute for Children and Adolescents hands ANPD substantial new authority over age verification and parental consent mechanisms, creating a regulatory bridge that should look strikingly familiar to companies navigating the UK’s Age Appropriate Design Code or implementing EDPB guidance on child data. European digital services operating in Brazil, particularly in social media, gaming, education, or wellness sectors, now face converging compliance expectations on both sides of the Atlantic. The technical architectures and consent flows designed for GDPR are increasingly fit for purpose in the Brazilian context as well.

Artificial intelligence and emerging technologies

The elevation of artificial intelligence to priority status represents ANPD’s clearest statement yet about where Brazilian regulation is headed – in fact, no big news in the move, since it is worrying every regulator in every industry. While the LGPD lacks specific AI provisions, the authority has been methodically laying groundwork through public consultations on automated decision-making and studies on algorithmic profiling. For companies already deep in EU AI Act preparation, such a convergence offers something rare in global privacy compliance: the potential for genuine efficiency gains through shared governance frameworks, unified risk assessment methodologies, and harmonized transparency protocols rather than duplicative regional adaptations.

Data subject rights and DPIAs: reinforcing accountability

ANPD’s continued emphasis on data subject rights and Data Protection Impact Assessments reinforces the structural similarities with GDPR’s accountability model. The Brazilian approach increasingly mirrors European expectations around documented risk assessment, standardized response protocols for individual rights requests, and transparency obligations for profiling activities. Multinational organizations can now reasonably contemplate unified DPIA templates and centralized rights management systems that serve both jurisdictions without fundamental architectural splits.

The updated Regulatory Agenda for 2025–2026: predictability as a compliance asset

The updated Regulatory Agenda for 2025–2026 provides something perhaps more valuable than new rules: predictability. One should not underestimate the importance of predictability in Brazil, since it is a rare asset, even before courts – former Treasury Minister Pedro Malana once iroonically stated that „in Brazil, even the past is uncertain“.

What ANPD is telegraphing next

By telegraphing upcoming initiatives on biometric data processing, inspection methodologies, sanctioning procedures, cybersecurity standards, and privacy program governance, ANPD offers companies the planning visibility that makes cross-border compliance feasible rather than reactive. These topics map directly onto GDPR’s controller obligations, security requirements, and Data Protection Officer independence provisions in Articles 24 through 39.

Beyond compliance: what convergence could mean for data flows

The regulatory convergence carries implications beyond operational compliance. The structural alignment between LGPD and GDPR, reinforced by ANPD’s strategic choices, strengthens the case for an eventual EU adequacy decision recognizing Brazil under Article 45.

For European businesses and their counsel, the trajectory suggests not just reduced friction in managing trans-Atlantic data flows, but the emergence of genuinely compatible regulatory ecosystems. The challenge will be maintaining attention to Brazilian developments with the same intensity devoted to EDPB guidelines and Commission decisions, recognizing that convergence is a continuous process rather than a static achievement.

Conclusion

Brazil’s ANPD is increasingly setting priorities that mirror the main pressure points of GDPR compliance, while using its Regulatory Agenda to add clarity and sequencing to what comes next. For organizations operating across the EU and Brazil, the message is practical: governance structures, rights-handling processes, and risk assessment tooling built for GDPR are becoming progressively reusable in the Brazilian context. At the same time, staying alert to ANPD’s evolving guidance—especially around children’s data, AI, biometrics, cybersecurity, and enforcement methodology—will be key to turning regulatory convergence into real operational efficiency and reduced cross-border friction.