{"id":29952,"date":"2026-01-28T15:49:04","date_gmt":"2026-01-28T18:49:04","guid":{"rendered":"https:\/\/lefosse.com\/?p=29952"},"modified":"2026-01-28T17:32:30","modified_gmt":"2026-01-28T20:32:30","slug":"international-data-protection-day-how-the-anpds-enforcement-activity-has-evolved-in-recent-years-and-expectation-for-2026","status":"publish","type":"post","link":"https:\/\/lefosse.com\/en\/news\/alerts\/international-data-protection-day-how-the-anpds-enforcement-activity-has-evolved-in-recent-years-and-expectation-for-2026\/","title":{"rendered":"International Data Protection Day: How the ANPD\u2019s enforcement activity has evolved in recent years and expectation for 2026"},"content":{"rendered":"\n

With the significant evolution of the ANPD\u2019s enforcement activity, 2026 emerges as a key year for the strategic prioritization of data protection governance within organizations.<\/em><\/p>\n\n\n\n

Today, January 28, we celebrate International Data Protection Day<\/strong>. The date, established in 2006 with the aim of promoting global awareness on the subject, gained prominence in Brazil with the entry into force of the General Data Protection Law<\/strong> (Law No. 13,709\/2018 \u2013 LGPD) and the establishment of the National Data Protection Authority (ANPD), in 2020.<\/p>\n\n\n\n

A few years after the start of the ANPD\u2019s activities and following its consolidation as a regulatory agency in 2025, it is now possible to identify certain enforcement patterns, regulatory priorities, and trends that highlight strategic fronts deserving attention and a concentration of data protection governance efforts in 2026.<\/p>\n\n\n\n

What has changed in the ANPD\u2019s enforcement activity?<\/h2>\n\n\n\n

Transformation into a regulatory agency<\/strong><\/h3>\n\n\n\n

In its early years, the ANPD\u2019s activities were naturally focused on institutional structuring, the issuance of non-binding guidance, and the gradual development of regulatory instruments. This scenario began to change more consistently from 2023 onwards, particularly in 2024 and 2025.<\/p>\n\n\n\n

A representative indicator of this shift is that, as of November 2025, the number of supervisory proceedings initiated by the ANPD was three times higher <\/strong>than the total recorded throughout the entire year of 2024.<\/p>\n\n\n\n

In addition, in the second half of 2025 the ANPD was granted regulatory agency status <\/strong>(Provisional Measure No. 1,317\/2025), with the authorization for 200 new permanent positions.<\/p>\n\n\n\n

This institutional reinforcement is expected to translate into increased operational capacity and intensified enforcement as early as 2026, especially with respect to matters addressed in the Priority Topics Map and the 2025\u20132026 Regulatory Agenda<\/a>.<\/p>\n\n\n\n

Mutual adequacy decision between Brazil and the European Union<\/strong><\/h3>\n\n\n\n

The mutual adequacy decisions between Brazil and the European Union<\/a> also deserve special attention, not only for enabling the reciprocal free flow of personal data, but also for signaling regulatory convergence between these jurisdictions.<\/p>\n\n\n\n

The adequacy decision issued by the ANPD (Resolution No. 32\/2026) expressly provides for the possibility of institutional cooperation between the ANPD, the European Commission, and European data protection authorities, including the exchange of information on the application and interpretation of their respective legislation, as well as the harmonization and sharing of regulatory practices.<\/strong><\/p>\n\n\n\n

This provision points to a trend toward progressive equivalence in the authorities\u2019 enforcement approaches.<\/strong> In this regard, it is worth noting that European data protection authorities have historically adopted a more assertive enforcement posture, including the imposition of significant sanctions and a strict interpretation of governance, transparency, and accountability obligations.<\/p>\n\n\n\n

As a result, guidance, decisions, and resolutions issued by European authorities tend to assume an increasingly strategic role as interpretative references in Brazil.<\/p>\n\n\n\n

However, beyond normative and institutional developments and international standards, it is particularly relevant to observe how the ANPD has acted in practice in recent years, as this offers important indications of the tone, priorities, and level of rigor that are likely to characterize its enforcement activity.<\/p>\n\n\n\n

Oversight and enforcement activity<\/h2>\n\n\n\n

The ANPD\u2019s recent activity demonstrates sector-diversified enforcement<\/strong>, with an increasing focus on higher-risk data protection issues<\/strong>, especially those involving sensitive data, children and adolescents, and new technologies<\/strong>.<\/p>\n\n\n\n

Oversight or sanctioning proceedings: affected sectors<\/strong><\/h3>\n\n\n\n

According to data published by the ANPD, organizations in the following sectors currently have ongoing supervisory or sanctioning proceedings:<\/p>\n\n\n\n

Oversight proceedings<\/mark><\/strong>
Current proceedings, in ascending order based on the number of affected processing agents per sector<\/em><\/td>		Enforcement proceedings<\/mark><\/strong>
Current proceedings, in ascending order based on the number of affected processing agents per sector<\/em><\/td><\/tr>
Sports<\/td>Health<\/td><\/tr>
Executive branch<\/td>Executive branch<\/td><\/tr>
Banks, financial institutions, and card administrators<\/td>Data aggregators<\/td><\/tr>
Digital platforms (messaging applications, social networks, intermediaries)<\/td>Digital platforms (social networks)<\/td><\/tr>
Public security<\/td>Education<\/td><\/tr>
Pharmaceutical<\/td>Pharmaceutical<\/td><\/tr>
Education<\/td>Scientific research<\/td><\/tr>
Data aggregators<\/td>Social security<\/td><\/tr>
Telecommunications<\/td>Public policies<\/td><\/tr>
Technology<\/td><\/td><\/tr>
Insurance<\/td><\/td><\/tr>
Public policies<\/td><\/td><\/tr>
Scientific research<\/td><\/td><\/tr><\/tbody><\/table><\/figure>\n\n\n\n

Topics under ongoing monitoring and oversight proceedings<\/strong><\/h3>\n\n\n\n

Monitoring and oversight proceedings are conducted under confidentiality. Nevertheless, it is possible to identify key topics reflected in the information disclosed by the ANPD to date:<\/p>\n\n\n\n