Targeted Ads Prohibited, Under 12s Banned — Brazil's Challenge in the "Post-SNS Era" of Child Protection

1) What is Happening - "Under 12 × SNS" is "Prohibited"

Brazil's major economic media, InfoMoney, reported on an unofficial draft (minuta) of a regulatory bill being prepared by the government. It proposes a strong demarcation by banning SNS access for those under 12 and requiring parental supervision (such as account linking) until age 16. Platforms are required to verify the actual age, with sanctions imposed for violations. In terms of advertising, the bill prohibits targeting based on behavioral profiles for children and young people and also bans advertisements for weapons, alcohol, tobacco, pornography, and gambling.InfoMoney

This is not a hasty idea. By June 2025, the Brazilian government (Ministry of Justice and Public Security) has raised Instagram's age rating to "not recommended for those under 16". There is a precedent for administrative decisions leaning towards "safety," aiming for permanence through legislation.Serviços e Informações do BrasilCNN Brasil

2) The Catalyst: A Single Video - Politics Captures Society's "Buzz"

The acceleration is driven by a video from popular YouTuber Felca, exposing the "adultification of children (adultização)." After its release, the lower house saw over 30 bills concerning the regulation of minors' exposure and platform obligations, while the upper house initiated a **CPI (investigative committee) on the exploitation of minors** with signatures from 70 legislators. The visibility of the issue temporarily brought right and left-wing parties to the same table, but conflict over the scope of regulation has reignited.CNN Brasilwww12.senado.leg.brnoticias.uol.com.brPoder360

3) Supporters Speak of "Protective Freedom," Opponents Warn of "Excessive State"

Supporters argue simply: "SNS is not a safe place for minors. Without parental supervision, the risks of exploitation, crime, and excessive commercialization skyrocket." Expert comments from public institutions also emphasize the stance that **"continuous parental monitoring is essential."**Agência Brasil

Opponents express concerns about (1) balancing with the constitutional freedom of expression and communication, (2) implementing age verification that invades privacy, (3) state intervention in the right to family education, and (4) pressure on innovation, including emerging platforms. Right-wing legislators strongly criticize it as "general regulation strengthening under the guise of child protection."noticias.uol.com.br

4) Key to "Implementation" - Age Verification, Advertising, and Supervision

Age Verification: The draft's demand for "verification of actual age" could realistically be achieved through a combination of technologies like ID upload, facial age estimation, and financial account linking, but concerns about misjudgment and discrimination risks and data breaches remain. Linking to parental accounts is key to preventing minors from impersonating others, but it increases the operational burden in single-parent or shared-device households.

Advertising Restrictions: The ban on profiling ads for children is a trend in many countries, and the Brazilian proposal goes further by explicitly excluding ads for weapons, alcohol, tobacco, pornography, and gambling. This could affect creators' revenue diversification, and platforms may be required to provide **compensation and transparency reports based on "age group determination errors."**InfoMoneyTerraHardware.com.br

Supervision Obligation: For accounts under 16, implement restrictions on usage time, features, and viewing categories, allowing parents to check audit logs. To ensure effectiveness beyond mere "parental approval flows," the design must address rejection, reporting, and deletion buttons' default positions and prohibit UI dark patterns.

5) SNS Reactions - "Protect the Children" vs. "Excessive Intervention"

On Instagram and Threads, voices are divided, with comments like "Under 12 is obviously not allowed," "Start with house rules," and "Don't force companies to verify age." In the comment sections of news posts, the debate continues between **"parental responsibility" and "corporate accountability", with some expressing cynicism as "politics scoring points." In threads on InfoMoney's official posts and various media's SNS posts, there is a significant number of middle-ground voices saying "I agree if it's linked to a supervisory account", while skepticism remains about it being **"a prelude to censorship."ThreadsInstagram

Right-wing accounts and some legislators warn of "internet regulation under the guise of child protection," while left-wing and child protection organizations support the regulation, arguing that "algorithms are 'commodifying' minors." News commentary programs are covering the topic daily, with features examining the social impact of Felca's video.Hora do Povo

6) Political Direction - "Unification" or "Separate Deliberation"

In the lower house, the focus is on whether to combine child protection and platform regulation in a single bill or to proceed with child protection first/platform obligations separately. The Speaker of the House is inclined towards packaging "child protection," but the opposition remains skeptical of "comprehensive regulation." If the CPI proposal is deliberated, testimonies from relevant ministries and platform executives will further illuminate the debate.noticias.uol.com.br

7) "Criteria for Judgment" for Readers

1. Severity of Harm: Urgent need to prevent crime and exploitation.

2. Balance of Rights: How to weigh freedom of speech, privacy, and the right to education.

3. Technological Feasibility: Can age verification be implemented safely, without discrimination, and at a cost that allows widespread adoption?

4. Accountability: Can companies regularly publish **transparent impact assessments (on advertising delivery and recommendations affecting minors)?**

5. Family and School: Can literacy education and parental support be strengthened alongside tech regulation?

8) Proposals for the "Optimal Solution" (Editorial Opinion)

• Phase Introduction: Prioritize the obligation to implement age verification and supervision functions, and clarify age-specific safety standards for advertising early on.

• Audit and Independent Evaluation: Include third-party oversight (academic and NPO) in the institutional design, not just government agencies.

• Data Minimization: Combine anonymous proof (zero-knowledge) and on-device estimation × parental approval to avoid centralized storage of ID images.

• UI/UX Standards: Incorporate dark pattern prohibition, visibility of report/block options, and default settings for usage time into regulatory technical standards.

• Educational Investment: Standardize media literacy materials for schools and families at the national level.

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