Newsletter (#003/2025) on Law and Technology by Campos Thomaz Advogados

Responsible Partner: Alan Campos Thomaz

Associate: João Marcelo Oliveira

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Highlights:

Most Read Article of the Month: New Rules for the Use of Artificial Intelligence in the Judiciary

Check out the comments from our partner Alan Thomaz: A Inteligência Artificial no Judiciário: Será que a intervenção humana é mesmo garantida? O que fazer?

Corporate – IMPORTANT! – M&A, Investments, and Venture Capital

Deadline until April 30 to Hold the Annual General Meeting

Partners of business companies, such as corporations (S.A.) and limited liability companies (Ltda.), must call an annual general meeting or a partners’ meeting, depending on the company type, to deliberate on the management accounts and financial statements for the 2024 fiscal year. This process must occur within the first four months of the year, by April 30, 2025. For corporations, it is necessary to make documents such as the management report, financial statements, and opinions from independent auditors and the fiscal council (if applicable) available 30 days before the meeting. As for large limited liability companies, they are no longer required to publish their financial statements for the partners’ meeting, according to recent legislative changes. Learn more.

Check out exclusive content on our website covering essential topics for entrepreneurs and investors. Understand the particularities of corporations in our articles “Sociedade por Ações No. 1 and No. 2,” learn about setting up companies in the U.S. and Cayman Islands, and discover how anti-dilution rules and stock options work. Don’t miss insights on convertible notes and the benefits of this tool, as well as a guide to startup survival, longevity, and success in venture funding. Learn more.

Digital Platforms and Online Services

Court Order Authorizes Access to Digital Platform Data for Locating Debtors

In a recent decision, the 17th Chamber of Private Law of the São Paulo Court of Justice (TJ/SP) authorized the issuance of orders to digital platforms such as iFood, Rappi, Uber, 99 Táxi, Mercado Livre, Amazon, and Netflix, to obtain registration data of a debtor who has defaulted on school tuition fees. This measure aims to facilitate the debtor’s location after unsuccessful attempts to find them at previously known addresses. This decision reflects a trend in the Judiciary to use new technologies and data from digital platforms to ensure the fulfillment of legal obligations, adapting to the behavior of modern consumers and the widespread use of online services. Learn more.

Signature Authentication for Minor Travel Authorization: Protection and Security

The National Justice Council (CNJ), in response to consultation in Procedure No. 0003850-52.2024.2.00.0000, has reaffirmed the requirement for signature authentication in minor travel authorizations, emphasizing the importance of notarial intervention to ensure the authenticity of parental or guardian consent. While the gov.br digital signature holds legal validity, it does not replace the situational analysis conducted by a notary, which enhances the security of the process. This stance reinforces the significance of public faith and the preventive nature of notarial services, helping to prevent fraud and ensuring child protection, in line with the principles established by the Child and Adolescent Statute (ECA) and international treaties. Learn more.

Labor

Important Changes in Labor Rules Affecting Psychosocial Risk Management

MTE Ordinance No. 1,419/2024 introduced significant changes to Regulatory Standard No. 1 (NR-1), including psychosocial risk management in companies’ Risk Management Program (PGR), effective May 26, 2025. This measure broadens the scope of occupational health and safety by incorporating factors such as harassment, emotional overload, exhausting work hours, and toxic organizational environments. It also increases the responsibility for the proper handling of personal data and compliance with the LGPD. The main goal is to prevent workers’ mental health issues and promote a healthier work environment.

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FinTechs, Banks, Financial Services, and Virtual Assets

Explore our new e-book on litigation strategies for Fintechs, featuring 10 strategies to reduce risks and costs related to over-indebtedness claims. Over the past month, we have published alerts on the Coaf’s restrictions on using generative AI and enhancing PIX security measures.

Stay up to date with the latest developments and resources on Fintechs, Banks, Financial Services, and Digital Assets. Our Newsletter #003/2025 highlights key topics such as Open Finance, Digital Assets, Bank as a Service, Tokenization, and Artificial Intelligence. You will also find ongoing public consultations and legislative updates from the Central Bank and CVM, covering issues such as property foreclosure, crypto regulations, and the new contactless Pix feature. Learn more.

Artificial Intelligence

Stay updated on Artificial Intelligence developments in our Newsletter #003/2025, featuring highlights such as the entry into force of the EU AI Act, new guidelines from the European Commission, and the repeal of the U.S. AI Executive Order. In Brazil, we cover key proposals, including the creation of committees to discuss Bill 2.338/2023, aimed at establishing a legal framework for AI, and Bill 526/2025, focused on transparency and data protection. We also discuss Spain’s draft bill on the ethical use of AI and the 2025 AI Safety Report. Subscribe to our newsletter for more updates! Learn more.

Privacy and Data Protection

In our Privacy Newsletter #003/2025, we discuss the new obligations introduced by the Online Safety Act in the UK, aimed at online child protection, with a deadline of April 16th for service evaluations. We also highlight inspections by Brazil’s National Data Protection Authority (ANPD) targeting pharmacy chains, the sanctioning procedure against RaiaDrogasil, and the decision to suspend financial compensations for iris collection in the World ID project. Additionally, we cover the ANPD’s investigation into facial recognition use by football clubs, international cooperation between ANPD and CNIL on AI and data protection, and updates to the Regulatory Agenda for 2025-2026. On the judicial front, we examine recent decisions by Brazil’s Superior Court of Justice (STJ) regarding the validity of evidence obtained through environmental recordings and the invalidation of camera installations without judicial authorization. The ANPD also denied the World Bank’s request for LGPD compliance concerning the international data transfer within the Bolsa Família program. Subscribe to our newsletter for more privacy, data protection, and cybersecurity content. Learn more.

ANPD Selects Winner for Consultancy in AI Regulatory Sandbox

The Brazilian Data Protection Authority (ANPD) has chosen the University of São Paulo (USP) to assist in the development of its Artificial Intelligence (AI) regulatory sandbox. This initiative aims to create a collaborative experiment between regulators, regulated entities, and other stakeholders, such as tech companies, academics, and civil organizations, to test innovations within a secure regulatory framework. USP was selected after scoring 69 points in the selection process, which assessed institutional qualifications, technical expertise, and the proposed methodology. The partnership, involving the United Nations Development Programme (UNDP), will last for 20 months and aims to test AI regulations, increase algorithmic transparency, and promote responsible innovation. Learn more.

HealthTechs

ANS Opens Public Consultation to Create Regulatory Sandbox for Health Plans

The National Supplementary Health Agency (ANS) has launched Public Consultation 151 to gather input on a regulatory sandbox proposal. This initiative aims to test a new health plan model focused exclusively on elective consultations and exams, expanding public access to primary and secondary healthcare services. By doing so, ANS seeks to provide a regulated alternative for individuals relying on unregulated discount cards or popular clinics. The testing period will last two years, during which participating operators must register new products and offer incentives to consumers who join care programs. Learn more.

Sports Betting, E-Sports, and Gambling

New: Brazilian Ministry Launches Regulatory Agenda 2025-2026

The Secretariat of Prizes and Bets of the Ministry of Finance (SPA-MF) launched, on Wednesday (April 16), the Regulatory Agenda for the 2025-2026 period, as established by Ordinance SPA/MF No. 817/2025 published in the Official Gazette of the Union. The agenda foresees the regulation of 13 priority topics by next year, focusing on creating a database of individuals excluded from the fixed-odds betting market, including self-exclusion, exclusion due to gambling-related disorders, and specific restrictions for athletes and public servants involved in regulation. The agenda was developed after a public consultation held between February and March of this year, which received approximately 200 contributions. As a result of public participation, significant adjustments were made, including the unification of items related to supplier regulation and the prioritization of actions aimed at supporting bettors with gambling-related disorders.

At the end of each quarter, starting on June 30 of this year, SPA will publish drafts of new regulations, opening space for public participation through public consultations and other legal mechanisms. In addition to fixed-odds betting, the new agenda addresses topics related to instant lottery (Lotex), commercial promotions, and early collection of popular savings, which is particularly relevant to the construction sector and is focused on tourism. SPA launched this second regulatory agenda, reinforcing its commitment to transparency and public participation in regulating a rapidly growing sector in Brazil.

Dive into an in-depth analysis of Brazil’s growing sports betting market. In our special feature, we explore the Regulation of Sports Betting, delving into the details of new legislation and its impacts. Discover rules and challenges related to betting advertising in the country and issues regarding betting operators’ intellectual property. These materials are crucial for understanding this expanding sector’s legal and strategic landscape. Learn More.

Tax

See our summary guide on Brazilian taxation. Our website offers essential materials for those looking to better understand Brazil’s taxation regimes, particularly for technology companies. Subscribe to our newsletter and stay updated on key analyses and developments in tax reform. Learn More.

Intellectual Property

Keep up with the latest updates and guidance on intellectual property protection with our exclusive guide, which offers comprehensive insights on safeguarding your company’s intellectual assets. Additionally, follow recent alerts, such as the impact of using trademarks as keywords in sponsored ads and the new INPI regulations on technology contracts. Learn More.

Media, Entertainment, and Digital Influencers

Follow current issues concerning the role of digital influencers in the market, including their participation in sectors like betting and the market regulated by B3. Understand the challenges and regulations surrounding this growing and impactful activity. Additionally, learn more about post-mortem image rights, an increasingly relevant subject in the legal and technological landscape. Learn More.

AgriTech

Our newsletter features an AgriTech Special covering key topics transforming agribusiness. Discover how agribusiness technologies impact civil liability, explore innovative financial products for the sector, and follow issues related to data and privacy, intellectual property, and the importance of ESG Finance in the context of AgTechs. The content also addresses the relevance of cultivars, M&A processes, investments, and venture capital in Brazilian agribusiness and corporate challenges in this segment. Learn More.

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