ANPD and UNDP hire consultants to study AI agents and data protection in Brazil

Five calls, one focused on AI agents

ANPD published five calls for proposals, together with the UNDP, to hire consultants who will produce strategic technical studies on priority data protection topics in Brazil. One of the five themes is specifically dedicated to AI agents in the context of personal data protection, according to an official statement published on gov.br/anpd. The other calls cover advertising directed at children and teenagers and manipulative design, a practice known as dark patterns. Applications remain open until July 26, 2026. Each consultancy lasts up to 120 days, with total pay of R$ 82,846.72 per consultant, as reported by Teletime and Convergência Digital.

Why AI agents became a regulatory priority

The choice of theme is not random. AI agents, systems able to make decisions and carry out tasks autonomously while collecting and processing personal data along the way, have spread quickly across customer service, marketing and internal operations at Brazilian companies. That raises concrete questions about consent, purpose limitation and accountability when an agent decides on its own. By commissioning a dedicated technical study, ANPD signals it wants to understand this technology in depth before eventually regulating its use, a move consistent with the other two chosen themes, both tied to how automated systems influence user behavior.

What it means for companies already using AI agents

No new rule takes effect with the publication of these calls. But the signal is clear for companies already running AI agents in customer service or marketing: personal data handled by these systems is on the regulator's radar, and a structured technical study usually precedes concrete rules. It is worth reviewing now how agents collect, store and use personal data, documenting the legal basis for each processing activity and mapping where automated decisions happen without human oversight. Companies that get ahead of this tend to face less friction once compliance requirements are formalized.

AI regulation in Brazil keeps moving slowly and unevenly

ANPD's move contrasts with the deadlock around PL 2338, the bill that would create a general framework for artificial intelligence in Brazil and remains stalled in the Chamber of Deputies. While the broader legislation stands still, ANPD chooses to act within the mandate it already has, using technical studies to build the groundwork for future specific rules on AI and personal data. It is a slower path, but also a more concrete one, and it shows that AI regulation in Brazil will likely advance piecemeal, agency by agency, before any comprehensive law leaves the drawing board.