Independent map & monitor Brazil Est. 2026 AI Governance Observatory

Mapping the governance of artificial intelligence in Brazil

Brazil has the most fully worked AI-governance debate in its region and, as yet, no general AI law. For a country whose general AI law is still a bill, that international footprint and a real domestic case docket are the profile's centre of gravity.

WAICO founding signatoryNamed among the twenty-nine founding signatories of the World AI Cooperation Organization (Shanghai, 16 July 2026); binding membership follows domestic ratification.
Explore the map Analyze the case tracker
20instruments mapped
6binding, in force
3soft law
3draft / pending
8regional / international
01The map

Every instrument, ordered by force

The shape is an emerging jurisdiction whose general AI law is still a bill. The binding tier is mostly general law an AI dispute would meet, with two AI-specific rules that bind only within their domains, elections and the courts. The soft tier carries a well-funded national plan, and the draft tier carries the framework bill that would, once enacted, move much of this into a single statute.

All Binding Soft law Draft / pending Regional
All types AI-specific Data protection Digital and telecom Copyright Industrial property
Binding · general law6 in force · enforceable
Data protectionVia data

Brazil's data-protection statute and the general law most likely to reach an AI harm. Its article 20 gives a right to request review of decisions taken solely on automated processing, with an explanation of the criteria used; the original guarantee of review by a natural person was removed in 2019, so the statute does not require a human reviewer.

Source: Planalto
Digital and telecomGeneral catch

The internet framework governing intermediary liability. In June 2025 the Supreme Court held article 19 partly unconstitutional and moved platform liability toward a notice-and-action regime. The fixed thesis addresses user content and platform duties and carries no AI-specific holding, so it reaches AI-amplified harm only indirectly.

Source: Planalto; STF
AI-specificAI-native

The one binding AI-specific transparency duty in force, scoped to electoral propaganda. Article 9-B requires explicit, prominent labeling of AI-generated or AI-altered campaign content; article 9-C bans campaign deepfakes, defined as synthetic audio or video altering the image or voice of a real, deceased or fictitious person, on pain of loss of registration or mandate. Administered by the electoral court, not a general operator duty.

Source: TSE
AI-specificAI-native

The binding rule for AI use inside the Judiciary. It classifies judicial AI by risk, requires meaningful human oversight with no decision taken solely by a machine, restricts sending personal data to external models, and creates a national AI committee. It binds the courts, not private operators.

Source: CNJ
CopyrightGeneral catch

The authorship framework. Article 11 defines the author as the natural person who creates the work, and the law carries no computer-generated-works provision. Its limitations in article 46 are an enumerated list read restrictively, with no text-and-data-mining exception.

Source: Planalto; WIPO Lex
Industrial propertyGeneral catch

The patent, trademark and design framework. Inventorship is confined to natural persons, and the INPI refused the DABUS filing that named an AI as inventor, withdrawing the national-phase application in 2022. No AI-inventorship provision.

Source: Planalto; WIPO Lex
Soft law · policy3 in effect · no sanctions
AI-specificAI-native

The first national AI strategy, built on the OECD AI Principles, setting direction across research, skills, public services and ethics. A strategy document with no operator duties.

Source: MCTI
AI-specificAI-native

The flagship AI investment plan, projecting around twenty-three billion reais over four years across five axes: computing infrastructure including a national supercomputer, diffusion and training, AI in public services, AI for business innovation, and support for the regulatory and governance process. An investment plan, not binding law.

Source: MCTI
AI-specificAI-native

The data-protection authority's AI work: a technical note analysing the AI bill, a study of generative-AI privacy risks under the LGPD, and a regulatory sandbox on AI and data protection with selected participants. Administrative and advisory, not a binding AI regulation; the authority's prospective role as AI regulator depends on the pending bill.

Source: ANPD
Draft / pending3 · no force yet
AI-specificAI-native

The flagship AI law. A risk-based framework with excessive-risk prohibited practices, high-risk duties, affected-person rights to information, explanation and contestation, an oversight authority role, sanctions of up to fifty million reais per infraction, and copyright provisions including a research and education text-and-data-mining lane. Not in force; a Chamber vote reportedly planned for 2026 had not occurred on the record.

Source: Congress
AI-specificAI-native

An executive complementary bill creating a national system to develop, regulate and govern AI, positioning the data-protection authority as a residual authority under a central council. It was sent to cure a constitutional initiative defect in the Senate text over assigning powers to the authority, and is intended to travel with the framework bill. Not in force.

Source: government releases
AI-specificAI-native

Draft guidelines sorting AI-related inventions into AI models, AI-based inventions and AI-assisted inventions, with patentability turning on human inventive contribution and fully autonomous AI output excluded. Emerging office guidance, still in consultation rather than settled.

Source: INPI
Regional & international8 verified memberships

Named founding signatory, agreement signed in Shanghai 16 Jul 2026; Brazil named among the twenty-nine founders in official releases, with domestic accession subject to internal procedures including ratification. Official source: Chinese government and Xinhua releases; Brazilian inter-ministerial press note.

Signatory, 1 to 2 Nov 2023. Official source: gov.uk, the Bletchley signatory list.

Signatory, 11 Feb 2025. Official source: elysee.fr, the statement signatory list.

Adherent; the national AI strategy is built on the principles. Official source: oecd.ai adherents.

Adopted 2021, as a UNESCO member. Official source: unesco.org.

Global Digital Compact adopted by consensus 22 Sep 2024; resolution 78/311 co-sponsored; resolution 78/265 adopted by consensus. Official source: UN records.

Adopted 18 Nov 2024 under Brazil's G20 presidency; reaffirms the G20 AI Principles and the UNESCO Recommendation and sets information-integrity and workplace-AI commitments. Official source: g20.org; the Rio declaration.

Adopted 7 Jul 2025 under Brazil's BRICS presidency; the first standalone BRICS AI-governance statement, calling for a UN-led framework and Global-South inclusion. Official source: brics.br; the statement text.

02Second reading

How squarely each instrument is written for AI, and how hard it binds

Axes: specificity (x, 0-100) is how squarely the instrument is written for AI; force (y, 0-100) is how hard it binds. Placements are editorial judgments for the comparison plot; the tier column is the authoritative classification. The pattern is a country whose AI-specific instruments cluster either high on force but narrow in domain (the electoral and judicial resolutions) or high on specificity but low on force (the bill, the plan, the office guidance), with a binding tier of general law beneath.

Prescriptive Principles Nonbinding Binding
Force without detail stays thin. The draft AI Law would plant a consolidating statute here.
Binding and enforceable
Binding, no direct sanction
Sector guidance
Regional / international
Draft / pending

Tap a marker

Twenty-five instruments, two readings

The binding and prescriptive corner is the crowded one: the CAC-led measures put force and detail together, service by service. The sector guidance sits just left of the binding line, nonbinding in form but treated as obligatory. Dashed markers are drafts; the National AI Law would consolidate the whole stack into one statute.

All twenty instruments
Compare this model with
03Case tracker

The record of AI disputes in Brazil

Unlike a sparse jurisdiction, Brazil has a real and growing docket where artificial intelligence is materially at issue. Four adjudicated matters are recorded below, two of them with published process numbers, alongside a reported cluster. Per the fabrication screen, a process number is cited only where it is published and verifiable, and where a decided matter's number could not be confirmed it is described without one.

The negative trail: No adjudicated Brazilian decision on copyright in an AI-generated work, on AI training data, or on AI inventorship was found; the industrial-property office refused an AI-inventor filing administratively rather than a court deciding the point.
4matters tracked
0adjudicated
4reported

AI-enabled deepfake fraud is reported in the press as a growing consumer risk, charged where at all under the general fraud provisions; these are reported incidents, not adjudicated AI cases.

Brazil · AI-IP Index

How Brazil aligns AI and intellectual property

Brazil holds the human line in statute while its institutions move: authorship and inventorship stay with natural persons and the training exception waits in a bill, but the patent office already has AI examination guidance out for consultation.

Accommodation 0.67 · Institution 0.67. Restrictive on what it will protect, but further along on the institution side than a jurisdiction that has done nothing, because the patent office has dedicated AI examination guidance out for public consultation. The statutes confine authorship and inventorship to human makers and hold no training exception, while the machinery aimed at the AI-and-IP question is emerging rather than settled.
The framework

What the index measures

The AI-IP Index reads a country on two questions that usually get folded together. Accommodation asks how far the law will go to protect intellectual property that a machine helped produce. Institution asks how much administrative machinery sits behind that law: its guidance, its international submissions, its disclosure duties.

A country can be generous on paper and have built almost nothing, or cautious and highly organised, so the two are scored apart and reported as a pair. Each rests on three questions, scored 0, 0.5 or 1.

Accommodation

How far the law will protect intellectual property that a machine helped make.

  • Q1. Patentability of AI-assisted inventionsWhether an invention developed with AI help, filed with a human named as inventor, can be granted. It decides whether AI-assisted research can be protected at all.
  • Q2. Copyright in AI-generated outputWhether output made with AI attracts copyright when a person directed the work. It sets who, if anyone, owns AI-assisted creative work.
  • Q3. Training and text-and-data-miningWhether copyrighted works can be used to train a model without the owner's permission. This is the main fault line between model builders and rights holders.
Institution

How much administrative machinery sits behind that law.

  • Q4. WIPO Conversation participationWhether the IP office has engaged the WIPO Conversation on IP and Frontier Technologies with a substantive submission. It shows the office is working the question at the international level.
  • Q5. National IP office AI guidanceWhether the office has published dedicated guidance on examining AI-related filings. It tells applicants where they stand before they file.
  • Q6. Disclosure or transparency dutyWhether a filing has to declare that AI was used. It is the office's main lever for provenance.

The scale runs the same way on both axes: 0 is the open or developed end, 1 is the restrictive or absent one, and 0.5 sits between for anything conditional or untested. Read as a pair, the two scores show whether AI-assisted work can be protected here, and whether the office has said so in writing.

Within each axis the three questions carry equal weight. That is a deliberate choice, not an oversight. An AI developer might reasonably value freedom to train above patent inventorship, but weighting is where indices lose their credibility, so the score stays a flat mean and the choice is stated in the open. Each cell also cites a statute section, a case or an office page, so any single score can be challenged without disputing the rest.

Two positions are worth naming. A country can be open on the law but thin on machinery, an open-but-undeveloped stance that bets on ambiguity. Or it can be restrictive on rights yet run an active office, a restrictive-but-developed stance that reflects a settled policy choice rather than a gap. The pair of scores tells those two apart where a single ranking would blur them.

Calibration

Testing the scale against known ground

A rubric is only as good as the results it produces on cases where the answer is already known. These three jurisdictions sit outside this series and are scored with the same six questions, as a check. Their law is the best documented anywhere, so if the scale puts them where the law actually sits, the scale is doing its job. They are reference points, not editions.

United StatesAccommodation 0.33 · Institution 0.17
Q10Q20.5Q30.5Q40Q50Q60.5

Firm judicial settlement at both poles and the weakest statutory position on training. The courts have closed the door on AI inventors and AI authors, while everything on training rides on unresolved fair-use litigation. There is no per se duty to declare AI use in a filing, only a candour duty that bites where the use is material.

Thaler v. Vidal, 43 F.4th 1207 (Fed. Cir. 2022); Thaler v. Perlmutter (D.C. Cir. 2025), cert. denied 2 Mar 2026; Bartz v. Anthropic (N.D. Cal. 2025); USPTO revised inventorship guidance, 90 Fed. Reg. 54636 (28 Nov 2025); 89 Fed. Reg. 58128 (17 Jul 2024); 89 Fed. Reg. 25609 (11 Apr 2024).

EuropeAccommodation 0.17 · Institution 0
Q10Q20.5Q30Q40Q50Q60

The most permissive statutory position on training and the strongest transparency duty in force, sitting over an authorship question no court has answered. Read the label carefully: training and transparency run through EU law, but patents run through the EPO under the European Patent Convention, which is not an EU institution and covers 39 states.

Directive (EU) 2019/790, arts. 3 and 4; Regulation (EU) 2024/1689, art. 53(1)(c) and (d); EPO J 8/20 (2021); EPO Guidelines G-II 3.3.1 (2026 edition); Infopaq C-5/08; Painer C-145/10.

United KingdomAccommodation 0.33 · Institution 0.67
Q10Q20.5Q30.5Q40.5Q50.5Q61

Liberal on patents since the Supreme Court abandoned the Aerotel test in February 2026, conservative on copyright, and currently thin on AI-specific machinery after the dedicated AI examination guidance was withdrawn. Section 9(3) nominally protects a work with no human author for 50 years, the widest AI-output right on paper, but no court has ever applied it to generative AI.

CDPA 1988 ss. 9(3), 12(7), 29A, 178; Thaler v Comptroller-General [2023] UKSC 49; Comptroller-General v Emotional Perception AI [2026] UKSC 3; UKIPO practice notice, 14 Jul 2026; Data (Use and Access) Act 2025 ss. 135 to 137.

The check earned its keep twice. The untested rule held: section 9(3) of the UK Copyright Act reads like the widest AI-output right anywhere, yet because no court has applied it to generative AI it scores as untested rather than open, which is the correct answer and the one a headline reading would miss. The check also exposed a limit worth stating. The Institution axis measures AI-specific machinery, not general office capacity, so a long-established office can score poorly when it has withdrawn its AI guidance and imposes no disclosure duty. Read that axis as what an office has built for AI, nothing wider.

Scorecard

The evidence, question by question

Each row below carries the test we applied and the finding behind the score, with a source. The rationale, not the number, is the point.

Direction of travelTightening. The intellectual-property statutes are settled and are not themselves being amended for AI, but the surrounding machinery is moving fast: a comprehensive framework bill sits in the Chamber with training and transparency rules, a complementary bill would build a national AI governance system, and the patent office's AI examination guidelines are being finalized from consultation. None of it is yet in force on the six questions, so it is recorded apart from the level: a pending change is signal, not yet the rule. This is recorded apart from the scores: a pending change is signal, not yet the rule.

Scores verified 21 July 2026, against AIP Index codebook v1.0. A score is only true as of its date.

0 · open or developed0.5 · conditional or emerging1 · restrictive or absent

Accommodation: what the law permits

Mean 0.67
0.5
Q1. Patentability of AI-assisted inventions

What we look forA granted patent or a clearly workable examination route, not merely a silent statute.

The findingThe industrial-property law confines inventorship to natural persons, so an AI-assisted invention with a human inventor is open in principle while the machine cannot be named. The office refused the DABUS filing that named an AI as inventor, and its draft guidelines would admit AI-assisted inventions on a human-contribution test while excluding fully autonomous output. Open in principle, untested for a grant, and the guidance not yet settled.

Law 9.279/1996; INPI DABUS withdrawal (2022); INPI Public Consultation 03/2025
0.5
Q2. Copyright in AI-generated output

What we look forProtection applied where human choices shape the work, and refusal of purely machine output.

The findingThe copyright law defines the author as the natural person who creates the work, so a human who directs an AI tool and contributes authorship can hold copyright, while purely AI-generated output has no qualifying author and no route to protection. There is no computer-generated-works provision and no ruling tests the point, so it is untested.

Law 9.610/1998, art. 11; WIPO Lex
1
Q3. Training and text-and-data-mining

What we look forA statutory or judicial mining lane. Silence scores against the miner, since the reserved-rights default governs.

The findingThere is no training or text-and-data-mining exception in force. The copyright limitations in article 46 are an enumerated list read restrictively, with no mining carve-out; a research and education mining lane exists only in the draft framework bill. With copyright silent, the reserved-rights default governs the use of works for training.

Law 9.610/1998, art. 46; PL 2338/2023 (draft)

Institution: how developed the machinery is

Mean 0.67
0.5
Q4. WIPO Conversation participation

What we look forA traceable, substantive submission on the record, not bare membership.

The findingBrazil and its industrial-property office are active internationally, presenting at the WIPO Conversation and leading a BRICS project on AI in patent examination, but no formal national written submission to the WIPO Conversation was found. Substantive participation without a submission on the record earns the middle.

WIPO Conversation materials; INPI and BRICS project record
0.5
Q5. National IP office AI guidance

What we look forA standalone AI examination text, not AI handled quietly under general practice.

The findingThe industrial-property office has published draft AI patent-examination guidelines for public consultation, sorting AI-related inventions by human contribution. This is real institutional action aimed at the AI-and-IP question, but it sits in consultation rather than as a settled directive, so it earns the middle rather than the absent pole.

INPI Public Consultation 03/2025
1
Q6. Disclosure or transparency duty

What we look forA mandatory declaration inside the filing, not a proposal or an informal request.

The findingNo filing requires declaring AI use, and no in-force instrument imposes a labeling or transparency duty on AI-generated content in the intellectual-property system. The transparency duties that would reach developers exist only in the draft framework bill, and the in-force AI-labeling duty is scoped to electoral propaganda, not IP filings.

Copyright and Industrial Property filing provisions; TSE Resolution 23.732/2024 (electoral only)

Conclusions

Can AI be named as inventor?
No; the industrial-property law confines inventorship to natural persons
Statutory opt-out from training?
None in force; with no training exception there is nothing to opt out of
Volume of disputes
Growing, but not yet on the intellectual-property questions; the decided AI cases are electoral

Instruments where AI meets IP

Copyright & patents

Copyright and Related Rights Law, Law 9.610/1998

The authorship framework.
National Congress; in force, as amended; administered by the copyright bodies
Article 11 defines the author as the natural person who creates the work, and the law carries no computer-generated-works provision. Its limitations in article 46 are an enumerated list read restrictively, with no text-and-data-mining exception.
Copyright & patents

Industrial Property Law, Law 9.279/1996 (LPI)

The patent, trademark and design framework.
National Congress; in force; administered by the INPI
Inventorship is confined to natural persons, and the INPI refused the DABUS filing that named an AI as inventor, withdrawing the national-phase application in 2022. No AI-inventorship provision.
Copyright & patents

AI Framework Bill (PL 2338/2023)

The flagship AI law.
National Congress; approved by the Senate 10 December 2024, pending in the Chamber of Deputies awaiting the rapporteur's report
A risk-based framework with excessive-risk prohibited practices, high-risk duties, affected-person rights to information, explanation and contestation, an oversight authority role, sanctions of up to fifty million reais per infraction, and copyright provisions including a research and education text-and-data-mining lane. Not in force; a Chamber vote reportedly planned for 2026 had not occurred on the record.
Copyright & patents

INPI patent-examination guidelines on AI (Public Consultation 03/2025)

Draft guidelines sorting AI-related inventions into AI models, AI-based inventions and AI-assisted inventions, with patentability turning on human inventive contribution and fully autonomous AI output excluded.
National Institute of Industrial Property; consultation opened August 2025, comment window closed October 2025, no definitive act published
Emerging office guidance, still in consultation rather than settled.

The case record

No reported decision. As of July 2026 there is no published court decision or IP office ruling in Brazil on AI authorship, training-data infringement, AI inventorship or an AI registration. Growing, but not yet on the intellectual-property questions; the decided AI cases are electoral, labour-court and surveillance matters, not disputes over AI-made rights.

Method. Six questions, three per axis, scored 0, 0.5 or 1 against AIP Index codebook v1.0. The three questions in each axis are weighted equally by choice, and the two axes are reported as a pair, never blended into one number. Every score cites a statute, case or office page, carries a verified date, and records its direction of travel apart from the level. Positions are editorial judgements read from primary law and office practice, not official scores. WIPO's public catalogue of IP-office AI initiatives does not score jurisdictions on this basis, so the readings here come straight from the source law. Not legal advice.

04About

Why this exists

Brazil has the most fully worked AI-governance debate in its region and, as yet, no general AI law. The flagship instrument, the Marco Legal da Inteligencia Artificial (PL 2338/2023), a risk-based framework influenced by the European approach, passed the Federal Senate in December 2024 and sits in the Chamber of Deputies awaiting the rapporteur's report, so its prohibited practices, high-risk duties and transparency obligations are not in force. What binds instead is a dense layer of general and sector law: a data-protection statute with an automated-decision review right, a reshaped internet-liability regime, and two binding AI-specific rules that reach only their own domains, an electoral resolution that labels AI content and bans deepfakes in campaigns, and a judicial-council resolution governing AI use inside the courts. The intellectual-property statutes confine authorship and inventorship to human makers. Brazil's distinctive weight is international: back-to-back G20 and BRICS presidencies with AI on the agenda, signature of the Bletchley and Paris texts, OECD adherence, and a named founding seat in the World AI Cooperation Organization. For a country whose general AI law is still a bill, that international footprint and a real domestic case docket are the profile's centre of gravity.

The site does three things: it maps every instrument that governs AI in Brazil, 20 of them, ordered by how hard each one binds; it reads the same instruments a second time by how squarely each is written for AI; and it records the matters where AI meets the law, with what was searched and found empty stated as plainly as what was found. Every claim traces to a primary source, and absences are recorded rather than papered over.

A membership claim enters this table only from an official list: a declaration annex, a treaty signature table, an organization's own record or an official government statement. Brazil's footprint is the largest in the series, anchored by consecutive G20 and BRICS presidencies with AI on the agenda.

Behind this country report

Muhammad Deckri AlgamarIP & digital law · LL.M. (IE-WIPO), AIGP

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An independent research and educational project. Information is provided as-is, may be incomplete, and does not constitute legal advice. Case entries record reported proceedings on a stated date, drawn from public sources, not a legal finding of guilt or liability.