Brazil's Ministry of Justice and Public Security has published a technical note assessing the risks that artificial intelligence companion applications pose to children and adolescents. The document reviews 13 platforms operating in the Brazilian market and indicates possible noncompliance with the Digital Child and Adolescent Statute, known as ECA Digital. It recommends that data protection and consumer authorities examine the services under their respective mandates.
Scope of the Technical Analysis
The note was prepared by the National Secretariat for Digital Rights and sent to the National Data Protection Authority and the National Consumer Secretariat. It examines AI companions, which are tools designed to simulate friendship, companionship, or romantic bonds through continuous and personalized interaction. The platforms reviewed include Character.AI, Replika, Nomi, Candy.ai, Kindroid, Chai, Paradot, Talkie, CrushOn.AI, Eva AI, Anima, Swipey, and SpicyChat.AI.
Market Growth and Documented Risks
According to the note, the number of AI companion platforms grew from 16 in 2022 to more than 128 by July 2025, with 60 million downloads recorded in the first half of 2025 alone. The document cites research indicating that a large share of adolescents have already used such tools. Identified risks include intense attachment, compulsive use, replacement of human relationships, exposure to sexualized or inappropriate content, and excessive collection of intimate data.
Age Verification Weaknesses
The technical note highlights that most evaluated services rely exclusively on user-declared birth dates, which can be easily bypassed by minors. Brazilian law expressly prohibits self-declaration as the only barrier for content that is inappropriate for users under 18 years old. The document also references tests showing that among 21 applications, none prevented date of birth falsification, and 20 continued conversations after a user stated they were 12.
Possible Violations and International Context
The analysis organizes concerns into six areas: insufficient age verification, lack of transparency about the artificial nature of interactions, potentially manipulative mechanisms, missing protections against compulsive use, exposure to sexualized content, and use of conversation data for commercial profiling. It cites legal cases in the United States involving adolescents and Character.AI, while clarifying that allegations do not establish causation. The document also notes legislative responses in several U.S. states and China's prohibition on offering such services to minors.
Recommendations to Authorities
The Ministry of Justice has asked the National Data Protection Authority to evaluate the risks of AI companions under the ECA Digital framework. It also suggested that the National Consumer Secretariat review advertising, billing practices, and data use for possible consumer protection violations. The note emphasizes that the analysis is preliminary and does not prejudge the outcome of any formal investigation.
Broader Enforcement Landscape
The technical note arrives as Brazil strengthens enforcement of the ECA Digital. In August 2026, the National Data Protection Authority suspended live transmissions on Discord and fined TikTok's parent company 153.7 million reais for data protection failures involving minors. The agency has received about 200 complaints under the ECA Digital since June.
The publication signals stronger regulatory attention to emotional AI products and their impact on young users in Brazil. If authorities pursue investigations, companies may need to demonstrate age assurance, transparency, and safeguards against manipulative design. The findings are also expected to support a future government guide on artificial intelligence in childhood and adolescence.