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Regulation

AI Legal Framework in Brazil

Technical analysis of PL 2338/2023 — the bill that establishes the AI Legal Framework in Brazil. Understand what changes, who is impacted and how to prepare.

Under consideration — Chamber of Deputies (2025–2026)

What is PL 2338/2023?

Bill No. 2,338/2023, authored by Senator Rodrigo Pacheco, is the main bill for comprehensive regulation of Artificial Intelligence in Brazil. It was developed by the Senate's Commission of Jurists for AI (CJIA), created by Presidential Act No. 4/2022.

The text establishes principles, rights, obligations and a governance system for the development and use of AI systems in the country. It adopts a risk-based approach, similar to the European EU AI Act, with obligations proportional to the potential impact level of each system.

IBGIA has been monitoring and analyzing the legislative process since its inception, producing technical analyses and recommendations to improve the text.

Legislative Timeline

Jun/2023

Bill introduced

Senator Rodrigo Pacheco introduces PL 2338/2023 based on the work of the Senate's Commission of Jurists (CJIA).

2024

Debates and hearings

Public hearings, consultations and debates in the Federal Senate. Amendments and substitutes to the original text.

2025–2026

Chamber of Deputies

Bill approved in the Senate and sent to the Chamber of Deputies for analysis and voting.

2026

Presidential approval

After approval in both chambers, the bill goes to the President for signing or veto.

2027+

Entry into force and regulation

Compliance period for organizations; detailed regulation by the regulatory body to be created.

Risk Classification

The bill adopts a risk-based approach: the greater the potential for negative impact, the greater the obligations for developers and operators.

Unacceptable Risk

Prohibited

Broad social scoring systemsSubliminal behavior manipulationMass biometric surveillance in public spacesClassification of people by race, gender or ethnicity

High Risk

Mandatory impact assessment + human oversight

AI in credit and loan decisionsEmployee selection and evaluation systemsAI in healthcare (diagnosis, treatment)AI in the justice system and law enforcementAI in education and student evaluation

Limited Risk

Transparency and identification obligations

Chatbots and virtual assistantsContent generation (deepfakes, synthetic images)Content recommendation systems

Minimal Risk

Free use; voluntary best practices recommended

Spam filters and antivirusVideo games and entertainmentAI in industrial automation without impact on people

Rights of Affected Persons

Right to information when interacting with AI
Right to explanation of automated decisions
Right to challenge high-risk decisions
Right to human review of automated decisions
Protection against algorithmic discrimination
Transparency about use of data in training

Many of these rights directly relate to the LGPD. See our analysis on the regulatory gaps between AI and LGPD

PL vs. EU AI Act

High-level comparison
Approach
BR Risk-based + principle-driven
EU Risk-based + exhaustive list
High risk
BR Principle-based definition
EU Annex III with 37+ subcategories
Biometrics
BR Restrictions, no total ban
EU Ban in public spaces
Enforcement
BR Regulatory body to be defined
EU National authorities + AI Office
Generative AI
BR Partial coverage
EU Specific obligations (GPAI)

IBGIA Publications on the Legal Framework

Technical analyses and practical guides available for free

Who Needs to Prepare?

Public Sector

  • Algorithmic impact assessment
  • Human oversight in automated decisions
  • Transparency in systems used
  • Right to explanation for citizens
Guide for public managers

Private Companies

  • AI systems inventory
  • Classification by risk level
  • Internal AI governance policy
  • LGPD + Legal Framework compliance
Guide for SMEs

AI Developers

  • Technical documentation of models
  • Bias and discrimination testing
  • High-risk systems registry
  • Compliance by design
Maturity framework

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Need help preparing?

IBGIA offers assessment frameworks, consulting and training for organizations that need to understand and implement AI governance best practices in light of the Legal Framework.