CGI.br Issues 46-Point Technical Roadmap for Regulating Social Media

Overview

• The CGI.br published the 46 directives on Thursday, Sept. 17, as a consultative document meant to shape future legislation, regulatory standards and judicial reasoning rather than create immediate legal duties.
• The guide is organized into six interdependent axes that apply the principle of proportionality so larger, higher‑impact platforms face stricter obligations than small providers and community networks.
• Key prescriptions include requiring foreign platforms that serve Brazilians to keep legal representation in Brazil, mandating publication of moderation rules and removal metrics, requiring trained human moderators for Brazilian contexts, and labeling AI‑generated content.
• The roadmap draws a clear line between low‑interference data transport services and high‑interference recommendation platforms, saying greater algorithmic influence should bring stronger prevention duties and potential liability, and it bans abusive self‑preferencing by dominant ecosystems.
• The document is already feeding debate in Congress, regulators and civil society about whether to draft new laws or enforce existing frameworks like the Marco Civil and the ECA Digital, which could affect platform operations, competition remedies and oversight practices.