Brazil. Data localisation / cross-border. Regulation

ANPD Res. 19/2024Resolution CD/ANPD No. 19/2024 - Regulation on International Data Transfers and Standard Contractual Clauses

In force

§1Summary

Synopsis

Sets out procedures for international transfers under the LGPD, adopts mandatory ANPD standard contractual clauses and governs approval of specific clauses, BCRs and adequacy decisions.

Key themes
  • SCCs
  • BCRs
  • adequacy
  • transparency of transfers
  • equivalent clauses
Unique features

ANPD SCCs must be adopted verbatim (no modification) and the controller must publish transfer information on request; foreign SCCs may be recognised as equivalent.

SaaS relevance

SaaS providers receiving data from Brazilian customers outside Brazil generally need ANPD SCCs in their DPAs (or reliance on EU adequacy where applicable).

§2Obligations

Extraterritorial
Yes
Cross-border transfers
ANPD SCCs mandatory text since 2025-08-23
Maximum penalty
As per LGPD

§3Dates

Key dates
  • Adopted
  • In force
  • 12-month window to incorporate ANPD SCCs into existing contracts ended 2025-08-23

§4Text and authority

Text
Authority
Agência Nacional de Proteção de Dados (ANPD)

§5Where it applies

Domestic law of
Brazil

§6Sources and verification

Verification

High confidence.

DOU URL pattern from general knowledge.