What the technical note is
Sedigi defines an AI companion as a conversational agent that keeps up continuous, personalised interaction, simulates a personality, remembers what the user has shared and adapts to their history and preferences. That definition covers both character roleplay services and personal companion apps, which is why the list mixes the two.
The note was signed by the National Secretary for Digital Rights, Victor Oliveira Fernandes, according to Exame. ConJur, a Brazilian legal publication, stresses that it is a preliminary analysis: it points to possible non-conformities that deserve a closer look, but it does not conclude that any company has violated the law.
The 13 apps named
All four reports give the same list: Character.AI, Replika, Nomi, Candy.ai, Kindroid, Chai, Paradot, Talkie, CrushOn.AI, EVA AI, Anima, Swipey and SpicyChat.AI. Several are general-purpose character platforms; others market themselves as virtual partners, and some openly host adult content. The note's point is not that every app targets children, but that children can get in.
What the note says is wrong
| Risk area | What the note reportedly found | Who is asked to look at it |
|---|---|---|
| Age checks | Most services use a self-declared age as the only gate. The note says how easily that is bypassed is itself an indication that minors probably have access. | ANPD |
| Compulsive use | Design patterns that encourage excessive attachment and long sessions, with few protections against overuse. | ANPD |
| Inappropriate content | Exposure of minors to sexualised or age-inappropriate material. | ANPD |
| Intimate data | Collection of personal and emotional information and the building of emotional and behavioural profiles for commercial use. | ANPD |
| Advertising and payments | How the apps advertise, charge and use data, from a consumer-protection angle. | Senacon |
Exame summarises the note as listing six areas of concern, adding a lack of transparency about the artificial nature of the companion and potentially manipulative mechanisms. The core thread in every report is the same: a birthday field is not an age check.
Why the ECA Digital matters here
The ECA Digital, Brazil's Digital Statute for Children and Adolescents (Law 15.211/2025), came into force on 17 March 2026. Among other things it bars digital services from relying on self-declaration as the only way to keep under-18s away from unsuitable content, and gives the ANPD an enforcement role. ConJur adds that the ANPD has put child protection online and AI on its priority monitoring list for 2026–2027. That is why the ministry sent the note to the data regulator rather than opening a case itself.
Fast Company Brasil places the note against usage data from the TIC Kids Online Brasil 2025 survey, which it reports found that 65% of internet users aged 9 to 17 had used generative AI tools, and about 10% had used them to talk about personal or emotional problems.
How this fits the global picture
Brazil is following the same direction as other regulators this year, but with a different tool. The EU Kids Act proposal would make companion features off by default for minors; the UK's Ofcom is applying age-assurance duties under the Online Safety Act; and Australia is pushing checks down to the app store. Brazil already has the statute in force, so the question there is enforcement, not legislation.
What it could mean for users
Adults in Brazil
The most likely visible change is stronger age assurance at sign-up: document checks, facial age estimation or app-store age signals in place of a date picker. That brings a privacy trade-off, which we cover in AI companion privacy and age verification.
Character and roleplay platforms
General-purpose character apps were named alongside virtual-partner apps. If the ANPD acts, persona memory, retention nudges and mature filters for unverified accounts are the obvious pressure points. Our notes on notifications and retention describe the patterns regulators keep pointing at.
Everyone
The note's data concern applies anywhere: companion apps hold some of the most personal conversations people have. Our privacy checklist is a quick way to see what an app keeps and whether you can delete it.
What happens next
The ANPD and Senacon each decide whether to open proceedings; neither had announced one in the reports we reviewed. Under Brazilian law, opening a case would not by itself mean penalties, and companies would have the chance to respond. We will update this page if either body acts.
Related on CompanionRank
EU KIDS Act: New Rules for AI Companions and Minors UK Age Checks for AI Companions: What Ofcom Enforces AI Companion Privacy & Age Verification, Explained AI Companion App Privacy Settings & Safety Checklist 2026Frequently asked questions
Which AI companion apps is Brazil looking at?
The technical note names 13: Character.AI, Replika, Nomi, Candy.ai, Kindroid, Chai, Paradot, Talkie, CrushOn.AI, EVA AI, Anima, Swipey and SpicyChat.AI.
Has Brazil banned or fined any of these apps?
No. The note is a preliminary analysis that recommends the data regulator ANPD and the consumer secretariat Senacon examine the services. It does not conclude that any company broke the law.
What is the main problem the note identifies?
Most of the services rely only on a self-declared age to keep children out. The ECA Digital, in force since 17 March 2026, does not accept self-declaration as the only age-check method.
Does this affect users outside Brazil?
Not directly. The ECA Digital applies to services offered to users in Brazil, but apps often roll out age-assurance changes across regions once they build them.