AI law comparison · Data verified 2026-08-22
Brazil LGPD vs California CPRA
Brazil LGPD and California CPRA are two of the 169 AI and data regulations Aegis Firma tracks. They have different scopes, effective dates, and penalties — and many businesses fall under both. Here is the side-by-side, drawn directly from the regulatory registry.
Find which laws apply to my businessSide by side
Summary of publicly available regulatory text. Verify against current official sources before relying on this for compliance decisions. Not legal advice.
The key difference
Brazil LGPD takes effect first, so it is usually the more urgent of the two. Brazil LGPD tracks 4 compliance requirements and California CPRA tracks 4. They are not interchangeable — meeting one does not discharge the other. The practical question is not which law is “stricter,” but which of them — or both — actually applies to your business.
Brazil LGPD + AI Bill (PL 2338/2023) — AI Provisions
Brazil's Lei Geral de Proteção de Dados (LGPD, Law 13,709/2018) has been in force since September 18, 2020. Article 20 grants data subjects the right to request human review of any decision made solely on automated processing — including AI decisions — that affects them (profiling, scoring, creditworthiness, hiring, health assessments). Controllers must disclose the criteria and procedures used. The ANPD (National Da…
Full Brazil LGPD requirementsCalifornia Privacy Rights Act (CPRA) — AI Provisions
The CPRA expanded CCPA to cover automated decisionmaking technology (ADMT). The CPPA's ADMT / risk-assessment / cybersecurity-audit regulations (11 CCR §§ 7120-7222) were approved 22-23 September 2025 and took effect 1 January 2026; businesses using ADMT for significant decisions must comply with the ADMT article (pre-use notice, opt-out, access) by 1 January 2027.
Full California CPRA requirementsCommon questions
Could both Brazil LGPD and California CPRA apply to my business?
Yes. Brazil LGPD and California CPRA are separate regulations with separate scopes — a business can fall under both at once. Brazil LGPD covers LGPD extraterritorial reach: applies to processing of personal data of persons located in Brazil, regardless of where the controller is established. California CPRA covers Applies to for-profit businesses doing business in California that meet at least one of: (1) annual gross revenues over $25M in the preceding calendar year (as… If your operations meet both scopes, you must comply with both. Aegis Firma's free scan checks all 169 tracked regulations against your business profile so you do not have to read each law to find out.
Which has the higher maximum penalty — Brazil LGPD or California CPRA?
Brazil LGPD: 2% of revenue in Brazil per violation, up to R$50,000,000 (approximately USD $10M); AI Bill will add sector-specific penalties when enacted California CPRA: $7,500 per intentional violation or violations involving consumers under 16; $2,500 per other violation (Cal. Civ. Code § 1798.155) Penalty structures differ by regulator and violation type — read each law's full page for the cure periods and per-violation detail.
When does each law take effect?
Brazil LGPD — effective 2020-09-18. California CPRA — effective 2023-01-01. Dates last verified against official sources on 2026-08-22 and 2026-08-22 respectively.
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