AI law comparison · Data verified 2026-08-22
Brazil LGPD vs GDPR Article 22
Brazil LGPD and GDPR Article 22 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
GDPR Article 22 takes effect first, so it is usually the more urgent of the two. Brazil LGPD tracks 4 compliance requirements and GDPR Article 22 tracks 5. 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 requirementsEU GDPR Article 22 — Automated Decision-Making & AI Profiling
GDPR Article 22 (in force since May 25, 2018) gives EU and EEA residents the right not to be subject to decisions based solely on automated processing — including AI profiling — that produces legal or similarly significant effects (credit scores, hiring, insurance pricing, content moderation). Organizations must inform individuals of automated processing, provide meaningful explanations of logic, implement human revi…
Full GDPR Article 22 requirementsCommon questions
Could both Brazil LGPD and GDPR Article 22 apply to my business?
Yes. Brazil LGPD and GDPR Article 22 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. GDPR Article 22 covers GDPR Art. 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 GDPR Article 22?
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 GDPR Article 22: €20,000,000 or 4% of global annual turnover — whichever is higher (GDPR Art. 83(5)) 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. GDPR Article 22 — effective 2018-05-25. Dates last verified against official sources on 2026-08-22 and 2026-08-22 respectively.
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