On 8 December 2025 the Brazilian federal government submitted Bill No. 6.237/2025 in an extra edition of the Official Gazette, proposing a “National System for the Development, Regulation and Governance of Artificial Intelligence”. The bill was co-signed by the Ministry of Management and Innovation, the Ministry of Justice and Public Security, and the Social Communication Secretariat.
Positioning: build the system before setting the rules
Unlike the EU, which sets company obligations through risk tiering, this bill focuses on the “governance system” itself — who regulates, how, and with what tools — rather than listing a schedule of company obligations.
From public information, the orientation has three layers:
First, the state takes a leading role in AI governance. Establishing a national governance system means governance responsibility is coordinated at the federal level rather than relying wholly on industry self-regulation.
Second, development and regulation go together. The bill’s title places “development”, “regulation” and “governance” side by side, showing Brazil is trying to balance promoting the AI industry with setting a regulatory framework.
Third, it advances alongside existing legislative proposals. Brazil’s Senate already has a legislative proposal on the development, promotion and ethical use of AI. The parallel tracks reflect Brazil’s multi-track approach to AI institution-building.
Why the Latin American market deserves its own file
For companies going global, Latin America has rarely featured in AI compliance. That is changing:
First, the market is significant. Brazil is the largest economy in Latin America and an important destination for Chinese AI companies. Fintech, e-commerce and content platforms all involve AI applications.
Second, rules are entering substantive legislation. Moving from “no rules” to “a legislative proposal” means companies need to start preparing a separate compliance assessment rather than copying templates from other jurisdictions.
Third, governance-system legislation often comes first. When a country builds a governance system before detailing company obligations, companies should focus on the composition and powers of the regulator, which will determine future enforcement style and focus.
Three points for companies going global
First, bring Brazil into the regional rule map. Rule maturity varies widely across Latin America and needs separate documentation. See our multi-jurisdiction service.
Second, separate “regulation” from “access”. As in Southeast Asia, AI regulation and foreign investment access and data localisation requirements are separate tracks to be assessed independently.
Third, watch for possible regional mutual recognition. Southeast Asia has shown a trend of leading regional rules through dedicated legislation (as with Vietnam’s AI Law); whether Latin America follows deserves continued observation. See our note on Vietnam’s AI Law taking effect and the China–ASEAN AI governance workshop.
A judgment
The submission of this bill marks Latin American AI regulation moving from discussion to institution-building. For Chinese AI companies, the going-global compliance map is expanding from “Europe, the US and Southeast Asia” to “Europe, the US, Southeast Asia, Latin America and the Middle East”. Building a rule map for emerging markets early is more efficient than responding when a project lands.
This article is based on Brazil’s Bill No. 6.237/2025 and public reporting. It is for general reference only and does not constitute legal advice.