> ## Documentation Index
> Fetch the complete documentation index at: https://docs.orbit.devotel.io/llms.txt
> Use this file to discover all available pages before exploring further.

# Brazil LGPD + Anatel Sender Posture

> Brazil's Lei Geral de Proteção de Dados (LGPD) and Anatel's A2P SMS requirements mapped to the consent records, DSAR/erasure surface, sender registration, and quiet-hours controls you configure on Orbit.

# Brazil LGPD + Anatel Sender Posture

Brazil shapes A2P messaging along two axes, and operators usually meet
the second before the first. Meta's WhatsApp Business Account rules and
**Anatel's** A2P SMS regime (short-code dominance, carrier-side sender
filtering) decide whether your traffic delivers at all — the
**Lei Geral de Proteção de Dados (LGPD)**, enforced by the ANPD, then
decides what you owe the person behind each +55 number once it does.
This page is the canonical Brazil reference: which controls are yours,
where each one lives on Orbit, and how they fit together for SMS,
WhatsApp, and RCS traffic to Brazilian recipients.

<Note>
  Everything below is a **tenant-owned control**. Orbit ships the
  surfaces — consent records, suppression, the DSAR workflow,
  tenant-configurable quiet hours, sender registration status —
  defaults-open; your organization configures them for Brazil.
  Compliance with LGPD, Anatel rules, and Meta's policies remains your
  responsibility, and the carriers and regulators enforce them
  regardless of what any toggle says.
</Note>

***

## 1. Scope: which traffic touches LGPD

LGPD applies to the processing of personal data of individuals in
Brazil. For messaging, that covers every channel where the recipient's
phone number is the identifier:

* **SMS** — the A2P traffic Anatel and the carriers regulate.
* **WhatsApp** — Meta's WABA layer on top; LGPD obligations still apply
  underneath.
* **RCS** — treated like SMS for lawful-basis purposes.

The channel differences sit mostly on the sender-readiness side
(sections 2–3). The LGPD obligations — lawful basis, consent records,
data-subject rights — are channel-independent. Pick an
LGPD-compliant delivery path first, then document the lawful basis per
recipient either way.

***

## 2. Anatel SMS rules

Brazil's three dominant carriers (Claro, Vivo, TIM) treat A2P SMS as a
registered-sender market:

* **Short codes dominate.** Dedicated short codes are the dependable
  A2P sender type in Brazil; long numbers and unmanaged alphanumeric
  sender ids are heavily filtered at the carrier edge.
* **Registration lead time is 4–8 weeks.** Short-code registration with
  the carriers is not a same-week operation — budget the lead time
  before a launch date depends on SMS.
* **Unregistered alphanumeric senders are filtered** rather than
  delivered with a degraded sender, so an unvetted `from` value does
  not gracefully fall back — it disappears.

Sender registration status and the accepted sender types per country
are exposed on the country-rules surface — filter
`GET /compliance/country-rules` with `country_code=BR` to read Brazil's
row fields (`sender_types`, `registration`, `sender_rules`,
`content_restrictions`). End-to-end sender-id onboarding is covered in
the [LATAM channels onboarding
guide](/guides/latam-channels-onboarding#sender-readiness--sms-sender-id-and-short-code)
and the [sender ID registration
page](/compliance/sender-id-registration).

***

## 3. WhatsApp WABA rules and RCS as the second channel

WhatsApp is the default messaging app in Brazil, so most tenants open
with a WABA rather than an SMS short code:

* **WABA first.** Sender identity on WhatsApp is bound to your connected
  WhatsApp Business Account; you never pass it per send. Complete the
  [WABA setup guide](/guides/whatsapp/waba-setup), and keep the display
  name in the local language — Meta rate-limits sends when
  display-name quality is low.
* **Template language codes.** Business-initiated sends need an
  approved template, and the language code in your request must match
  the approval exactly. For Brazil, submit templates in `pt_BR` — Meta
  does not fall back across language codes.
* **Quality grounds.** Watches you already run for Meta apply: a
  low quality rating throttles or pauses template sends, so treat
  block-rate and user-feedback signals as a sender-readiness metric,
  not a nice-to-have.

RCS is the natural second channel in Brazil — Samsung Messages and
Google Messages have good penetration. Confirm your
[RCS agent](/guides/rcs-onboarding) is verified per country before you
lean on it as a fallback; RCS verification is per-country, exactly like
WABA and short-code registration.

The channel choice per LATAM country — with Brazil's WhatsApp-primary,
SMS/RCS-fallback row — is mapped in the
[LATAM channels onboarding guide](/guides/latam-channels-onboarding).

***

## 4. LGPD lawful bases for messaging

LGPD names ten lawful bases; for messaging traffic, two do nearly all
the work, and one more covers the tail:

| Basis                           | When it fits                                                                                                                  | What you record                                                                 |
| ------------------------------- | ----------------------------------------------------------------------------------------------------------------------------- | ------------------------------------------------------------------------------- |
| **Consent**                     | Promotional / marketing sends                                                                                                 | An explicit opt-in captured per recipient, with the disclosure version they saw |
| **Legitimate interest**         | Service-adjacent messaging your balancing test supports (order status, account alerts your customers would reasonably expect) | The documented balancing test, retained                                         |
| **Contract / legal obligation** | Strictly transactional traffic (OTP, appointment confirmation, mandated notifications)                                        | The contract or obligation the message serves                                   |

Whatever basis you rely on, stamp it on the consent record so the
claim survives audit. Orbit's consent surface carries
`lawful_basis` (`consent`, `legitimate_interest`, `contract`,
`legal_obligation`) alongside the channels and the purpose:

```bash theme={null}
curl -X POST https://api.orbit.devotel.io/api/v1/compliance/consent \
  -H "Authorization: Bearer $ORBIT_API_KEY" \
  -H "Content-Type: application/json" \
  -d '{
    "identifier": "+5511987654321",
    "channels": ["sms", "whatsapp"],
    "opt_in": true,
    "lawful_basis": "consent",
    "purpose": "Promotional messaging the recipient agreed to receive",
    "consent_text_version": "br-promo-v2",
    "consent_proof_url": "https://signup.example.com/consent/evt_7a91c2"
  }'
```

Verify the record before a campaign with
`GET /compliance/consent/lookup?identifier=%2B5511987654321&channel=sms`.

For contacts with **no recorded consent**, your tenant-owned default
decides what happens: the
[unknown-marketing policy](/compliance/consent-default-policy)
defaults to `refuse` for marketing sends, and the consent-default
policy governs CDP fanout. Legitimate-interest marketing in Brazil is a
deliberate posture with a documented balancing test — not a synonym
for leaving the unknown-marketing policy open without one. See
[Consent Management](/compliance/consent-management) for the record
contract.

***

## 5. DSAR posture: erasure and portability under LGPD

LGPD is a first-class regime on Orbit's data-subject-request surface —
it is one of the supported `applicable_jurisdiction` values, and the
SLA tracker applies a **15-day** clock to requests filed under it (see
the jurisdiction table on the [DSAR page](/compliance/dsar)). Requests
arrive through operator workflows or the self-service portal, and
erasure requests run the lifecycle that page documents (cooling-off
window, then the scheduled hard-delete).

To handle Brazil-bound subjects correctly:

1. **File with the right jurisdiction.** Set
   `applicable_jurisdiction: "lgpd"` on intake (or reclassify when a
   request arrives generically) so the 15-day statutory clock applies
   from the start.
2. **Erasure flows feed suppression.** When an erasure completes, the
   outcome flows into suppression — so a deleted contact does not
   re-enter marketing sends via a later import. See
   [Opt-Out & Suppression Lists](/compliance/opt-out-suppression).

The Mexico-style country gate (`regional_send_gates.MX.enabled`) does
not have a BR analog — Brazil enforcement here is the DSAR surface
plus the consent ledger plus your ERP-side suppression, not a send-gate
toggle. The LGPD regime's presence on the erasure/portability surface
is also catalogued in the
[privacy register](/compliance/privacy-register)
(dsar-tracker activities).

***

## 6. Data residency

Voice is the one channel where you pin a resident region directly;
SMS, WhatsApp, RCS, and the audit trail are covered by the platform
geography Devotel publishes, plus the guarantees that apply when a
data-subject request is exported. The full map — which surface answers
which channel's residency question, and what belongs in a
residency-aware tenant checklist — is the
[Data Residency Overview](/compliance/data-residency-overview).

***

## 7. Quiet hours and marketing windows

Brazil has no single federal SMS quiet-hours statute comparable to the
US TCPA calling window; the practical restraint comes from carrier
filtering, Anatel consumer-protection guidance, and LGPD's purpose
limitation — sending marketing at 03:00 is a complaint magnet even
where no statute forbids it. Orbit's enforcement layer is therefore
yours to configure:

* Set tenant **quiet hours** for Brazil-bound marketing in the
  quiet-hours configuration (per-channel, recipient-timezone-resolved)
  — see [quiet-hours configuration](/guides/quiet-hours-configuration)
  and [campaign limits and quiet
  hours](/guides/campaign-limits-quiet-hours).
* Preview a window before a campaign with the
  [quiet-hours preview](/compliance/quiet-hours-preview) surface so
  the gate's decision on a given recipient/time is visible before the
  send.

Use the local recipient timezone (São Paulo time for the bulk of
Brazilian traffic) set deliberately per campaign; the resolver maps the
+55 country prefix unless you override it. A deliberately chosen
window is the difference between a tenant-controlled posture and an
accidental default.

***

## Frequently asked questions

**Does Orbit register my short code with Anatel or the carriers?**
No — carrier/Anatel-facing registration is yours to file (or to file
through your aggregator), the same way sender registration works in
every market. Orbit exposes the country-rules row for Brazil so you can
confirm `sender_types` and `registration` status, and it delivers your
traffic once the sender is registered.

**Which lawful basis should my marketing sends carry?**
Nearly always `consent`. Legitimate interest for promotional messaging
in Brazil requires a documented balancing test your counsel signs off
on; legitimate interest without the test is how ANPD complaints start.

**Does the Mexico-style country send gate exist for Brazil?**
No. Brazil enforcement on Orbit = the consent ledger + the DSAR/erasure
surface + tenant-configured quiet hours + your suppression flow. Check
the ledger before the campaign, not after.

**What clock does an LGPD data-subject request carry?**
15 days — file or reclassify the request with
`applicable_jurisdiction: "lgpd"` and the SLA tracker applies the
statutory clock. Also remember opt-out keywords in-market: a
recipient-initiated `STOP`/`SAIR` flow must work on every sender you
run in Brazil.

***

<Warning>
  This page is documentation, not legal advice — an engineering map of
  the Orbit surfaces, not a legal opinion. LGPD, Anatel rules, and
  Meta's WhatsApp policies carry real enforcement (ANPD, carrier
  edge-filtering, Meta quality-downgrading); have counsel review your
  lawful-basis choices, consent capture language, and sender
  registrations before you send to Brazilian recipients.
</Warning>

***

## Related references

* [LATAM channels onboarding](/guides/latam-channels-onboarding) — the
  step-by-step sender-readiness playbook this page is the posture
  reference for.
* [Country Compliance Requirements](/compliance/country-requirements)
  — the per-country row contract behind `GET /compliance/country-rules`.
* [Consent Management](/compliance/consent-management) — the consent
  record contract (`lawful_basis`, proof URL, text version).
* [Data Subject Access Requests (DSAR)](/compliance/dsar) — the
  erasure/portability surface where `lgpd` and its 15-day clock live.
* [Opt-Out & Suppression](/compliance/opt-out-suppression) — how
  erasure and opt-out outcomes flow into suppression.
* [Quiet-hours configuration](/guides/quiet-hours-configuration) —
  tenant-controlled marketing windows.
* [Data Residency Overview](/compliance/data-residency-overview) — the
  residency map per channel.
* [Assembling a GDPR Posture End to End](/compliance/gdpr-posture-guide) —
  the model for assembling a jurisdiction posture end to end;
  transferable to LGPD with the bases above.