Brazil was the partner country at this year’s HANNOVER MESSE. The trade fair was opened three weeks ago by Chancellor Merz and President Lula in person. Brazil was represented more strongly than any partner country before it.
Ahead of the fair, the Brazilian Embassy invited selected guests from business, politics and academia to a formal afternoon reception to discuss the most important topics shaping German-Brazilian trade. Our colleague Dr. Fabio Cavalcante was invited to participate as a data protection expert on the topic of data protection and international data transfers.
The occasion was a significant development: in January 2026, the EU and Brazil granted each other mutual adequacy decisions. The EU recognises Brazil under Art. 45 GDPR as a third country with an adequate level of protection; Brazil recognises the EU on the basis of ANPD Resolution No. 32/2026. The background is that Brazil’s data protection law, the LGPD, broadly mirrors the GDPR in its underlying approach.
Dr. Cavalcante has published a full article on the topic in Tópicos, the journal of the German-Brazilian Society (available here) and discussed the impacts deriving from the mutual adequacy decisions in a previous article on this blog (here).
In many cases, standard contractual clauses as the primary transfer instrument are no longer required. This meaningfully simplifies supplier relationships, procurement processes and day-to-day operations. At the same time, Dr. Cavalcante was clear: adequacy is not a blanket clearance. Data flows must be documented, onward transfers to third parties controlled, and standard contractual clauses kept available as a fallback. The substantive obligations under the GDPR and LGPD remain unchanged.
If you have questions about this topic or your business in Brazil, please do not hesitate to get in touch.
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