Brazil CONAR 2026 guide: AI avatars as influencers, and AI labels

Brazil's advertising self-regulator CONAR published an updated Guide to Marketing and Advertising by Digital Influencers in May 2026, in force from 1 June 2026. It has a section called "Uso de Inteligência artificial na publicidade" and widens the definition of influencer to include avatar profiles, animals and virtual influencers. Law-firm commentary reads it as not creating a new duty to tell consumers that an ad was made or edited with AI.

CONAR's own news page confirms the guide, the AI section and the 1 June date. The detail on avatars and on AI disclosure comes from Abratel and Lawletter, which are secondary sources; I could not read the guide itself, so check the PDF. All read on 2026-10-03, and none of it is legal advice.

What changed for avatars and virtual influencers?

Abratel quotes the guide as covering "perfis de avatares, animais e influenciadores virtuais", so a talking avatar that fronts your product is an influencer for the guide's purposes. Brasil em Folhas adds that advertisers and agencies are now expected to guide, monitor and correct non-conformities in published pieces, rather than leaving that to the creator. For an AI avatar ad, the creator and the advertiser are often the same team.

Does CONAR require an AI label?

According to Lawletter, not as a new rule: it quotes the guide as not addressing new disclosure duties for AI use, and says CONAR "não impõe, por ora" an obligation to tell consumers that content was generated or edited by AI. The same article reads AI content as bound by the existing code, with AI treated as a production tool. What the guide does keep is clear identification of advertising content, which Abratel gives as the #publi tag.

What do I do on an AI video ad for Brazil?

Treat the ad-identification duty and the existing code as the floor, and decide separately whether to add an AI note. The ad tag and any hashtag go in the post and the platform's paid-partnership tool. In the file, you can burn an on-screen line with Sume's video captions, which accept authored cues with text, start and end and skip speech-to-text.

If the presenter is a Sume avatar, remember what the route makes: avatar video turns a ready avatar and a script into a talking video of 4 to 60 seconds. The script is where truthfulness is decided, so a human reads it before the render. Other markets word the AI question differently: India's three questions, the UK's misleading-or-not test, and the platform label.

What is still unsettled?

Lawletter calls the missing AI disclosure duty a regulatory gap that could be filled by a CONAR amendment, data-protection rules or AI legislation, naming Bill 2.338/2023. That is the author's reading, not a published timetable, so keep your AI notes while the rules settle, and re-read CONAR's page before each campaign. The EU's separate marking duty is not an ad rule either; see whether the EU label replaces an ad disclosure.