According to the document released on Tuesday (Jan. 20), one of the recommendations is the creation, within a maximum of 30 days, of technical and operational procedures to identify, review, and remove this type of content still available on X when it is generated by Grok in response to user commands.
They also recommend implementing a “transparent, accessible, and effective mechanism” that allows data subjects to exercise their rights, including submitting complaints about irregular, abusive, or illegal use of personal data, especially in cases involving the creation of synthetic sexualized or eroticized content without consent, with an adequate response provided within a reasonable timeframe.
The recommendations were developed in response to user complaints that pointed to the generation of synthetic sexualized content from images of real people.
They were also based on reports published in the national and international press and on tests conducted by government institutions, which indicate the illegal use of the tool by users to produce deepfakes - an artificial intelligence technique that creates false images of real people. The content is sexualized or erotic and carries pornographic connotations, involving real women, children, and adolescents.
The institutions warn that this type of content can affect the protection of personal data and consumer relations, as well as the dignity of the human person and other diffuse, collective, and unavailable individual rights - especially those of women, children, and adolescents.
“Among the joint recommendations is the immediate implementation of measures to prevent Grok from generating new images, videos, or audio files that represent children and adolescents in sexualized or eroticized contexts,” the institutions argue.
According to the document, although Article 19 of the Brazilian Civil Rights Framework for the Internet stipulates that internet application providers are not responsible for harmful content published by third parties except after a court order, the document argues that removal must nevertheless be carried out.
This is because, in the case of sexualized deepfakes, they are not produced exclusively by third parties, but rather through an interaction between users and the artificial intelligence tool created and widely made available by X, “which therefore makes it a co-author of such content, and not merely its intermediary,” the text says.
The document also notes that, recently, Brazil’s Supreme Court declared the partial unconstitutionality of Article 19 of the Brazilian Internet Bill of Rights, precisely because it understands that it “does not offer sufficient protection to relevant constitutional rights.”
In the ruling, the Court established that internet application providers have a special duty of care to adopt all necessary measures to prevent the massive circulation of particularly serious crimes, such as those committed against women because of their gender, including content that propagates hatred against them.
The institutions also note that X’s own self-regulation policy on non-consensual nudity prohibits the publication and sharing of explicit images or videos produced or shared without the consent of the individuals involved.
The platform also prohibits the production, manipulation, and dissemination of images of third parties with sexual or erotic content in contexts involving Grok, which makes “unsustainable, from this perspective as well, the availability of an artificial intelligence tool without rigorous filters that facilitates such conduct.”
If the recommendations are not followed or are implemented insufficiently to mitigate the identified risks, the three institutions may consider and adopt other measures, both administratively and judicially, to ensure adequate protection for the country’s citizens, especially women, children, and adolescents.
According to the study, the expansion of the use of CKD (completely knocked down) and SKD (semi-knocked down) regimes as assembly models could have several effects on Brazil’s auto sector, with repercussions not only on employment but also on car parts manufacturers and exports.
In the CKD model, vehicles are imported in completely disassembled form and then undergo welding, painting, and component integration in Brazil. Under the SKD regime, cars are imported virtually ready-made, in large assemblies. As it stands today, China’s maker BYD operates in Brazil mainly under the SKD model, which is used at its factory in Camaçari, Bahia state, inaugurated last year.
In mid-2025, the Brazilian government authorized an additional quota of USD 463 million, with zero import tax, for dismantled electric and hybrid vehicles. Valid until January 31, the measure ultimately benefited BYD and sparked widespread criticism from traditional auto makers in the country – such as Toyota, General Motors, Volkswagen, and Stellantis, all represented by ANFAVEA.
With the deadline approaching, the association decided to pressure the government not to renew the import tax exemption on dismantled electric vehicles.
“SKD and CKD are not harmful processes in themselves. Many auto makers started their operations in Brazil using these models, collecting the appropriate taxes and structuring their local production based on that. Others utilize the model to serve niche markets. The problem is maintaining incentives for simple high-volume assembly without requiring domestic value added. This threatens the survival of the highly complex industry and the creation of skilled jobs in the country,” ANFAVEA President Igor Calvet argues.
In his view, the industry as it is currently established in Brazil, with more traditional models, is prepared to compete with the new regimes, but only if conditions are similar. “ANFAVEA and its associates do not fear competition. Over the last few decades, the sector has welcomed several international brands willing to invest and compete in Brazil. What we are seeking is a fair competitive environment, with equal rules for all,” Calvet says in a statement.
In a manifesto published on its website, the association reaffirms its opposition to renewing the exemption on imports of kits for high-volume manufacturing. “[This exemption] may seem like an advantageous solution in the short term, but it does not build a strong industry. Simplified production models do not develop local chains, do not generate the same level of jobs, and do not leave the same value in the country. In the long term, they weaken what took decades to build. We are in favor of competition without distortions and with regulatory consistency,” the association argues.
Approached by Agência Brasil, BYD has not yet commented on the matter. The Brazilian Ministry of Development, Industry, Trade, and Services, however, said in a statement that “the quota system for CKD and SKD imports ends this January and, to date, there has been no request from the sector to renew the measure.”
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