1. Regulatory focus
Article 6 combines a daily volume condition—more than 1,000 calls per access or more than 10,000 across a user's accesses within the same service—with a short-call share of at least 85%, and provides for a 15-day restriction on call origination. ([congressonacional.leg.br](https://www.congressonacional.leg.br/materias/medidas-provisorias/-/mpv/175932?utm_source=openai)) Short calls include unsuccessful attempts, calls routed to voicemail, and connected calls lasting no more than six seconds. These are voice-specific criteria, not SMS throughput limits; teams should keep the statutory thresholds separate from supplier traffic policies and verify Anatel implementation rules before treating every element as immediately enforceable. ([www12.senado.leg.br](https://www12.senado.leg.br/publicacoes/estudos-legislativos/tipos-de-estudos/sumarios-de-proposicoes/mpv1396/%40%40download/file/Sumario_Executivo_MP1396.pdf))
2. Business impact
The rollout is staggered: blocking calls and messages using irregular access codes, together with specified per-access abusive-calling obligations, becomes enforceable after 30 days, while authentication, corporate caller identification, and the centralized numbering database depend on implementing regulations. ([www12.senado.leg.br](https://www12.senado.leg.br/publicacoes/estudos-legislativos/tipos-de-estudos/sumarios-de-proposicoes/mpv1396/%40%40download/file/Sumario_Executivo_MP1396.pdf)) Operationally, teams should therefore distinguish OTP voice fallback, collections, and marketing traffic rather than investigate them as one undifferentiated stream. A useful incident review should identify which workflow generated repeated attempts, which numbers or accounts the supplier restricted, and whether the notice concerns voice origination or a separate messaging issue, instead of assuming that a calling restriction automatically suspends SMS.
3. Operating recommendations
Build a Brazil calling dashboard that aggregates daily attempts, unsuccessful calls, voicemail outcomes, and connections lasting six seconds or less by number and user, and ask suppliers to document their counting methodology and reporting time zone. Configure OTP cooldowns, retry caps, and cross-channel deduplication; add backoff rules for unanswered collection calls and preserve workflow labels for incident review. Maintain separate trackers for Anatel implementation and congressional consideration: the congressional record updated on October 29 still showed the measure awaiting installation of its committee, so internal policy documents should not describe it as legislation already permanently enacted by Congress. ([congressonacional.leg.br](https://www.congressonacional.leg.br/materias/medidas-provisorias/-/mpv/175932?utm_source=openai))