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Brazil Introduces 15-Day Blocking for Abusive Calling

For businesses using automated voice calls in Brazil for OTP fallback, collections, or customer callbacks, short-call patterns can become a service-continuity issue rather than merely a conversion metric. Published on October 13, 2026, Provisional Measure 1396 introduces a 15-day restriction on call origination for abusive use. Its rollout distinguishes obligations enforceable after 30 days from requirements dependent on Anatel regulations, making implementation tracking essential before changing production dialing rules or interpreting supplier blocking notices. ([congressonacional.leg.br](https://www.congressonacional.leg.br/materias/medidas-provisorias/-/mpv/175932?utm_source=openai))

Published:10/31/2026 Updated:10/31/2026

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))

Frequently Asked Questions

Should we lengthen short OTP voice recordings?
Do not lengthen recordings simply to manipulate a metric. First measure actual attempts and outcomes, reduce duplicate fallback requests, and cap calls associated with a single verification transaction. Record audio-file duration separately from the recipient's connected-call duration so supplier reviews use actual call outcomes rather than the length of the recording prepared by your application.
Can adding outbound numbers prevent a restriction?
Number rotation is not a dependable workaround because Article 6 includes both per-access and user-wide volume conditions. ([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)) Ask your supplier how it associates numbers with a user, consolidate the relevant number pool in one dashboard, and correct excessive retries or duplicate dialing jobs before expanding capacity. Treat additional numbers as a capacity decision, not a compliance exemption.
Can we switch directly to SMS after a calling restriction?
Check whether the notice restricts voice origination, particular numbers, or other services before enabling a fallback route. For verification, send SMS only for transactions that remain valid and reuse the transaction identifier to prevent duplicate delivery. Review the messaging purpose, applicable consent, and supplier restrictions independently; do not automatically migrate an entire collections or marketing queue into SMS.
This article is for informational purposes only and does not constitute legal advice.

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