Brazil - AI Management Group (2/2025)

Overview

Resolução CITDIGITAL nº 2/2025, adopted on 8 May 2025 and published in the Diário Oficial da União on 12 May 2025, establishes a fifteen-member Group of Work (GT) to operationalize the management of the Plano Brasileiro de Inteligência Artificial (PBIA). The GT is coordinated by the Ministry of Science, Technology and Innovation and is tasked with monitoring execution, producing annual plans and reports, and proposing adjustments to the CITDigital Executive Committee. The instrument implements the coordination powers conferred by Decree No. 12.308/2024 (which instituted CITDigital) and complements the committee’s internal rules under Resolução CITDIGITAL nº 1/2025. The Resolution is administrative in nature and aims to centralize monitoring and coordination functions for PBIA across ministries, development banks and national research agencies, enabling strategic alignment of public investments and policy measures to foster responsible AI development in Brazil.

Definitions

The Resolution uses standard administrative and programmatic terminology: "Group of Work (Grupo de Trabalho - GT)" refers to the collegiate body instituted by the Resolution to manage PBIA activities; "PBIA" stands for Plano Brasileiro de Inteligência Artificial; "Coordinator" denotes the representative of the Ministry of Science, Technology and Innovation designated to lead the GT; "Members and alternates" are the representatives indicated by participating ministries and agencies; "Annual plan" refers to the operational plan prepared each year by the GT and presented to the CITDigital Executive Committee. The instrument also contemplates "interdisciplinary technical subgroups"—temporary advisory bodies created by the coordinator to provide specific technical and scientific support.

Governance and Institutional Framework

The GT is embedded within the governance architecture created by Decree No. 12.308/2024 (see Decree 12.308/2024) and operates under the oversight of the CITDigital Executive Committee. Composition is explicitly listed in the text: Ministry of Science, Technology and Innovation (coordinator), Casa Civil, Secretariat of Social Communication, Ministry of Finance, Ministry of Management and Innovation in Public Services, Ministry of Development, Industry, Trade and Services, Ministry of Education, Ministry of Justice and Public Security, Ministry of Communications, Ministry of Foreign Affairs, FINEP, BNDES, CNPq, CAPES and EMBRAPII. The GT’s institutional function is coordination — consolidating monitoring information, advising the Executive Committee, and issuing annual monitoring reports. Operational decisions (member appointments and convocation of experts) follow standard administrative procedures: members are indicated by their agencies and officially designated by the GT coordinator; the coordinator may invite subject-matter experts, researchers, civil-society representatives and other public or private institutions to participate as non-voting attendees. The GT may establish interdisciplinary technical subgroups to supply technical-scientific evidence to inform PBIA tasks, enabling flexible operationalization aligned with sectoral policies and funding instruments.

Key Focus Areas

The GT’s assigned duties emphasize program management and oversight rather than direct regulatory enforcement. The principal functions are: (1) monitoring PBIA implementation and proposing necessary adjustments to ensure the plan’s objectives are met and aligned with national priorities; (2) preparing and organizing its work in annual operational plans to be presented to the CITDigital Executive Committee; (3) responding to information requests from the CITDigital coordinator and maintaining transparency about progress; and (4) presenting an annual monitoring report on PBIA execution to the Executive Committee. These duties situate the GT at the intersection of policy coordination, public investment oversight and technical advisory activity. By including development finance institutions (BNDES, FINEP) and research funding bodies (CNPq, CAPES), the GT is designed to align financing, research capacity building and industrial innovation actions. The inclusion of EMBRAPII reflects a focus on industry-research collaboration and pre-competitive R&D partnerships that can accelerate applied AI projects. The GT thus functions as a policy-operational hub for cross-sectoral AI initiatives in Brazil and is positioned to shape implementation priorities, interministerial coordination and the distribution of public resources in line with PBIA objectives.

Implementation Framework

Implementation is administrative and iterative: the GT must develop annual plans that detail tasks, timelines and coordination mechanisms and submit them to the CITDigital Executive Committee for review. Members are appointed by their agencies and named by the GT coordinator; the coordinator may convene additional participants or institute technical subgroups as needed. The GT’s operational model deliberately combines permanent institutional representation with the capacity to bring in external expertise, enabling both continuity and access to specialized knowledge. Reporting obligations (annual monitoring report) create a feedback loop with the CITDigital Executive Committee that allows course corrections and formal proposals for plan adjustments. The Resolution imposes no direct duties on private sector AI suppliers but creates governance pathways through which future regulatory, funding or procurement policies may be shaped. Where sectoral policies (e.g., health, finance, education) require coordination with PBIA, the GT serves as the mechanism to ensure alignment and to coordinate research, pilots and capacity-building projects.

Monitoring and Evaluation

The GT’s monitoring responsibilities require it to collect execution metrics, evaluate progress against PBIA targets and propose adjustments where necessary. Annual monitoring reports are the primary evaluation instrument, to be presented to the CITDigital Executive Committee. The Resolution empowers the GT to request information and convene technical subgroups to obtain the necessary data and technical assessments. While the Resolution does not prescribe specific monitoring indicators or evaluation methodologies, the institutional composition (including BNDES, FINEP, CNPq and CAPES) supports access to fiscal, project and research-performance data. The annual planning cycle mandates iterative evaluation: annual plans are prepared and then assessed through monitoring reports, enabling transparency and administrative accountability within the CITDigital governance structure.

Penalties, Liability, and Appeals

Resolução CITDIGITAL nº 2/2025 is an administrative governance instrument and does not itself create sanctions, criminal liabilities or administrative penalties for private actors. It prescribes internal procedural arrangements for federal bodies and the GT’s functioning. As such, enforcement and penalties for non-compliance with future AI-specific obligations will derive from other regulatory instruments (sectoral regulation, administrative decrees, or specific federal laws). The GT’s remit includes recommending adjustments and reporting to the CITDigital Executive Committee, which may in turn propose regulatory initiatives or recommend enforcement action to competent authorities. For disputes internal to the GT (e.g., member designation), standard administrative review and appeal channels within the federal administration apply; member appointments are implemented by the GT coordinator following agency indications.

Relationship to Other Instruments

The Resolution operates within the legal architecture established by Decree No. 12.308/2024 (creation of CITDigital) and is complementary to the Regimento Interno of the CITDigital Executive Committee (Resolução CITDIGITAL nº 1/2025). It also links to subsequent implementing acts that specify membership and operation, such as Portarias that set group compositions and the later Resolução CITDIGITAL nº 3/2025 (which introduced an additional representative for the Ministry of Health). The GT is a policy coordination and operational mechanism that feeds into sectoral regulators, public procurement policy, research funding decisions and national AI strategy execution: its outputs (annual plans, monitoring reports, and policy proposals) are intended to inform those complementary instruments and to align PBIA activities across the federal administration.

International Alignment

The Resolution emphasizes national coordination rather than explicit international regulatory harmonization. Nevertheless, by centralizing PBIA management in a high-level interministerial GT that includes the Ministry of Foreign Affairs, the instrument creates channels for international engagement, bilateral cooperation and alignment with global AI governance norms. Inclusion of the Ministry of Foreign Affairs supports coordination of international partnerships, technical cooperation and adherence to multilateral commitments. The GT’s structure (bringing together research funders, development banks and industry-oriented research organizations) positions Brazil to coordinate international R&D funding, participate in cross-border pilot projects and align PBIA activities with international frameworks and best practices — for example, OECD AI Principles and multilateral research initiatives — as the GT develops operational plans and recommendations.

Implementation Timeline

Sources and References