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Bill N. 4675/25 in Brazil uses the term "digital markets" 83 times throughout 13 pages of text. It does not define it once. This omission is not merely a technical oversight; it lies at the heart of a profound regulatory challenge. Brazil is currently debating a shift from a reactive (ex post) competition regime to a preventive (ex ante) framework designed to target "systemically relevant actors". Yet, as Bill 4.675/2025 moves through the legislative process at a rapid pace,

Brazil's Digital Markets Bill targets Big Tech. But the evidence from Europe suggests that the companies most exposed to its collateral effects may be the smallest ones. When Brazil's government introduced Bill 4,675/2025, the public debate quickly centered on a familiar cast of characters: Alphabet (Google), Apple, Meta, Amazon, Microsoft. The political framing was unmistakable; this was regulation designed to rein in global digital giants. Yet a closer look at how similar

Has the Brazilian competition defense framework really failed to the point of requiring a profound structural reform? The Administrative Council for Economic Defense's (CADE) track record suggests the opposite. As CADE’s president stated, commenting on a recent interview about its antitrust enforcement in the digital era, " [t]his we already do, [and] we have done it very well. We have cases today that are considered references in the world ". [1] The General Superintendenc

A New Regulatory Regime Historically, competition law enforcement has operated in a reactive manner, relying on ex post interventions – those that occur after the fact. Under this model, regulatory authorities act as investigators, analyzing specific conduct only once it has already taken place . The goal is to gather concrete evidence of market harm before imposing any applicable penalties or sanctions. [1] In what is commonly referred to as “digital markets” – a contest