Brazil: Board of Directors of the National Data Protection Authority upheld order banning Tools for Humanity from offering financial incentives in exchange for biometric data

On 6 August 2025, the Board of Directors of the National Data Protection Authority (ANPD) upheld its ban on Tools for Humanity (TFH) offering financial incentives in exchange for biometric data. The order suspended any form of financial compensation for World IDs created through iris collection in Brazil, citing two main concerns, namely that monetary rewards could undermine genuine consent and that insufficient information about data processing compromised the ability of individuals to give informed consent. The technical note on the vote highlighted that financial incentives could exert undue influence, particularly on vulnerable individuals, and stressed that biometric data processing carries irreversible risks. In response, TFH proposed a new business model in which individuals verifying their World ID would no longer receive direct payments. Instead, verified users could earn rewards by referring others who completed verification. The ANPD determined that this referral scheme still placed financial incentives at the centre of the process, continuing to threaten the freedom and informed nature of consent. The proposal was rejected, and the ban remains in effect.