A Deadline Extension That Matters More Than It Sounds
On July 27, 2026, Brazil's telecom regulator Anatel extended the comment deadline for Tomada de Subsídios nº 3/2026 — its market review of the machine-to-machine (M2M) and Internet of Things (IoT) ecosystem — from late July to September 13. The agency's Competition Superintendence said the extra six weeks responded to industry requests citing "the technical complexity of the subject matter and the need for additional time to analyze the questions submitted to the consultation." Alongside the extension, Anatel hosted a technical workshop, "Desenvolvimento do Ecossistema M2M/IoT no Brasil," on August 13 at its Brasília headquarters, drawing telecom operators, banks, energy and sanitation utilities, and connected-device suppliers to weigh in on device connectivity, smart cities, connected vehicles, financial-services applications, and public-service uses of IoT.
A deadline extension is not, on its face, news. But in this case it signals something more consequential: Anatel choosing to slow down a rulemaking process that industry warned could misfire if rushed.
Why the File Was Opened
Anatel opened the underlying review on June 8, 2026, after noticing what its own announcements describe as rising litigation over IoT billing values, exclusivity clauses, and access to M2M connectivity technologies. Much of that friction traces back to the 2025 revision of Brazil's General Competition Goals Plan (PGMC), formalized in Resolução Anatel nº 783/2025, which governs how mobile virtual network operators (MVNOs) — a business model many IoT resellers depend on — access wholesale capacity from Claro, TIM, and Vivo. Anatel's own MVNO regulatory page confirms that authorization and credentialing under this framework, set by Resolução nº 777/2025, currently rest on general Personal Mobile Service rules with no IoT-specific carve-out — which is precisely the gap TS 3/2026 is meant to fill.
The Case for Regulatory Concern
The strongest argument for intervention is a real one. Brazil's roaming rules treat any device that stays outside its "home" network for more than 90 consecutive days as engaged in prohibited permanent roaming, triggering fines or contract termination. That rule was written for human subscribers who eventually go home. A smart water meter, an agricultural soil sensor, or a card-payment terminal often never does — it is installed once and left running for years. Applied literally, the same anti-abuse mechanism designed to stop SIM-card arbitrage could instead punish routine IoT deployment. Independent IoT resellers also have a legitimate complaint: if MVNOs remain outside PGMC's regulated wholesale-pricing regime, incumbent carriers retain leverage to impose exclusivity terms that squeeze smaller connectivity providers out of the M2M supply chain. These are not manufactured grievances — they're the reason Anatel's board itself flagged the issue.
Anatel's Response: Wait for the Data
That's exactly what happened on August 6, 2026, when Anatel's board considered a reconsideration request tied to the PGMC roaming rules and voted to postpone judgment for 90 days rather than rule on the spot. Board member Alexandre Freire put it plainly: applying permanent-roaming rules "indiscriminately" to IoT and M2M devices "may produce effects different from those expected by regulation." Instead of resolving the question in isolation, the board explicitly tied its decision to TS 3/2026, directing staff to consolidate the consultation's findings before returning with a segment-specific assessment.
Why This Restraint Is the Right Call
Brazil's M2M and IoT connections reached roughly 30 million by mid-2026 — about 11% of all mobile connections nationwide — and the segment (combined with point-of-sale terminals) grew to nearly 58 million lines by June, adding over a million connections that month alone and accounting for roughly 70% of the mobile market's net new activity. That is not a niche corner of telecom; it is the fastest-growing layer of Brazil's connectivity infrastructure, spanning smart meters, logistics fleets, and — as Chinese automakers redirect record EV export volumes toward Brazil alongside Thailand and the Gulf — a rapidly expanding connected-vehicle fleet that will need low-friction, standardized M2M links rather than rules built for human roaming abuse.
Imposing a blunt, retrofitted roaming penalty on that infrastructure before understanding its actual usage patterns risks disconnecting legitimate deployments, not curbing arbitrage. Anatel already has ex-post tools — competition-law enforcement and case-by-case dispute resolution — to address genuine exclusivity abuse without freezing the whole market under premature ex-ante rules. Gathering the workshop's cross-industry input and giving the Superintendência de Competição until September 13 to synthesize contributions is proportionate, not dilatory.
The Caveat
None of this excuses indefinite delay. The MVNO wholesale-access gap and exclusivity disputes are real, and Anatel should resolve them on a fixed clock rather than let extensions become a standing excuse for inaction. The value of this pause lies specifically in its boundaries: a hard September 13 deadline and a 90-day diligência window, not an open-ended review. If Anatel uses that window to write IoT-native rules instead of stretching a framework built for human subscribers over sensors and terminals, Brazil's connected-device economy will be better served than by a faster, cruder fix.