Of the list, 68 set 18 as the minimum age for someone to be tried as an adult, while eight use lower ages: Albania, Andorra, Armenia, Azerbaijan, Haiti, Lithuania, Poland and Portugal.
The Brazilian National Congress debates reducing the age of criminal responsibility in Brazil, now at 18 years. Discussions took place in the Chamber of Deputies and the Senate, with parallel proposals.
Last week, the president of the Senate, Davi Alcolumbre (União-AP), decided to wait for the Chamber to vote on the matter first.
The opposition wants a general reduction from 18 to 16 years and to 14 years in cases of heinous crimes, such as murder.
President Lula (PT) defended the reduction of the age of criminal responsibility to 16 years for heinous crimes. It was the first time that the PT member, then a candidate for re-election, spoke about the topic in a forceful way, when answering a question from journalist Renata Lo Prete, during an interview with TV Globo in the second round of the election.
In Congress, senator Camilo Santana (PT-CE), government leader, presented a proposal to reduce the age from 18 to 16 in the case of heinous crimes. This is the proposal that Lula said he supports.
Situation in the world
None of the 19 G20 countries analyzed by Unicef have the age of criminal responsibility under 18. In Latin America, the scenario is similar: of the 20 countries surveyed, only Haiti has the age of majority at 16.
The Unicef survey was carried out between August and September 2026 and analyzed the legislation of countries such as the United States, China, Germany, Argentina and Japan, in addition to Brazil.
The G20 functions as the world's main economic club, bringing together 19 of the most influential countries on the planet, the European Union and the African Union. Together, these members control 85% of all wealth produced in the world (GDP) and 75% of global trade.
In the United States, for example, the variation occurs in some states of the country -- as state legislation there may be different from federal legislation. In the Netherlands, this happens to those who are 16 or 17 years old, when a judge considers that the crime is serious enough or that the personality of the perpetrator allows him to respond as an adult for the crime committed.
The CRIN study with European countries is from 2019 and was updated by the g1 report based on the laws of each country listed.
Two different concepts are taken into account:
the age of criminal responsibility, which defines the age at which a person can be judged as an adult;
and the age of criminal liability, when adolescents can already be held accountable for their actions, but in a system specific to their age group.
In Brazil, the age of criminal responsibility is 18 years old, while the responsibility of adolescents begins at 12 years old, the age at which they can comply with socio-educational measures for infractions.
Brazil among countries that hold teenagers responsible earlier
According to Unicef, all 19 G20 countries analyzed have separate justice systems for adults and adolescents who commit infractions. In seven of them, there are exceptions that allow teenagers to be sent to the adult criminal system, but the general rule is that they be tried by juvenile justice.
Brazil is among the countries that begin to hold teenagers responsible earlier. In the G20, the age of 12 is also adopted by South Africa, Canada, Indonesia, Mexico and Türkiye. In countries such as Germany, Argentina, Italy and Japan, accountability begins at age 14.
In Albania, accountability occurs at age 16 for criminal misdemeanors, but it can be done at age 14 if the person commits more serious crimes, such as murder.
France has liability from the age of 13, but the person can respond before that if the Court considers that the perpetrator of the crime understood what would be done and, even so, did it.
In Latin America, Brazil is also among the countries with the lowest age of liability. In addition, Costa Rica, El Salvador, Ecuador, Honduras, Mexico and Panama establish 12 years as the minimum age. In Argentina, Bolivia, Chile, Colombia, Paraguay, Peru and Venezuela, for example, the limit is 14 years.
For Joaquin Gonzalez-Aleman, Unicef representative in Brazil, reducing the age of criminal responsibility could have negative impacts on Brazil.
"Today, teenagers who commit criminal acts are held responsible through the Socio-Educational System, in units separate from adults, with measures that combine accountability with education and social reintegration. Taking them to the adult prison system can expose them to more structured criminal networks and increase the risk of recruitment by organized crime", he says.
According to the expert, data from the National Council of Justice (CNJ) show that "reentry into the prison system among adults is almost double that observed among adolescents in the Socio-Educational System, which reinforces the importance of investing in responses capable of reducing recidivism."
"Here we start talking not only about impacts for teenagers, but for society as a whole: if teenagers move to the adult system, with the reduction of the age of criminal responsibility, it is likely that their recidivism rates will also increase and that society will suffer from more crimes", he says.
According to Gonzalez-Aleman, the reduction could also impact Brazil on the international stage.
"The current rule, of the age of criminal responsibility at 18 years old, is in line with the internationally predominant standard: none of the 19 G20 countries analyzed by Unicef establishes, as a general rule, an age below 18 years old. A reduction would move Brazil away from this standard and from international evidence on juvenile justice appropriate to the age and development of adolescents."
Changes in legislation
The survey also highlights recent changes in legislation in other countries. In Argentina, an amendment approved in February 2026 reduced the age of criminal liability from 16 to 14 years. The age of criminal responsibility, however, remained at 18 years.
In the United States, states such as New York, Connecticut and North Carolina took the opposite path: they changed their legislation so that teenagers aged 16 and 17, who previously could be tried as adults, would now face juvenile justice: "They saw that [the measures] did not produce the expected results", says the Unicef representative.
According to Unicef, the changes like those in American states occurred after assessments that treating teenagers as adults before the courts did not contribute to reducing crime or improving public safety.
“The richest countries in the world, where around 60% of the world's population live, agree that it is possible to hold a teenager responsible without treating him as an adult,” said Joaquin Gonzalez-Aleman.
For the representative, the separation between the adult and juvenile justice systems allows adolescents to have access to education, health and social assistance, with the aim of promoting their reintegration into society and preventing recidivism.
Unicef also warns that placing teenagers and adults in the same prison system can have the opposite effect to what was expected, bringing young people closer to criminal organizations and breaking ties with school, family and the community.
"Holding responsibility for teenagers who commit criminal acts is necessary. But to do so, it is not necessary to treat them as adults," said Gonzalez-Aleman.
Criminal majority vs accountability
In Brazil, adolescents between 12 and 17 years old who commit infractions may be subjected to socio-educational measures, provided for in the Child and Adolescent Statute (ECA). These include warning, obligation to repair the damage, provision of services to the community, assisted release, semi-freedom and hospitalization.
Therefore, having a lower age of liability does not necessarily mean having a lower age of criminal responsibility. It is this distinction that, according to Unicef, explains why Brazil holds teenagers responsible from the age of 12, but maintains the age of criminal responsibility at 18.
According to Joaquin Gonzalez-Aleman, from Unicef, the minimum age of criminal responsibility in Brazil is below the most current recommendation of the Committee on the Rights of the Child, which is 14 years old.
"This guideline, updated in 2019, is justified by the different stage of physical and psychological development of children and adolescents, and is observed by almost 40% of G20 and Latin American countries. It is a legitimate debate for the country, but it is important not to confuse it with the age of criminal responsibility: it is one thing to define when a teenager can be held responsible; another is to define when they should start to be treated as an adult by the criminal system", he explains.
