Brazil’s Securities and Exchange Commission (CVM) has launched a public call for evidence on its ISSB-aligned sustainability-related financial reporting regime, examining voluntary and mandatory approaches.
Announced on October 29, 2026, ASA/CVM 02/2026 seeks input to inform a possible Regulatory Impact Analysis (AIR). Responses are due by February 28, 2027.
This does not reinstate mandatory reporting or confirm a future mandate.
Why Is CVM Reviewing the Regime?
The review concerns Resolution 193, taking account of amendments under Resolutions 219, 227, and 244. In 2026, Resolution 244 removed the general mandatory reporting obligation, retaining voluntary adoption subject to regulatory conditions.
What Is CVM Investigating?
Its working hypotheses address:
- Whether material information gaps persist despite existing disclosures.
- Whether voluntary reporting provides sufficient coverage, comparability, and credibility.
- Whether mandatory adoption’s capital-cost benefits exceed compliance costs.
- Whether usefulness is concentrated among institutional and nonresident investors.
- Whether smaller or less complex companies face proportionally higher costs.
- Whether reasonable assurance, a minimum three-year commitment, and a full-compliance declaration discourage participation.
- Whether regulatory changes created unrecoverable investments or reduced predictability.
These are questions to test—not CVM conclusions.
What Could Follow?
Options include retaining or adjusting voluntary reporting, mandatory or phased models, Reference Form integration, and non-regulatory approaches. They are non-exhaustive and do not represent CVM’s position.
CVM’s Board will determine any AIR, its scope, and the responsible unit through the 2027 Regulatory Agenda.
How Can Reporting Teams Respond?
Teams can contribute documented evidence on costs, assurance readiness, data availability, and regulatory uncertainty.
Email asa@cvm.gov.br by February 28, 2027, with subject TOMADA PÚBLICA DE SUBSÍDIOS ASA/CVM Nº 02/26. Submit the main response as PDF and quantitative data in Annex I’s editable template; answering every question is unnecessary. Annex II covers international ISSB adoption. Materials are available through the official announcement.
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