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Regulation, updated on

The regulatory map of social, environmental and climate risk.

The challenge is not knowing the regulation. It is turning regulatory requirements into opportunities and portfolio management, with evidence and an audit trail.

Informational content; does not constitute a legal opinion.

regulations and references mapped
23
in force
16
published, with a future effective date
4
proposed or voluntary
3

Count from the table below, reviewed on .

Compliance is the institution's responsibility.

ESGreen provides data, evidence and an audit trail. Each requirement below is mapped to a data point, a piece of evidence and a report.

In force
regulation published and applicable.
Published
regulation published with a future effective date.
Proposed
text under public consultation; may change in the final version.
Voluntary
adoption not mandatory as of the review date.
≈ Estimate
year estimated from an official document, with no date yet set in regulation (for the Brazilian Sustainable Taxonomy, the MRV System guidance document, with T0 = 2025).
Review date
each row shows when it was last checked. Deadlines are set by regulators and may change.

Four recent changes that alter risk and reporting routines

  • The GRSAC now comes with numbers.

    BCB Resolution 586 and BCB Normative Instruction 772, of September 3, 2026, overhaul the GRSAC report with quantitative tables starting January 1, 2027. First disclosure by S1 and S2 in 2028, with a December 2027 reference date.

  • IFRS S1/S2 reporting became voluntary for listed companies.

    CVM Resolution 244, of May 29, 2026, removed the requirement set out in CVM 193. For financial institutions, CMN 5,185 keeps the report mandatory, with reasonable assurance.

  • Rural credit now requires documented monitoring.

    CMN 5,268/2025 added to section 9 of the MCR (Rural Credit Manual) the PRODES/INPE check for vegetation clearing and remote sensing monitoring of contracts above 300 ha, “documented, auditable and assessable by the Central Bank”.

  • Rural insurance gained social and environmental restrictions.

    Since May 3, 2026, CNSP 485/2025 bars coverage for properties without an active CAR, under embargo for illegal deforestation, or belonging to producers listed in the MTE employer registry.

Regulations, deadlines and where ESGreen fits in

23 regulations and references that affect the social, environmental and climate risk of financial institutions and companies in Brazil.

Segment
Status

9 normas exibidas

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Regulations, deadlines and where ESGreen fits in. Informational content; does not constitute a legal opinion.
#RegulationWhoDeadline and statusWhat it requiresHow ESGreen helpsContent
R13 CVM Res. 193/2023 + CVM Res. 244/2026
See details for CVM Res. 193/2023 + CVM Res. 244/2026
Deadline
Voluntary. CVM 244 of May 29, 2026: voluntary reporting from fiscal year 2026; "comply or explain" from January 1, 2027
Who
Listed companies
What it requires
Voluntary IFRS S1/S2 reporting for listed companies, with a commitment of at least 3 fiscal years and assurance for adopters. For financial institutions, CMN 5,185 applies.
How ESGreen helps
IFRS S1/S2 reporting, voluntary for listed companies (CVM 193/244) and mandatory for financial institutions (CMN 5,185): value chain and counterparty data with source, date and version.
Listed companies Voluntary Voluntary. CVM 244 of May 29, 2026: voluntary reporting from fiscal year 2026; "comply or explain" from January 1, 2027 Reviewed:

Voluntary IFRS S1/S2 reporting for listed companies, with a commitment of at least 3 fiscal years and assurance for adopters. For financial institutions, CMN 5,185 applies.

IFRS S1/S2 reporting, voluntary for listed companies (CVM 193/244) and mandatory for financial institutions (CMN 5,185): value chain and counterparty data with source, date and version.
R14 Brazilian Sustainable Taxonomy (Decree 12,705/2025) and MRV System
See details for Brazilian Sustainable Taxonomy (Decree 12,705/2025) and MRV System
Deadline
Voluntary at first. Decree of October 31, 2025. The MRV System guidance document estimates, with no date yet set in regulation: Wave 1 (S1 and S2 banks, asset managers and funds, listed companies except smaller ones) and the MRV Portal in ≈2027; Wave 2 (S3 to S5, credit cooperatives, insurers, pension funds and other companies) in ≈2028; mandatory verification in ≈2029
Who
Non-financial companies, banks, asset managers and funds; then cooperatives, insurers and pension funds
What it requires
Classification of activities by CNAE and alignment indicators: PAES (companies), PAS and POVS (banks) and PIS (asset managers and funds), with verification by accredited verifiers in the mandatory phase.
How ESGreen helps
Ready for the TSB MRV System: classification by CNAE (economic activity code) and evidence per transaction and per investee.
Non-financial companies, banks, asset managers and funds; then cooperatives, insurers and pension funds Voluntary Voluntary at first. Decree of October 31, 2025. The MRV System guidance document estimates, with no date yet set in regulation: Wave 1 (S1 and S2 banks, asset managers and funds, listed companies except smaller ones) and the MRV Portal in ≈2027; Wave 2 (S3 to S5, credit cooperatives, insurers, pension funds and other companies) in ≈2028; mandatory verification in ≈2029 Reviewed:

Classification of activities by CNAE and alignment indicators: PAES (companies), PAS and POVS (banks) and PIS (asset managers and funds), with verification by accredited verifiers in the mandatory phase.

Ready for the TSB MRV System: classification by CNAE (economic activity code) and evidence per transaction and per investee.
R15 SBCE, Law 15,042/2024regulated carbon market
See details for SBCE, Law 15,042/2024
Deadline
In force, with phased implementation. Timeline still proposed in CP SEMC 1/2026: phase 1 with a monitoring plan in 2027; phase 2 in 2029
Who
Facilities emitting more than 10,000 tCO₂e/year; above 25,000, also subject to a reconciliation obligation
What it requires
Monitoring, reporting and verification of emissions per facility, with a verified annual report. Primary agricultural production excluded.
How ESGreen helps
A topic tracked in Research. Useful for banks and asset managers assessing the transition risk of clients and investees.
Facilities emitting more than 10,000 tCO₂e/year; above 25,000, also subject to a reconciliation obligation In force In force, with phased implementation. Timeline still proposed in CP SEMC 1/2026: phase 1 with a monitoring plan in 2027; phase 2 in 2029 Reviewed:

Monitoring, reporting and verification of emissions per facility, with a verified annual report. Primary agricultural production excluded.

A topic tracked in Research. Useful for banks and asset managers assessing the transition risk of clients and investees.
R16 Law 12,846/2013 + Decree 11,129/2022, art. 57, XIII
See details for Law 12,846/2013 + Decree 11,129/2022, art. 57, XIII
Who
Companies
What it requires
Integrity program with appropriate, risk-based due diligence to contract and oversee third parties, including politically exposed persons.
How ESGreen helps
Pre-assessment at contracting and continuous monitoring in third-party oversight, with restrictive lists, sanctions and ownership structure.
Content
Companies In force Reviewed:

Integrity program with appropriate, risk-based due diligence to contract and oversee third parties, including politically exposed persons.

Pre-assessment at contracting and continuous monitoring in third-party oversight, with restrictive lists, sanctions and ownership structure.
R17 Law 14,133/2021, art. 25, §4public procurement
See details for Law 14,133/2021, art. 25, §4
Deadline
In force. Large-scale contract threshold in 2026: R$261,968,421.04 (Decree 12,807/2025)
Who
Public sector suppliers in large-scale contracts
What it requires
Implementation of an integrity program within 6 months of contract signing.
How ESGreen helps
Dated evidence of supply chain due diligence.
Public sector suppliers in large-scale contracts In force In force. Large-scale contract threshold in 2026: R$261,968,421.04 (Decree 12,807/2025) Reviewed:

Implementation of an integrity program within 6 months of contract signing.

Dated evidence of supply chain due diligence.
R20 EUDREU Regulation 2023/1115, as amended
See details for EUDR
Deadline
Published. December 30, 2026 for large and medium operators; June 30, 2027 for micro and small operators. Deforestation cutoff: December 31, 2020
Who
Exporters of soy, cattle, coffee, cocoa, palm oil, rubber and wood to the European Union, and those who finance them
What it requires
Due diligence with proof of zero deforestation and geolocation of production areas.
How ESGreen helps
Checks for embargoes, deforestation and territorial overlaps by CNPJ, CPF and property of producers and suppliers.
Exporters of soy, cattle, coffee, cocoa, palm oil, rubber and wood to the European Union, and those who finance them Published Published. December 30, 2026 for large and medium operators; June 30, 2027 for micro and small operators. Deforestation cutoff: December 31, 2020 Reviewed:

Due diligence with proof of zero deforestation and geolocation of production areas.

Checks for embargoes, deforestation and territorial overlaps by CNPJ, CPF and property of producers and suppliers.
R21 CBAMEuropean Union
See details for CBAM
Deadline
In force. Definitive regime since January 1, 2026; certificate sales from Feb 2027
Who
Exporters of steel, iron, aluminum, cement and fertilizers, among others
What it requires
Carbon cost embedded in European imports of these products.
How ESGreen helps
A topic tracked in Research. Useful for assessing the transition risk of exporting clients and investees.
Exporters of steel, iron, aluminum, cement and fertilizers, among others In force In force. Definitive regime since January 1, 2026; certificate sales from Feb 2027 Reviewed:

Carbon cost embedded in European imports of these products.

A topic tracked in Research. Useful for assessing the transition risk of exporting clients and investees.
R22 CSDDDEU Directive, after Omnibus I
See details for CSDDD
Deadline
Published. Applies from July 26, 2029
Who
Companies with more than 5,000 employees and €1.5 billion in revenue, and their Brazilian suppliers
What it requires
Human rights and environmental due diligence across the chain of activities, passed on to suppliers through questionnaires.
How ESGreen helps
Supplier monitoring and Evidence Assessment to answer European clients' questionnaires.
Content
Companies with more than 5,000 employees and €1.5 billion in revenue, and their Brazilian suppliers Published Published. Applies from July 26, 2029 Reviewed:

Human rights and environmental due diligence across the chain of activities, passed on to suppliers through questionnaires.

Supplier monitoring and Evidence Assessment to answer European clients' questionnaires.
R23 LGPDLaw 13,709/2018
See details for LGPD
Who
All organizations that process personal data
What it requires
A legal basis for each purpose, an appointed data protection officer and handling of data subject rights.
How ESGreen helps
Appointed data protection officer (DPO), legal bases and a channel for data subjects, described on the Trust page.
All organizations that process personal data In force Reviewed:

A legal basis for each purpose, an appointed data protection officer and handling of data subject rights.

Appointed data protection officer (DPO), legal bases and a channel for data subjects, described on the Trust page.

Reviewed: September 30, 2026. Deadlines set by regulators and subject to change. ≈ = estimate, with no date set in regulation. Proposed = text under public consultation.

Deadlines may change. The direction won't.

Every requirement in this table moves in the same direction: from drafting to consultation, from publication to entry into force. And the evidence each one will demand needs a track record, which cannot be built overnight.

Status of social, environmental and climate risk rules
  1. Under development

    Foreseen in an official document, with no date set in a rule yet.

    • TSB: MRV Portal and first wave (S1 and S2 banks, asset managers, funds and listed companies) TSB
    • TSB: second wave, with credit cooperatives, insurers and pension funds TSB
    • TSB: mandatory verification by accredited verifiers TSB
  2. Proposed

    Under consultation or with a proposed timeline. The direction is already set.

    • SUSEP: new sustainability rules, with climate scenarios and ESG in underwriting SUSEP 666
    • SBCE: monitoring plan for regulated facilities SBCE
  3. Published

    Rule published. The requirement takes effect in stages.

    • EUDR: zero-deforestation due diligence for large and medium-sized operators EUDR
    • New GRSAC: quantitative tables in the report BCB 586
    • CMN 5,268: PRODES check for properties of up to 4 fiscal modules CMN 5.268
    • CVM 244: “comply or explain” model CVM 193/244
    • CBAM: sale of certificates CBAM
    • Previc 728: ESG plan and double materiality, starting with S1 and S2 entities Previc 728
    • EUDR for micro and small operators EUDR
    • New GRSAC: first quantitative disclosure, starting with S1 and S2 BCB 586
    • CMN 5,185: IFRS S1/S2 reporting for S3 institutions CMN 5.185
    • CSDDD: supply chain due diligence by large European companies, passed on to suppliers CSDDD
  4. In force

    Already applies. Evidence must be kept up to date.

    • CMN 5,185: IFRS S1/S2 reporting with reasonable assurance for publicly traded institutions and S1 and S2 leaders CMN 5.185
    • CVM 244: voluntary IFRS S1/S2 reporting for listed companies CVM 193/244
    • CNSP 485: socio-environmental restrictions in rural insurance CNSP 485
    • CMN 5,268: PRODES check and remote monitoring in rural credit CMN 5.268
    • CBAM: definitive regime for European imports CBAM

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Frequently asked questions

Short answers to the most common questions.

Still have questions? Talk to an expert

Does ESGreen guarantee my institution's compliance with these regulations?

No. Compliance is the institution's responsibility. ESGreen provides data, evidence and an audit trail that support compliance: every data point with source, date and version. ESGreen does not certify, does not issue assurance and does not provide legal opinions.

What changes in the GRSAC report with BCB Resolution 586?

Published on September 3, 2026, BCB Resolution 586 and BCB Normative Instruction 772 replace BCB Resolution 139 and IN 153 and take effect on January 1, 2027. The report now includes quantitative tables, with counterparties classified by CNAE (economic activity code). S1 and S2 make their first disclosure in 2028, with a December 2027 reference date; S3 follows from the December 31, 2028 reference date.

Is IFRS S1/S2 reporting mandatory in Brazil?

It depends on who reports. For publicly traded financial institutions and S1 and S2 conglomerate leaders, CMN Resolution 5,185 makes the report mandatory from fiscal year 2026, with reasonable assurance; for S3, from 2028. For listed companies in general, CVM Resolution 244, of May 29, 2026, made reporting voluntary.

What did CMN Resolution 5,268 change in rural credit?

The rule requires a PRODES/INPE check for vegetation clearing after July 31, 2019, since April 2026 for properties above 4 fiscal modules and from January 2027 for the others. For contracts above 300 ha, since March 1, 2026, it requires remote sensing monitoring that is documented, auditable and assessable by the Central Bank.

What is the Brazilian Sustainable Taxonomy MRV System and when does it become mandatory?

It is the Monitoring, Reporting and Verification system of the TSB, established by Decree 12,705/2025. Adoption is voluntary at first. The MRV System guidance document estimates the MRV Portal and Wave 1 around 2027, Wave 2, with credit cooperatives and insurers, around 2028, and mandatory verification by accredited verifiers around 2029. These are estimates, with no date yet set in regulation. The sequence, however, is already defined: institutions that classify transactions by CNAE starting now will reach the mandatory phase with a track record.

How often is this map reviewed?

Each row shows the date of its last review, and the overall date appears at the top of the page. Regulations under public consultation appear as proposed until the final text is published. The status of each milestone in the table is reviewed by the ESGreen team and does not change automatically with the calendar: if a regulator postpones a deadline, the milestone stays where it is until the review.

How we assess

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