Brazil's CVM Opens Consultation on ISSB Sustainability Reporting Rules

Brazil's Securities and Exchange Commission (CVM) has launched a public consultation to evaluate the country's sustainability-related financial disclosure framework, following changes to mandatory reporting requirements earlier in 2026. Announced on 29 October, Public Consultation Notice ASA/CVM 02/2026 seeks evidence on the effectiveness, costs and benefits of reporting aligned with standards issued by the International Sustainability Standards Board (ISSB). The findings may inform a future Regulatory Impact Analysis (RIA).

 

The consultation concerns the framework established under CVM Resolution 193, which was subsequently amended by Resolutions 219, 227 and 244. In 2026, Resolution 244 removed the general requirement for mandatory sustainability reporting, retaining voluntary adoption under specified conditions. CVM is now examining whether voluntary disclosures provide sufficient material information for investors and whether mandatory reporting could improve comparability and credibility while potentially lowering companies' cost of capital.

 

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The regulator is also assessing compliance costs, particularly for smaller companies, and whether existing voluntary reporting conditions discourage participation. These include reasonable assurance requirements, a minimum three-year reporting commitment, and a declaration of full compliance with applicable standards. Other issues under consideration include the usefulness of sustainability disclosures to institutional and international investors, and whether successive regulatory changes have created unrecoverable compliance costs or reduced regulatory predictability.

 

Potential regulatory approaches include maintaining the current voluntary framework, modifying participation requirements, introducing phased or differentiated mandatory reporting, incorporating sustainability disclosures into existing corporate reporting documents, or adopting self-regulatory solutions. CVM has emphasized that these are options for evaluation rather than proposed regulatory changes. Stakeholders can submit evidence until 28 February 2027. Any decision to conduct a formal RIA, including its scope, will be considered during preparation of CVM's 2027 Regulatory Agenda.

 

Source: Securities and Exchange Commission (CVM)