Summary
Details
- Brazil
Listed companies (companhias abertas) must prepare and disclose the report for fiscal years starting on or after 1 January 2026.
Listed companies may voluntarily adopt earlier (from 2024), subject to explicit market communication and continuity.
Investment funds and securitization companies have an opt-in path and may declare the option up to the end of the fiscal year prior to first report publication.
Deep dive
📩 Stay ahead of climate regulation and reporting shifts
Regulatory updates, reporting standards, and new climate software — distilled into one concise weekly brief for decision-makers.
Thanks for signing up. Please check your inbox to confirm your subscription.
Practical updates. Once per week.
What’s Required
1) Produce a “sustainability-related financial information” report (segregated and identified)
The regulation requires preparation and disclosure of a dedicated report based on ISSB standards, as internalized in Brazil (CBPS standards approved by CVM). The report must be clearly identified and presented separately from other entity information and the financial statements.
2) Define reporting boundary and consolidation basis
The report is prepared on the consolidated reporting entity basis; if no consolidated entity exists, it is prepared on the individual entity basis. This has implementation consequences for groups with multiple issuers and complex consolidation.
3) Decide on voluntary adoption and executethe required market communication
Resolution 193 creates an explicit voluntary adoption pathway:
Voluntary adoption allowed for fiscal years starting on or after 1 January 2024.
Listed companies must declare the option and the starting year via a market communication following the deadlines specified for 2024 and 2025 adoption tracks, including the 31 December 2025 communication deadline for 2025 adoption.
Voluntary adoption implies continuity throughout the voluntary period, so issuers should treat “opt-in” as a multi-year commitment rather than a one-off disclosure.
4) File through CVM electronic systems and meet timing rules
Resolution 193 sets minimum periodicity equal to year-end financial statements and specifies filing deadlines via CVM’s electronic system, including different timing rules for voluntary adoption, first mandatory year, and subsequent mandatory years.
5) Implement assurance readiness
The consolidated text of Resolution 193 states that the report must be subject to assurance by an independent auditor registered with CVM, aligned to applicable standards (issuers must plan for auditability, documentation retention, and internal control design to support assurance work).
Important Deadlines
Adoption: 20 October 2023 (published in DOU 23 October 2023).
Entry into force: 1 November 2023 is referenced in practitioner summaries; operationally, the rule applies through the staged adoption model.
Voluntary adoption window: fiscal years starting on or after 1 January 2024.
Mandatory adoption (listed companies): fiscal years starting on or after 1 January 2026.
Communication deadlines (selected): for voluntary adoption in fiscal year starting on or after 1 January 2025, listed companies must file a market communication by 31 December 2025.
Filing deadlines (selected):
voluntary adoption years: by the last day of the 9th month after fiscal year end (as per amended text)
first mandatory year: same date as Formulário de Referência (FRE) delivery
from the second mandatory year: within 3 months after the fiscal year end or the same date as the financial statements, whichever comes first
Current Status
In force and operational, with mandatory application for listed companies beginning with fiscal years starting on or after 1 January 2026, and amendments noted in the consolidated text (including 2024 and 2025 CVM resolutions that adjust mechanics).
Penalties for Non-Compliance
Resolution 193 is a CVM disclosure obligation. Non-compliance risk typically materializes through:
administrative proceedings for failure to disclose, late filing, or misleading/incomplete disclosure
sanctions available under CVM’s enforcement framework for issuers and administrators (which can include fines and other market supervisory measures), depending on the violation type and severity
Operationally, the highest compliance risk is not only “non-filing” but also filing that cannot be substantiated under assurance or supervisory review, creating exposure to allegations of misleading disclosure.
Examples of Known Violations
Common failure modes observed in mandatory reporting regimes and particularly likely here given ISSB complexity:
Boundary mismatch: report prepared at subsidiary level despite consolidated requirement, or inconsistent consolidation perimeter vs financial statements.
Late or missing market communication for voluntary adoption: opting in without proper disclosure by the specified cut-off dates, then attempting to file a report without having declared adoption.
Non-segregated presentation: sustainability financial report embedded in other reports without clear identification or separation.
Assurance-readiness gaps: inadequate audit trail for emissions, scenario analysis inputs, or governance statements, leading to qualified assurance or inability to obtain assurance at all.
Inconsistency with financial filings: climate-related risks are described as material in the sustainability report but not reflected in MD&A, risk factors, or financial statement notes, raising supervisory red flags.
Resources
Cut through the green tape
We don't push agendas. At Net Zero Compare, we cut through the hype and fear to deliver the straightforward facts you need for making informed decisions on green products and services. Whether motivated by compliance, customer demands, or a real passion for the environment, you’re welcome here. We provide reliable information. Why you seek it is not our concern.