Summary
Details
- Brazil
BCB-licensed financial institutions allocated to S1–S4 must publish the GRSAC report.
Conditional flexibility:
Credit cooperative systems may publish a unified report under specified conditions (centralized risk and capital management structures and consistent duties/responsibilities).
Some content (templates for indicators and opportunities) is optional, but governance/impact/process disclosure is core.
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What’s Required
1) Determine applicability: S1–S4 institutions must publish
BCB Resolution 139 applies to financial institutions and other BCB-licensed entities allocated to segments S1, S2, S3, and S4 (as defined in CMN segmentation rules) and requires them to publish the GRSAC report.
2) Publish the report on a prudential conglomerate consolidated basis
The report must be prepared on a consolidated basis, including all institutions in the same prudential conglomerate. This means disclosure must reflect group-wide exposures and governance rather than isolated entities.
3) Minimum content: governance, impacts, processes
The GRSAC report must contain information related to social, environmental, and climate-related risks, including:
governance of risk management and responsibilities of decision-making bodies (board, senior management)
real and potential impacts of those risks on business strategy and on risk and capital management under different scenarios across short, medium, and long term
processes for managing these risks
4) Optional disclosures and standardized templates
The resolution makes certain disclosures optional and structures them via templates, including:
MEM template for indicators used in risk management
OPO template for business opportunities associated with social, environmental, and climate issues
Templates and layouts are established in supporting instruments and documents, including standardized tables that specify qualitative and quantitative disclosures and methodological descriptions.
5) Publication control and corrections
If inconsistencies are identified, the report must be immediately updated and republished. The corrected version must be made available for five years from the date of republication and must explicitly indicate that it is a correction.
Important Deadlines
Adoption: 15 September 2021.
Cadence: annual publication expectation is reflected in official and practitioner descriptions of the GRSAC reporting duty, and templates specify annual frequency for certain tables.
Correction timing: immediate update and republication upon identification of inconsistencies, with five-year availability of the corrected version.
Current Status
In force and embedded in the prudential sustainability framework, the Central Bank has also pursued consultation on adjustments to Resolution 139, indicating active supervisory evolution of disclosure requirements.
Penalties for Non-Compliance
As a BCB prudential disclosure requirement, enforcement typically occurs through supervisory review and administrative processes for:
failure to publish
late publication
materially inaccurate or misleading disclosures
failure to correct known inconsistencies (a specific duty in the resolution)
Sanctions can include administrative measures under the Central Bank’s supervisory powers. The most practical compliance exposure is “defensible disclosure”: institutions must be able to evidence claims made about scenario analysis, governance structures, and indicators.
Examples of Known Violations
Common observed breakdowns in prudential disclosure regimes that fit GRSAC design:
Governance overstatement: report claims board oversight but cannot show minutes, mandates, or regular reporting, creating a misrepresentation risk.
Scenario analysis that is not reproducible: narrative references scenarios, but the institution lacks documented criteria, assumptions, and model governance required to defend the analysis.
Template non-conformance: quantitative indicators reported without methodology descriptions, or inconsistent use of standardized tables.
Inconsistency not corrected: errors are discovered internally or flagged externally, but the institution delays republication, violating the immediate update duty.
Conglomerate boundary errors: report excludes certain entities within the prudential conglomerate, undermining consolidated disclosure.
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