Brazil's Climate Disclosure Rules: What You Need to Know

Brazil climate disclosure at a glance

Brazil's securities regulator, the Comissão de Valores Mobiliários (CVM), made climate and sustainability reporting under the CBPS standards (the Brazilian adoption of IFRS S1 and IFRS S2) voluntary for listed companies through Resolution 244 of 29 May 2026, revoking the mandate that was due to apply from financial year 2026. From 1 January 2027, a listed company that does not file the report must publish a notice explaining why, and a company that files for financial year 2026 onward reports for at least three consecutive years, with reasonable assurance.

How Brazil got here: from mandate to comply-or-explain

Resolution 193, issued on 20 October 2023, offered voluntary reporting from financial year 2024 and made reporting mandatory for listed companies from financial year 2026. In October 2024 the CVM approved CBPS 01 and CBPS 02, the Portuguese-language standards issued by the Brazilian Sustainability Pronouncements Committee, and in March 2025 Resolution 227 made them the basis of the Brazilian report.

On 29 May 2026, Resolution 244 revoked Article 2 of Resolution 193, the mandate, with effect for financial years beginning on or after 1 January 2026. In its place, among other changes, the CVM set three rules: a comply-or-explain notice for listed companies that do not file, a three-year minimum once a company opts in, and a market notice before a company stops. On 27 August 2026 the CVM published guidance on the amended rule, Ofício-Circular 2/2026.

What Brazil's climate disclosure rules require

A company that opts in publishes a sustainability-related financial information report prepared in full under CBPS 01 and CBPS 02, with an explicit and unreserved statement of compliance, filed on the CVM's electronic system.

• CBPS 01 (General Requirements): the Brazilian adoption of IFRS S1. The company reports material sustainability-related risks and opportunities on the four pillars of governance, strategy, risk management, and metrics and targets.

• CBPS 02 (Climate-related Disclosures): the Brazilian adoption of IFRS S2, covering climate-related transition and physical risks, scenario analysis, industry-based metrics, and gross Scope 1, Scope 2 and Scope 3 greenhouse gas emissions.

• The Greenhouse Gas Protocol as the measurement standard: CBPS 02 follows IFRS S2 paragraph 29(a)(ii): emissions are measured under the Greenhouse Gas Protocol Corporate Accounting and Reporting Standard (2004) unless a jurisdictional authority or exchange requires another method, with a first-year relief for companies that used a different method the year before.

Resolution 193 also requires the report to be clearly identified, presented separately from the financial statements, and prepared for the consolidated reporting entity (or the individual entity where there is no group).

Partial use of the standards counts. Ofício-Circular 2/2026 states that a report describing itself as "aligned with", "based on" or "inspired by" the CBPS or ISSB standards falls under Resolution 193 and must meet all of its requirements. A report prepared under the Global Reporting Initiative (GRI) standards sits outside the rule; the CVM reviews case by case where such a report is tied to the financial statements, signals use of the CBPS or ISSB standards and does not name its framework.

Filing deadlines: in the first year a company files under the current regime, the report is due on the same date as its Reference Form (Formulário de Referência). From the second year, it is due within three months of year-end or with the annual financial statements, whichever comes first.

Who is in scope

Every publicly held company registered with the CVM decides whether to file, and from 1 January 2027 a decision to skip the report is itself disclosed.

Listed companies (companhias abertas): a company that does not file publishes a market notice explaining management's reasons by the date it files its annual financial statements with the CVM. The CVM's guidance suggests covering the criteria behind the decision, the relevance of the information, the obstacles to preparing the report and any preparation under way, and warns that generic explanations that leave the reasoning unclear reduce the notice's usefulness.

Companies that opt in: a company reporting for a financial year beginning on or after 1 January 2026 publishes for at least three consecutive years. To stop, it announces the decision in a market notice by the filing date of the annual financial statements for the year before the first year it will skip.

Earlier voluntary adopters: companies that opted in under the previous rules, for financial years 2024 or 2025, are free to stop without the three-year commitment, unless they file for financial year 2026 onward.

Supply-chain reach: a Brazilian group that reports discloses Scope 3 from its second reporting year, and Scope 3 covers the emissions of its suppliers, logistics providers and farm-level producers.

Key dates and milestones

First-year reliefs in the standards cover comparatives, Scope 3, a climate-only report and publication after the financial statements. Companies that opted in under the earlier rules can extend them to financial year 2026, disclosing that this departs from the standards.

Why this matters beyond Brazil

1. Supply-chain reach into global food and commodity chains. Brazilian agribusiness, pulp and mining groups supply companies that report Scope 3 under the EU's European Sustainability Reporting Standards and under ISSB-based rules in the UK, Japan, Singapore and Australia. In our experience those buyers ask for supplier-specific emissions whatever Brazil's own rules require, so the same Scope 3 supplier engagement data serves both. For farm-sourced products, that data includes land emissions and removals.

2. Investor visibility through comply-or-explain. From 2027, investors see which listed companies file and which explain why they do not. In our view, a company that has measured its Scope 1, Scope 2 and Scope 3 emissions is free to choose either path on its own timetable.

3. A domestic carbon market is coming. Law 15.042 of 11 December 2024 created the Brazilian Emissions Trading System, which requires monitoring plans and annual emissions reports from installations above 10,000 tCO2e a year, and allowance reconciliation above 25,000 tCO2e (thresholds the system's managing body can raise), on a phased start. Operators need a corporate carbon footprint that ties installation data to group totals.

How companies should prepare

Filing and explaining both start from the same emissions data.

• Establish your greenhouse gas inventory on the GHG Protocol. Scope 1 and Scope 2 across every consolidated entity, measured under the 2004 Corporate Standard, form the base of a CBPS 02 report and feed the monitoring an installation needs under the emissions trading system.

• Map your value-chain exposure. Identify which overseas customers report Scope 3, and which categories dominate your own inventory.

• Build assurance-ready processes early. Reports for financial year 2026 onward carry reasonable assurance, the higher level. Methodology documentation, source-data traceability and review controls need to be in place during measurement, so every figure answers the auditor's question: where did this number come from?

• Build on the frameworks you already use. Companies reporting under GRI, CDP or the Brazilian GHG Protocol Programme already hold much of the data. The new work is the financial-materiality lens of CBPS 01, scenario analysis and industry-based metrics.

Your first climate audit

Preparing for reasonable assurance under Resolution 193? Download Your First Climate Audit: A Practical Guide for a step-by-step walkthrough of what assurance providers ask for and how to get your data ready.

How Terrascope can help

Terrascope's AI-powered platform helps companies operating in Brazil and across the Americas move from baseline emissions data to audit-ready disclosures, including Dyno Nobel, the explosives manufacturer with operations across the Americas that achieved limited assurance over its global Scope 1 and 2 emissions one year ahead of Australia's mandatory reporting deadline and is extending to reasonable assurance of Scope 1 and 2 in 2026.

• Scope 1, 2, and 3 emissions measurement. Integrations pull emissions data from your source systems monthly, so your inventory stays current across every consolidated subsidiary and Scope 3 category.

• Audit-ready reporting. Audit Trail makes every figure traceable from data entry to disclosure, with assurance-provider access built in, so your CVM-registered auditor works from evidence that meets a reasonable assurance standard.

• Supply-chain intelligence. Analytics shows you where your Scope 3 hotspots sit, so overseas customer requests and your CBPS 02 inventory draw on one dataset.

• Multi-framework alignment (Climate reporting). ISSB Reporting drafts your CBPS 01 and CBPS 02 disclosures from your measured data, reviewed by your team, ready to file with the CVM.

Frequently asked questions

Speak to an expert

Are you ready to get ahead of Brazil's CVM Resolution 193 requirements? Speak to a Terrascope expert and see how we help companies move from baseline emissions data to audit-ready disclosures.