Brazil's CVM asks for evidence on its voluntary ISSB reporting regime

Brazil's securities regulator, the CVM, opened a call for evidence on 29 October on its sustainability reporting regime under CVM Resolution 193, which has been voluntary since May, the regulator said, to inform a possible regulatory impact analysis.

The call, numbered ASA/CVM 02/26, is run by the CVM's economic analysis, risk management and integrity office. It asks for data, studies, evidence and views on the report of sustainability-related financial information prepared under the standards of the International Sustainability Standards Board (ISSB). Whether an impact analysis follows, its scope and the unit that runs it will be decided by the CVM's board when it sets the 2027 regulatory agenda, the CVM said; the call comes before that analysis and does not replace it.

From a mandate to an opt-in in three years

Resolution 193 of 20 October 2023 allowed listed companies to report on the ISSB basis from financial years starting on or after 1 January 2024 and required it from those starting on or after 1 January 2026, the notice recalls. Resolutions 217 and 218 of 29 October 2024 made the Brazilian standards CBPS 01 and CBPS 02, which match IFRS S1 and IFRS S2, mandatory for listed companies from 2026. Resolutions 231 and 232 of 3 July 2025, in force since 2 January 2026, exempted smaller companies with consolidated gross revenue below BRL 500 million.

Resolution 244, approved by the board on 27 May 2026 and published on 29 May, did not revoke Resolution 193 but removed its general obligation. Listed companies, investment funds and securitisation companies may still opt in. An entity that does must declare full compliance with the CBPS and ISSB standards without reservation, publish for at least three consecutive years and obtain reasonable assurance from an independent auditor for financial years starting on or after 1 January 2026. From 1 January 2027, a listed company that chooses not to file must give management's reasons in a market notice by the date it files its annual financial statements. The notice also lists loose ends: article 4 still refers to the revoked article 2, and the text of Resolutions 217 and 218 was not changed.

Seven hypotheses and ten options

The CVM sets out seven working hypotheses that it neither endorses nor rejects. They ask whether a material information gap remains after existing disclosure rules; whether voluntary reporting falls short of a socially efficient level; whether the mandatory share of adoption lowers issuers' cost of capital by more than its compliance costs; whether the information mainly serves institutional and non-resident investors; whether costs weigh proportionally more on smaller companies; whether reasonable assurance, the three-year minimum and the full-compliance declaration deter voluntary adoption; and whether successive rule changes created costs that cannot be recovered.

Ten regulatory alternatives are listed for comment, in a list the CVM calls non-exhaustive and without a stated preference. They run from keeping the current regime and a maximally flexible voluntary regime, through keeping the voluntary regime with lighter conditions for filers that opt in (limited or optional assurance, a shorter minimum period, partial adoption), a mandate phased by company size, a uniform deferred mandate, a mandate limited to CBPS 02 without Scope 3 emissions, a mandate set by a quantitative threshold and the transfer of essential items into the reference form, to self-regulation and, at the other end, a full mandate beyond listed companies with reasonable assurance. Question 43 asks companies, auditors and consultants for first-year and recurring costs, split into data collection, systems, staff, consultants, limited and reasonable assurance, legal advice and training, with the share due to Scope 3.

What other regulators did

An annex maps 16 jurisdictions plus Brazil, from sources accessed on 8 September 2026. It cites an S&P Global survey of May 2026 in which 40 jurisdictions had adopted the ISSB standards or committed to do so, 28 of them with adoption in place and 12 planning or consulting. The CVM groups the reviews it found into two families: regulators that asked whether the regime was sufficient and went ahead with calibration, namely the United Kingdom, Australia, Japan, Nigeria and Malaysia, and those that asked whether it was excessive and moved to reduce, defer, suspend or revoke it, namely the European Union, New Zealand, Singapore, Canada, the United States and Türkiye. On Türkiye, the annex records that the Public Oversight, Accounting and Auditing Standards Authority (KGK) doubled its three size thresholds on 16 January 2026, to total assets of TRY 1 billion, net sales of TRY 2 billion and 500 employees, citing inflation.

Contributions go to asa@cvm.gov.br with the call's number in the subject line, the main text in PDF and quantitative data also in the template spreadsheet of Annex I. Section 6.1 of the notice sets the deadline at 9 February 2027, although its cover gives four months from signature and the CVM's announcement says 28 February 2027. Responses will be published in full after the deadline, and respondents are asked to declare any direct economic interest in the outcome.

The call runs alongside the CVM's call on its corporate governance report, and Brazil's entry in EM Governance Review's ISSB reporting clock notes the Resolution 244 change.