The Securities and Exchange Commission of Brazil (Comissão de Valores Mobiliários, or CVM) has launched a public call for input regarding the reporting framework for sustainability-related financial information aligned with International Sustainability Standards Board (ISSB) standards. Issued by the Economic Analysis, Risk Management and Integrity Advisory (ASA), Call for Input ASA/CVM 02/2026 seeks empirical data and stakeholder feedback to evaluate future regulatory options following recent rule changes that made disclosures voluntary.
Regulatory Context and Impact Analysis
The initiative aims to expand the empirical foundation for evaluating the disclosure regime established under CVM Resolution 193, accounting for modifications introduced by CVM Resolutions 219, 227 and 244. In 2026, CVM Resolution 244 removed the general mandatory reporting requirement for ISSB-aligned sustainability disclosures, maintaining them on a voluntary basis under specified regulatory conditions.
This public consultation precedes any potential formal Regulatory Impact Analysis (RIA) process and does not replace it. The CVM Board will determine whether to perform an RIA, as well as its scope and responsible organisational unit, when preparing the 2027 Regulatory Agenda.
Hypotheses Under Examination and Regulatory Options
The consultation seeks evidence to test several working hypotheses. Key questions include whether a deficit of material sustainability disclosures persists despite existing accounting obligations, whether voluntary reporting fails to achieve efficient levels of comparability and credibility, and whether mandatory adoption reduces issuers' aggregate cost of capital by an amount exceeding compliance costs.
Further hypotheses examine whether the utility of disclosures is concentrated among institutional and non-resident investors, whether compliance costs fall disproportionately on smaller or less complex companies, and whether requirements such as reasonable assurance, a three-year minimum commitment and full compliance statements reduce voluntary uptake. The CVM is also testing whether successive regulatory shifts created sunk costs and affected regulatory predictability.
Alongside these hypotheses, the CVM is evaluating regulatory alternatives including maintaining current rules, adjusting voluntary conditions, adopting phased mandatory models, integrating disclosures into the Reference Form (Formulário de Referência), and non-normative or self-regulatory solutions. The regulator noted that these hypotheses and listed alternatives do not indicate a preference or definitive conclusions.
Participation Guidelines and Deadlines
Stakeholders can submit evidence and market views to [email protected] with the subject line 'TOMADA PÚBLICA DE SUBSÍDIOS ASA/CVM Nº 02/26' until 28 February 2027.
Submissions require a primary text in PDF format, while quantitative data should be provided using the editable template in Annex I of the call for input. CVM clarified that respondents are not required to answer all consultation questions.
