Brazil's Securities and Exchange Commission, CVM, has launched a public call for input to evaluate its corporate governance reporting framework for publicly traded companies.
Scope and Regulatory Context
The Securities and Exchange Commission of Brazil, through its Advisory for Economic Analysis, Risk Management and Integrity, released Public Call for Input ASA/CVM No. 01/26. The initiative targets the disclosure regime for publicly held companies, focusing on the Corporate Governance Report governed by Annex D of CVM Resolution 80. Scheduled under CVM's 2026 Regulatory Agenda, the call builds on a December 2024 Regulatory Result Evaluation which found that the report has a positive but limited effect on market practices.
Working Hypotheses Under Examination
CVM is collecting technical evidence to test seven working hypotheses. These address whether the report's added informational value is concentrated in a narrow group of practices, whether explanations for non-compliance tend toward boilerplate repetition, and whether direct utility is confined mainly to institutional investors.
Additional hypotheses examine whether reporting costs disproportionately affect smaller issuers, whether concentrated ownership structures limit market discipline, and whether increased adoption of governance practices is driven by factors external to the report. CVM clarified that these hypotheses do not represent definitive regulatory conclusions or institutional preferences.
Consultation Timeline and Submission Format
The consultation exercise is preliminary and exploratory, and any eventual regulatory adjustments will depend on the received evidence. Market participants and interested parties can submit contributions until 2 February 2027.
Submissions must be sent via email in PDF format. Where quantitative data is included, respondents are required to submit the structured spreadsheet template provided in Annex I of the official call notice.
Frequently Asked Questions
What is the deadline for submitting feedback to CVM?
Stakeholders must submit technical contributions to CVM by 2 February 2027.
What document formats are required for consultation submissions?
Submissions must include a main document in PDF format and a completed annex spreadsheet for any quantitative data provided.
