RegulationGuide
Sustainable Taxonomy in Brazil: What It Is, How to Apply It and How to Unlock Green Credit
What a sustainable taxonomy is, why it is strategic for Brazil and how structured ESG data helps unlock green credit.
Regulation, updated on
The regulatory map of social, environmental and climate risk.
The challenge is not knowing the regulation. It is turning regulatory requirements into opportunities and portfolio management, with evidence and an audit trail.
Informational content; does not constitute a legal opinion.
- regulations and references mapped
- 23
- in force
- 16
- published, with a future effective date
- 4
- proposed or voluntary
- 3
Count from the table below, reviewed on .
Compliance is the institution's responsibility.
ESGreen provides data, evidence and an audit trail. Each requirement below is mapped to a data point, a piece of evidence and a report.
- In force
- regulation published and applicable.
- Published
- regulation published with a future effective date.
- Proposed
- text under public consultation; may change in the final version.
- Voluntary
- adoption not mandatory as of the review date.
- ≈ Estimate
- year estimated from an official document, with no date yet set in regulation (for the Brazilian Sustainable Taxonomy, the MRV System guidance document, with T0 = 2025).
- Review date
- each row shows when it was last checked. Deadlines are set by regulators and may change.
Four recent changes that alter risk and reporting routines
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The GRSAC now comes with numbers.
BCB Resolution 586 and BCB Normative Instruction 772, of September 3, 2026, overhaul the GRSAC report with quantitative tables starting January 1, 2027. First disclosure by S1 and S2 in 2028, with a December 2027 reference date.
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IFRS S1/S2 reporting became voluntary for listed companies.
CVM Resolution 244, of May 29, 2026, removed the requirement set out in CVM 193. For financial institutions, CMN 5,185 keeps the report mandatory, with reasonable assurance.
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Rural credit now requires documented monitoring.
CMN 5,268/2025 added to section 9 of the MCR (Rural Credit Manual) the PRODES/INPE check for vegetation clearing and remote sensing monitoring of contracts above 300 ha, “documented, auditable and assessable by the Central Bank”.
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Rural insurance gained social and environmental restrictions.
Since May 3, 2026, CNSP 485/2025 bars coverage for properties without an active CAR, under embargo for illegal deforestation, or belonging to producers listed in the MTE employer registry.
Regulations, deadlines and where ESGreen fits in
23 regulations and references that affect the social, environmental and climate risk of financial institutions and companies in Brazil.
| # | Regulation | Who | Deadline and status | What it requires | How ESGreen helps | Content |
|---|---|---|---|---|---|---|
| R01 | BCB Res. 586/2026 + BCB IN 772/2026new GRSAC; revoke BCB Res. 139 and IN 153 See details for BCB Res. 586/2026 + BCB IN 772/2026
|
S1 to S4 institutions | Published Published September 3, 2026; in force from January 1, 2027. S1 and S2: first disclosure in 2028, reference date Dec 2027. S3: from the December 31, 2028 reference date. S4: commitment tables on the same timeline as S3 Reviewed: | Annual GRSAC report with quantitative tables and counterparties classified by CNAE. The CP 127/2025 draft provided for exposures and financed emissions by sector, agricultural credit by biome, exposures to power generation by source, exposure to drought and heavy rainfall by region, exposures to social and environmental risk, a transition plan and voluntary commitments. |
IRC-ESGreen (Climate Risk Index) and ESGreen Score as inputs for the new tables: classification by CNAE, risk per counterparty and climate exposure by land parcel and region. | Read analysis See all on this regulation |
| R02 | CMN Res. 5,185/2024IFRS S1/S2 for financial institutions See details for CMN Res. 5,185/2024
|
Publicly traded financial institutions and prudential conglomerate leaders | In force In force since January 1, 2025. Fiscal year 2026 for publicly traded institutions and S1 and S2 leaders; 2028 for S3 Reviewed: | Report of sustainability-related financial information under CBPS pronouncements 01 and 02 (IFRS S1/S2), with reasonable assurance by an independent auditor. |
Evidence trail ready for reasonable assurance: every data point with source, date and version. Physical risk inputs for IFRS S2. | Read analysis |
| R03 | CMN Res. 5,268/2025rural credit, MCR section 9 See details for CMN Res. 5,268/2025
|
Institutions that provide rural credit, including cooperatives | In force In force. PRODES/INPE: since Apr 2026 for properties above 4 fiscal modules; from Jan 2027 for the others. Remote sensing: contracts above 300 ha since March 1, 2026 Reviewed: | Check for vegetation clearing after July 31, 2019, including adjacent areas, and remote sensing monitoring before and during the contract, "documented, auditable and assessable by the Central Bank". These add to the section 9 impediments, such as a missing or canceled CAR, embargoes and the MTE employer registry. |
Checks by CPF, CNPJ and property, climate risk by land parcel, and a record of the source, date and version of each check. | Read analysis See all on this regulation |
| R04 | CMN Res. 4,945/2021PRSAC See details for CMN Res. 4,945/2021
|
All institutions in the National Financial System (SFN), including cooperatives | In force In force since July 1, 2022 (replaced CMN Res. 4,327/2014) Reviewed: | Social, Environmental and Climate Responsibility Policy approved, implemented and applied to clients, operations and suppliers. |
From policy to evidence: the PRSAC applied to clients, suppliers and operations, with continuous monitoring, history and protocols. | Read analysis See all on this regulation |
| R05 | CMN Res. 4,943/2021 and 4,944/2021risk management See details for CMN Res. 4,943/2021 and 4,944/2021
|
4,943: S1 to S4. 4,944: S5 (simplified regime) | In force In force since 2022 Reviewed: | Inclusion of social, environmental and climate risk in the risk management framework, risk appetite and stress tests. |
ESGreen Score and IRC-ESGreen as inputs for risk appetite, limits and stress tests. | Read analysis |
| R06 | BCB Res. 151/2021DRSAC See details for BCB Res. 151/2021
|
Regulated institutions subject to submission | In force In force. Semiannual submission, in February and August Reviewed: | Document submitted to the Central Bank with social, environmental and climate risk assessments of credit and securities exposures and their debtors. |
Risk flags per counterparty, with source and date, ready to feed into the document. | Read analysis See all on this regulation |
| R07 | BCB Circular 3,978/2020PLD/FT See details for BCB Circular 3,978/2020
|
Institutions authorized by the Central Bank | In force Reviewed: | Anti-money laundering policy and procedures, including knowing your clients, employees, partners and outsourced service providers. |
Continuous monitoring of suppliers and partners, with restrictive lists, international sanctions and news. | No articles published |
| R08 | CMN Res. 4,893/2021cybersecurity and cloud See details for CMN Res. 4,893/2021
|
Institutions authorized by the Central Bank, when contracting data and cloud services | In force Reviewed: | Cybersecurity policy and requirements for contracting data processing, data storage and cloud computing services. |
Trust page and supplier due diligence materials sent on request. | No articles published |
| R09 | CNSP Res. 485/2025rural insurance See details for CNSP Res. 485/2025
|
Insurers that offer rural insurance | In force In force since May 3, 2026 (published November 4, 2025) Reviewed: | Ban on coverage for properties without an active CAR, under embargo for illegal deforestation, or belonging to producers listed in the MTE employer registry. |
CAR, embargo and MTE registry checks by CPF, CNPJ and property at underwriting, with source and date. | No articles published |
| R10 | SUSEP Circular 666/2022 See details for SUSEP Circular 666/2022
|
Insurers, reinsurers and other supervised entities | In force In force. Annual sustainability report by April 30, kept online for 5 years or more Reviewed: | Sustainability policy and physical, transition and litigation climate risks in risk management. |
Portfolio climate risk data and screening of policyholders, suppliers and investees as inputs for risk management and the report. | No articles published |
| R11 | SUSEP Public Consultation 05/2026 See details for SUSEP Public Consultation 05/2026
|
SUSEP-supervised entities, including cooperative insurers | Proposed Proposed. The draft under consultation provides for the new rule on December 31, 2026, data collection in 2027 and disclosure in 2028; dates may change in the final version Reviewed: | Alignment with IFRS S1/S2, climate scenario analysis for S1 and S2, ESG criteria in pricing and underwriting, and screening of assets, suppliers and service providers. |
Underwrite for the climate ahead, not just the climate behind: IRC-ESGreen in underwriting and ESGreen Score in screening assets and suppliers. | No articles published |
| R12 | Previc Ordinance 728/2026 See details for Previc Ordinance 728/2026
|
Closed private pension funds (EFPC) | Published Published September 16, 2026. Deadlines by Previc segment: S1 and S2 by Jun 2027; S3 and S4 by Mar 2028 Reviewed: | Double materiality, an ESG plan and external managers contractually required to integrate ESG criteria. |
Issuer-level data for the ESG plan and to track ESG integration by contracted managers. | No articles published |
| R13 | CVM Res. 193/2023 + CVM Res. 244/2026 See details for CVM Res. 193/2023 + CVM Res. 244/2026
|
Listed companies | Voluntary Voluntary. CVM 244 of May 29, 2026: voluntary reporting from fiscal year 2026; "comply or explain" from January 1, 2027 Reviewed: | Voluntary IFRS S1/S2 reporting for listed companies, with a commitment of at least 3 fiscal years and assurance for adopters. For financial institutions, CMN 5,185 applies. |
IFRS S1/S2 reporting, voluntary for listed companies (CVM 193/244) and mandatory for financial institutions (CMN 5,185): value chain and counterparty data with source, date and version. | No articles published |
| R14 | Brazilian Sustainable Taxonomy (Decree 12,705/2025) and MRV System See details for Brazilian Sustainable Taxonomy (Decree 12,705/2025) and MRV System
|
Non-financial companies, banks, asset managers and funds; then cooperatives, insurers and pension funds | Voluntary Voluntary at first. Decree of October 31, 2025. The MRV System guidance document estimates, with no date yet set in regulation: Wave 1 (S1 and S2 banks, asset managers and funds, listed companies except smaller ones) and the MRV Portal in ≈2027; Wave 2 (S3 to S5, credit cooperatives, insurers, pension funds and other companies) in ≈2028; mandatory verification in ≈2029 Reviewed: | Classification of activities by CNAE and alignment indicators: PAES (companies), PAS and POVS (banks) and PIS (asset managers and funds), with verification by accredited verifiers in the mandatory phase. |
Ready for the TSB MRV System: classification by CNAE (economic activity code) and evidence per transaction and per investee. | Read analysis See all on this regulation |
| R15 | SBCE, Law 15,042/2024regulated carbon market See details for SBCE, Law 15,042/2024
|
Facilities emitting more than 10,000 tCO₂e/year; above 25,000, also subject to a reconciliation obligation | In force In force, with phased implementation. Timeline still proposed in CP SEMC 1/2026: phase 1 with a monitoring plan in 2027; phase 2 in 2029 Reviewed: | Monitoring, reporting and verification of emissions per facility, with a verified annual report. Primary agricultural production excluded. |
A topic tracked in Research. Useful for banks and asset managers assessing the transition risk of clients and investees. | No articles published |
| R16 | Law 12,846/2013 + Decree 11,129/2022, art. 57, XIII See details for Law 12,846/2013 + Decree 11,129/2022, art. 57, XIII
|
Companies | In force Reviewed: | Integrity program with appropriate, risk-based due diligence to contract and oversee third parties, including politically exposed persons. |
Pre-assessment at contracting and continuous monitoring in third-party oversight, with restrictive lists, sanctions and ownership structure. | Read analysis |
| R17 | Law 14,133/2021, art. 25, §4public procurement See details for Law 14,133/2021, art. 25, §4
|
Public sector suppliers in large-scale contracts | In force In force. Large-scale contract threshold in 2026: R$261,968,421.04 (Decree 12,807/2025) Reviewed: | Implementation of an integrity program within 6 months of contract signing. |
Dated evidence of supply chain due diligence. | No articles published |
| R18 | SARB 026/2023Febraban self-regulation See details for SARB 026/2023
|
Signatory banks | In force In force for signatories. Reviewed: | Management of illegal deforestation risk in the beef supply chain. |
Checks for embargoes, deforestation and overlaps by CNPJ, CPF and property across the supply chains of the sector's clients. | Read analysis |
| R19 | ZARCAgricultural Climate Risk Zoning, MAPA (Ministry of Agriculture) See details for ZARC
|
Rural credit and rural insurance | In force In force. Published by crop, state and crop year Reviewed: | Official climate risk reference by municipality, crop and planting window. |
ZARC is static, by municipality and crop year. IRC-ESGreen is dynamic, by land parcel, recalculated with each run. The two views complement each other. | No articles published |
| R20 | EUDREU Regulation 2023/1115, as amended See details for EUDR
|
Exporters of soy, cattle, coffee, cocoa, palm oil, rubber and wood to the European Union, and those who finance them | Published Published. December 30, 2026 for large and medium operators; June 30, 2027 for micro and small operators. Deforestation cutoff: December 31, 2020 Reviewed: | Due diligence with proof of zero deforestation and geolocation of production areas. |
Checks for embargoes, deforestation and territorial overlaps by CNPJ, CPF and property of producers and suppliers. | No articles published |
| R21 | CBAMEuropean Union See details for CBAM
|
Exporters of steel, iron, aluminum, cement and fertilizers, among others | In force In force. Definitive regime since January 1, 2026; certificate sales from Feb 2027 Reviewed: | Carbon cost embedded in European imports of these products. |
A topic tracked in Research. Useful for assessing the transition risk of exporting clients and investees. | No articles published |
| R22 | CSDDDEU Directive, after Omnibus I See details for CSDDD
|
Companies with more than 5,000 employees and €1.5 billion in revenue, and their Brazilian suppliers | Published Published. Applies from July 26, 2029 Reviewed: | Human rights and environmental due diligence across the chain of activities, passed on to suppliers through questionnaires. |
Supplier monitoring and Evidence Assessment to answer European clients' questionnaires. | Read analysis |
| R23 | LGPDLaw 13,709/2018 See details for LGPD
|
All organizations that process personal data | In force Reviewed: | A legal basis for each purpose, an appointed data protection officer and handling of data subject rights. |
Appointed data protection officer (DPO), legal bases and a channel for data subjects, described on the Trust page. | No articles published |
No regulation matches this filter.
Clear filtersReviewed: September 30, 2026. Deadlines set by regulators and subject to change. ≈ = estimate, with no date set in regulation. Proposed = text under public consultation.
Deadlines may change. The direction won't.
Every requirement in this table moves in the same direction: from drafting to consultation, from publication to entry into force. And the evidence each one will demand needs a track record, which cannot be built overnight.
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Under development
Foreseen in an official document, with no date set in a rule yet.
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Proposed
Under consultation or with a proposed timeline. The direction is already set.
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Published
Rule published. The requirement takes effect in stages.
- EUDR: zero-deforestation due diligence for large and medium-sized operators EUDR
- New GRSAC: quantitative tables in the report BCB 586
- CMN 5,268: PRODES check for properties of up to 4 fiscal modules CMN 5.268
- CVM 244: “comply or explain” model CVM 193/244
- CBAM: sale of certificates CBAM
- Previc 728: ESG plan and double materiality, starting with S1 and S2 entities Previc 728
- EUDR for micro and small operators EUDR
- New GRSAC: first quantitative disclosure, starting with S1 and S2 BCB 586
- CMN 5,185: IFRS S1/S2 reporting for S3 institutions CMN 5.185
- CSDDD: supply chain due diligence by large European companies, passed on to suppliers CSDDD
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In force
Already applies. Evidence must be kept up to date.
- CMN 5,185: IFRS S1/S2 reporting with reasonable assurance for publicly traded institutions and S1 and S2 leaders CMN 5.185
- CVM 244: voluntary IFRS S1/S2 reporting for listed companies CVM 193/244
- CNSP 485: socio-environmental restrictions in rural insurance CNSP 485
- CMN 5,268: PRODES check and remote monitoring in rural credit CMN 5.268
- CBAM: definitive regime for European imports CBAM
Informational content; not legal advice. Deadlines are set by regulators and subject to change; official dates are on the regulatory map. Status reviewed on .
Research analyses by regulation
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RegulationGuide
Central Bank of Brazil SAC guide: PRSAC policy, DRSAC reporting and GRSAC disclosure
A guide to the Central Bank of Brazil social, environmental and climate rules: PRSAC, risk management and DRSAC, GRSAC reshaped by BCB 586/2026, and rural credit.
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RegulationGuide
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How SCFIs can build ESG criteria into KYC and KYP and prepare for the Central Bank’s social, environmental and climate requirements.
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The 2025 update to the Central Bank's Sustainability Agenda: Birô Verde, Public Consultation 119/2025, CMN 4,945 and how institutions can prepare.
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RegulationVideo
Webinar: Central Bank of Brazil sustainability agenda, technology and ESG assessment mechanisms
ESGreen's first webinar, with Viviane Torinelli of the Central Bank of Brazil, on the BCB sustainability agenda and the demand for ESG assessment mechanisms.
The same regulation, read by segment
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Credit cooperatives
PRSAC, CMN 5,268, the new GRSAC and the TSB's second wave.
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Banks
New GRSAC, CMN 5,185, DRSAC and PRSAC.
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Insurers
CNSP 485, SUSEP 666 and CP 05/2026.
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Asset managers and capital markets
TSB (PIS), CVM 193/244 and Previc 728.
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Companies
Decree 11,129, Law 14,133, EUDR and CSDDD.
Frequently asked questions
Short answers to the most common questions.
Still have questions? Talk to an expert
Does ESGreen guarantee my institution's compliance with these regulations?
No. Compliance is the institution's responsibility. ESGreen provides data, evidence and an audit trail that support compliance: every data point with source, date and version. ESGreen does not certify, does not issue assurance and does not provide legal opinions.
What changes in the GRSAC report with BCB Resolution 586?
Published on September 3, 2026, BCB Resolution 586 and BCB Normative Instruction 772 replace BCB Resolution 139 and IN 153 and take effect on January 1, 2027. The report now includes quantitative tables, with counterparties classified by CNAE (economic activity code). S1 and S2 make their first disclosure in 2028, with a December 2027 reference date; S3 follows from the December 31, 2028 reference date.
Is IFRS S1/S2 reporting mandatory in Brazil?
It depends on who reports. For publicly traded financial institutions and S1 and S2 conglomerate leaders, CMN Resolution 5,185 makes the report mandatory from fiscal year 2026, with reasonable assurance; for S3, from 2028. For listed companies in general, CVM Resolution 244, of May 29, 2026, made reporting voluntary.
What did CMN Resolution 5,268 change in rural credit?
The rule requires a PRODES/INPE check for vegetation clearing after July 31, 2019, since April 2026 for properties above 4 fiscal modules and from January 2027 for the others. For contracts above 300 ha, since March 1, 2026, it requires remote sensing monitoring that is documented, auditable and assessable by the Central Bank.
What is the Brazilian Sustainable Taxonomy MRV System and when does it become mandatory?
It is the Monitoring, Reporting and Verification system of the TSB, established by Decree 12,705/2025. Adoption is voluntary at first. The MRV System guidance document estimates the MRV Portal and Wave 1 around 2027, Wave 2, with credit cooperatives and insurers, around 2028, and mandatory verification by accredited verifiers around 2029. These are estimates, with no date yet set in regulation. The sequence, however, is already defined: institutions that classify transactions by CNAE starting now will reach the mandatory phase with a track record.
How often is this map reviewed?
Each row shows the date of its last review, and the overall date appears at the top of the page. Regulations under public consultation appear as proposed until the final text is published. The status of each milestone in the table is reviewed by the ESGreen team and does not change automatically with the calendar: if a regulator postpones a deadline, the milestone stays where it is until the review.
Which requirement weighs most on your agenda?
In a 30-minute conversation, we show how ESGreen data connects to the requirements your institution has already identified, with evidence and an audit trail.
- A reading of the rules that apply to your segment
- Demo of reporting and evidence deliverables
- Pre-assessment of CNPJs in your base
Or write to contato@esgreen.com.br
An ESGreen specialist replies within one business day to schedule a time.