The publication of CVM Resolution No. 244 in May 2026 marked a new chapter in the evolution of the agenda for disclosing financial information related to sustainability in Brazil. The regulation amended CVM Resolution No. 193, revoking the future mandatory adoption of IFRS S1 and IFRS S2 standards and establishing a model based on voluntary adherence, accompanied by transparency requirements for companies that choose to disclose or not disclose this information.
The main recommendation is that S1/S2 institutions, publicly traded financial companies, and institutions that publish consolidated financial statements in accordance with international standards should maintain, without slowing down, their implementation programs for CBPS 01/02. CVM Resolution 244/2026 alters the regime for publicly traded companies within the scope of the CVM, but does not dismantle the CMN/BCB prudential track.
The debate surrounding CVM Resolution No. 193
The path that led to this regulatory change was marked by intense debate among different market players.
In December 2025, the Brazilian Association of Publicly Held Companies (ABRASCA) requested that the CVM (Brazilian Securities and Exchange Commission) review the implementation schedule of Resolution 193, arguing that companies were simultaneously facing other relevant regulatory agendas, such as the Tax Reform, the implementation of Pillar 2 of the OECD, and new accounting and tax requirements. The entity advocated for the voluntary adoption of the standards or, alternatively, the postponement of mandatory implementation for at least three years.
A few days later, a joint statement from the Association of Investors in the Capital Market (AMEC), the Association of Analysts and Investment Professionals of the Capital Market (APIMEC Brasil), the Federal Accounting Council (CFC), the Foundation Institute for Accounting, Actuarial and Financial Research (FIPECAFI), and the Brazilian Institute of Independent Auditing (IBRACON) presented a different view.
The organizations defended maintaining Resolution 193, highlighting the importance of information comparability, investor protection, reduction of informational asymmetries, and integration between financial information and information related to sustainability.
The CVM’s technical position
In February 2026, the CVM’s technical area formally responded to ABRASCA’s statement.
The technical team rejected the request for postponement or voluntary adoption, arguing that the market had been aware of the timeline since 2023, that the standards provided for proportionality mechanisms, and that the adoption was aligned with international best practices.
The response also highlighted references such as IOSCO, the IFRS Foundation, and the Principles for Responsible Investment (PRI), in addition to recording the arguments presented by market entities in defense of maintaining the mandatory requirement.
Regulatory change
Despite this stance, in May 2026 the CVM Board approved Resolution No. 244, altering the model originally foreseen by Resolution 193.
The decision eliminated the future requirement for reports aligned with ISSB standards, but maintained mechanisms designed to promote transparency and accountability, including the need for public justification for certain decisions related to the disclosure of information.
What remains under debate
More than a discussion about being for or against IFRS S1 and IFRS S2, this process highlights the challenges associated with implementing new regulatory requirements in an environment of market transformation.
The easing of adoption requirements modifies the regulatory regime, but does not eliminate the financial relevance of climate and sustainability-related risks and opportunities. Investors, financial institutions, regulators, and companies continue to demand consistent information to understand impacts, assess strategies, price risks, and identify opportunities associated with the transition to a low-carbon economy.