CVM 193 and CVM 244: what changed in sustainability reporting

What CVM Resolutions 217, 218 and 219 are

In a progressive regulatory move, Brazil's securities regulator, the CVM, introduced a set of rules to bring international sustainability reporting standards into the Brazilian framework. CVM Resolution 193, published in 2023, was the starting point. It provided for adopting the International Sustainability Standards Board (ISSB) standards, IFRS S1 and IFRS S2, for sustainability reporting by listed companies in Brazil.

In 2024 the CVM then published Resolutions 217, 218 and 219, refining and consolidating Resolution 193. Resolution 217 established the duty for listed companies to disclose sustainability reports following the standards issued by Brazil's sustainability pronouncements committee (CBPS), which incorporate the ISSB standards. That duty was revoked by CVM 244 in May 2026, before it took effect. Resolution 218 amends the rules for preparing financial statements, providing for the presentation of sustainability reports, while 219 makes targeted changes for consistency. In essence, these resolutions solidify Brazil's commitment to transparency and standardisation in sustainability disclosure, aligning the country with global best practice and with the growing expectations of investors and stakeholders.

Implementation timeline

The CVM set out a phased implementation timeline, designed to let companies adapt gradually. Understanding it is decisive for strategic planning and resource allocation.

• Financial year beginning 1 January 2024 (reporting in 2025). For this period, adopting the ISSB standards through the CBPS/CPC is voluntary. Companies choosing to report in this format get to test their internal processes, identify gaps and refine their methodology ahead of any future requirement. This phase offers a valuable learning curve, positioning companies as sustainability leaders and easing dialogue with global investors already familiar with the ISSB standards. Voluntary adoption can be a competitive differentiator, showing initiative and a commitment to transparency.

• Financial year beginning 1 January 2025 (reporting in 2026). For this year, the CVM allows voluntary adoption or the use of other sustainability reporting standards. Companies that choose not to follow CBPS/ISSB have to justify the non-adoption annually and state which standard they used in their sustainability report, if they publish one. It was precisely that mechanism, adopt or justify non-adoption, that CVM 244 ended up making the permanent regime.

• Financial year beginning 1 January 2026 (reporting in 2027). This was the point at which adopting the ISSB standards through the CBPS/CPC would become mandatory for listed companies. CVM 244 revoked that mandate before it took effect. Under the current regime, a company choosing not to disclose has to explain the decision publicly, and one that discloses voluntarily follows the CBPS standard for three financial years. Preparation still pays off, but because banks, investors and clients require it, not the regulator.

It is worth stressing that the preparation needed is not merely an accounting exercise. It involves collecting and managing non-financial data, materiality analysis, identifying and managing sustainability-related risks and opportunities, and integrating that information into the organisation's strategic decisions.

IFRS S1 and S2 brought into Brazil

At the heart of the CVM resolutions is the incorporation of the ISSB standards, a fundamental step in the global standardisation of sustainability reporting. Through the CBPS, the national arm of the ISSB, Brazil formally adopts IFRS S1 and IFRS S2, aligning with an international movement to harmonise ESG disclosure.

• IFRS S1, general requirements for disclosure of sustainability-related information. This standard sets out the fundamental requirements for disclosing sustainability-related financial information. It requires entities to disclose material information about sustainability-related risks and opportunities that could affect cash flows, access to finance or the cost of capital. S1 is the foundation, defining the general principles guiding the identification, measurement and disclosure of non-financial information. It takes an investor-value perspective, focusing on how sustainability affects the company's ability to generate value over the long term. That includes disclosure of governance over sustainability risks and opportunities, strategy, risk management, and relevant metrics and targets.

• IFRS S2, climate-related disclosures. Complementing S1, IFRS S2 focuses specifically on climate. Given the salience of the topic and the growing pressure on companies to manage and mitigate their climate impacts and risks, this standard provides detailed guidance for reporting on climate-related risks and opportunities, both physical and transition. It requires disclosure that lets investors assess the company's exposure to climate risks and opportunities and its resilience to them. That covers greenhouse gas emissions, energy use, transition plans for a low-carbon economy, and climate scenario analysis.

The relationship between S1 and S2 is symbiotic: S1 sets the general architecture and the principles governing all sustainability disclosure, while S2 applies that framework to climate risks and opportunities, which are frequently the most material and complex for many companies. Brazil's adoption of these standards through the CBPS/CPC means that a company reporting on sustainability does so integrated with its financial information, in a language investors and regulators recognise globally. See also IFRS S2.

The four pillars of IFRS S2

IFRS S2 structures its disclosures around four fundamental pillars, drawn from the recommendations of the Task Force on Climate-related Financial Disclosures (TCFD). They provide a comprehensive framework for companies to communicate how they address climate risks and opportunities. Understanding each is essential to effective implementation.

1. Governance. This pillar requires companies to disclose the governance processes, controls and procedures used to monitor, manage and oversee climate-related risks and opportunities. The central question: how are my company's board and senior management involved in overseeing and managing climate risks and opportunities?

• In practice: a retail company might disclose that its board has a sustainability committee meeting quarterly to review the company's decarbonisation strategy, progress against emission targets, and the physical risks from extreme weather that could affect the supply chain or store operations. The disclosure would set out the specific responsibilities of the board and of senior management.

1. Strategy. This pillar covers how the organisation addresses climate risks and opportunities in its business strategy, business model and financial planning. Key questions: which climate risks and opportunities are material to my company over the short, medium and long term, and how do they affect our strategy and resilience?

• In practice: an agricultural company might disclose a climate scenario analysis showing how different global warming pathways (1.5°C vs 3°C, say) would affect crop productivity. The strategy might include diversifying into drought-resistant crops, investing in more efficient irrigation, or exploring climate insurance to mitigate harvest loss. The company would explain how those climate risks and opportunities feed into strategic planning and capital budgeting.

1. Risk management. This pillar addresses how the organisation identifies, assesses and manages climate-related risks and opportunities. The focus is on the processes used to integrate them into enterprise risk management.

• In practice: for a financial institution, the disclosure could detail how transition risks (such as the risk of stranded assets in loan books to carbon-intensive sectors) are built into its credit risk management framework. That might involve revised due diligence for new lending, exposure limits for high-carbon sectors, and climate stress testing of the portfolio. The company would explain the frequency and methodology of those assessments.

1. Metrics and targets. This pillar requires disclosure of the metrics the organisation uses to assess and manage climate risks and opportunities, and its targets for managing them. It covers GHG emission metrics (Scopes 1, 2 and 3), energy intensity, water use, and other climate-relevant metrics.

• In practice: an infrastructure company might disclose its Scope 1, 2 and 3 GHG emissions for the last three years, alongside a target of a 30% reduction in absolute emissions by 2030, aligned with the Science Based Targets initiative. It might also disclose energy intensity metrics per unit of service or product, and the share of renewable energy in its operations. The calculation methodologies and the assumptions behind the targets would be detailed.

Implementing these pillars successfully takes an integrated, cross-functional approach, involving finance, operations, risk management and sustainability.

Relationship with the B3 ISE and IGCT

The new regulatory wave, led by CVM Resolutions 217, 218 and 219, is closely tied to the evolution of Brazil's capital market and the growing demand for quality ESG information. In that context, B3's sustainability indices, the Corporate Sustainability Index (ISE) and the Corporate Governance and Custo Brasil Index (IGCT), gain a new layer of relevance and synergy with CBPS/ISSB reporting.

B3's Corporate Sustainability Index (ISE) has been, for more than a decade, the main reference for investors looking for companies deeply engaged with sustainability. Membership, based on a comprehensive questionnaire assessing companies' ESG practices, is a mark of recognition and a competitive differentiator.

With ISSB/CBPS standards consolidating as the reporting reference, a natural convergence follows:

• Content alignment. Many of the information requirements in the ISE questionnaire already cover governance, strategy, risk management and the measurement of environmental and social impacts. Adopting IFRS S1 and S2 provides a robust, standardised structure for collecting, analysing and reporting that data, making the ISE response easier and raising the quality and comparability of the information.
• Credibility and verification. Independent verification of reports lends greater credibility to sustainability data. That in turn raises confidence in the information supplied to the ISE, strengthening companies' market reputation.
• Competitive advantage. Companies already advanced in preparing for ISSB/CBPS reporting have a significant advantage in competing to enter or stay in the ISE. Being able to demonstrate solid governance over sustainability, climate resilience strategies and clear ESG performance metrics becomes an even more tangible differentiator. ISE membership attracts responsible capital, offers a better cost of financing and strengthens the employer brand.

The Corporate Governance and Custo Brasil Index (IGCT), for its part, focuses on corporate governance and how it mitigates the barriers to the country's development. It is more focused on governance and macroeconomic aspects, but it intersects with sustainability through the governance pillar of IFRS S2. Robust governance overseeing climate and sustainability risks and opportunities signals advanced, transparent management, which the IGCT values.

In short, reporting to the ISSB standard is no longer a regulatory requirement and remains a strategic investment, one that can pave the way to better positioning in indices such as the ISE and the IGCT. It reinforces the company's commitment to transparency, attracts capital that values sustainability and strengthens its standing with every stakeholder. Companies that see CVM 217/218/219 as a catalyst for improving their ESG practice and communication will hold a real competitive edge.

Preparation checklist

Preparing a company to report to the CBPS/ISSB standard, even voluntarily, takes planning and proactive action. To maximise the benefits, here is a practical checklist.

1. A comprehensive GHG emissions inventory. Start or improve the collection of data and the calculation of Scope 1, 2 and 3 greenhouse gas emissions. Scope 3 in particular needs attention, because it spans the whole value chain and can be the most complex to measure. A robust, consistent data base is fundamental to meeting IFRS S2 requirements.

1. Mapping climate risks and opportunities. Run an internal assessment to identify the climate risks (physical and transition) and associated opportunities (energy efficiency, new low-carbon products or services) that are material to your organisation. Do it across several time horizons: short, medium and long term.

1. Climate scenario analysis. As IFRS S2 requires, run climate scenario analysis to assess the resilience of your business strategy under different climate pathways (1.5°C, 2°C, 3°C of global warming). That will help you understand potential impacts and develop contingency plans. See how we structure climate risk analysis.

1. Integrating climate into corporate governance. Review and adjust governance structures so that oversight of climate risks and opportunities is clearly assigned to the board and/or senior management. Define responsibilities, reporting frequency and decision mechanisms. Update internal policies and charters.

1. Setting relevant metrics and targets. Identify the climate performance metrics most relevant to your industry and business model. Set clear, measurable targets for emission reduction, energy efficiency, water use and so on, aligned with market best practice (SBTi, for example).

1. Training and internal engagement. Invest in training cross-functional teams (finance, ESG, operations, risk, legal) on the requirements of IFRS S1 and S2. Sustainability reporting takes interdepartmental collaboration and a shared understanding of objectives and processes.

1. Reviewing processes and systems. Assess your current data collection and management systems. ISSB/CBPS compliance will demand systems that can consolidate sustainability data reliably and auditably, integrated where possible with financial systems.

1. Double materiality and the investor-value perspective. IFRS S1 and S2 focus primarily on the investor-value perspective (the financial impact of sustainability on the company), but it is also worth considering double materiality (the company's impact on society and the environment) for a complete picture and to meet other stakeholders' expectations.

1. Dialogue with the independent auditor. Start the conversation with your independent auditor about verification requirements for sustainability reports, anticipating what will be needed and adapting internal processes so the data is auditable.

Preparation should start now. Understanding that CVM 217, 218 and 219 are not merely a regulatory adjustment but a transformation demanding a rethink of how sustainability is integrated into your company's strategy and operations is a crucial step.

How Mangue Tech helps

At Mangue Tech we understand the challenges and opportunities that CVM Resolution 193/217/218/219 and the adoption of IFRS S1 and S2 represent for Brazilian listed companies. Our platform and expertise were built to simplify and streamline sustainability management and reporting, securing not just compliance but the business intelligence that comes from well-managed ESG data.

Our solution provides robust infrastructure to support CBPS/ISSB reporting:

• An extensive emission factor database. We maintain a database of more than 60,000 emission factors. That lets your company calculate Scope 1, 2 and 3 greenhouse gas emissions accurately and comprehensively, meeting the detailed requirements of IFRS S2. Collecting and managing Scope 3 data, frequently the hardest part, becomes easier, with traceability and auditability preserved.

• Support for multiple frameworks. Our platform supports more than 20 sustainability reporting frameworks, including of course the ISSB standards (IFRS S1 and S2) through the CBPS/CPC, GRI and others. That gives the flexibility to meet different stakeholder and regulator demands, consolidating every disclosure requirement in one place. See also IFRS S2.

• Modules dedicated to IFRS S2. We built specific modules for the IFRS S2 pillars:

• Climate risk module. Designed to support the identification, assessment and management of climate risks and opportunities, both physical and transition. It lets you document processes, assign responsibilities and track how risks evolve, supplying what the risk management pillar of IFRS S2 needs. See climate risk.

• Scenario analysis module. This makes running and documenting climate scenario analysis easier, which the strategy pillar of IFRS S2 requires. It helps your company assess the resilience of its operations and business model across different climate futures, giving insight for strategic planning and decision-making.

• Customisable visualisation and reporting. The Mangue Tech platform produces customisable reports and dashboards, making it easier to communicate CBPS/ISSB disclosures clearly, concisely and auditably. Real-time data visualisation supports management decisions and the preparation of annual reports.

• Specialist technical support. Our team is ready to provide technical support and consulting on implementing the ISSB/CBPS standards, so your company is prepared to report with a full audit trail.

With Mangue Tech, the transition to Brazil's new sustainability reporting regime becomes more manageable, efficient and strategic. We are ready to be your partner on that journey, turning regulatory challenges into opportunities to add value.