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CVM 218 Repealed: What Changes for Climate Risk

Mateus Lima
Mateus Lima

CEO

6 min read
CVM 218 Repealed: What Changes for Climate Risk

On May 29, 2026, Brazil's securities regulator (CVM) published Resolution 244, amending Resolution 193/2023 and repealing the mandatory disclosure of sustainability and climate-related financial information by listed companies.

In practice, Resolutions CVM 217 (IFRS S1, sustainability) and CVM 218 (IFRS S2, climate) are no longer mandatory. Reporting has returned to a voluntary basis under the "comply or explain" model: the company chooses whether to adopt the international ISSB/CBPS standards. If it chooses not to report, it must justify the decision through a market announcement.

The decision caught the market by surprise. As recently as February 2026, the CVM itself had rejected Abrasca's request for a postponement. So what changed?

What led to the repeal

The pressure came mainly from Abrasca (the Brazilian Association of Listed Companies), which filed an official request on the eve of the rule taking effect, citing implementation costs of up to 70% of audit spending and the burden of other legal changes, such as the Tax Reform.

The institutional context weighed heavily. The CVM board started 2026 with only two of five directorships filled and went five months without ruling on cases. The decision to repeal was made by two votes to one. Interim president João Accioly and superintendent Thiago Chaves in favor, director Marina Copola against.

The new CVM president, Otto Lobo, approved by the Senate on May 20, had not yet taken office. A week later, Finance Minister Dario Durigan was already publicly calling for the rule to be reinstated (Folha, 06/06/2026).

What Resolution 244 actually changed

End of the mandate: companies that do not wish to adopt the ISSB/CBPS standards are no longer required to report.

"Comply or explain" model: starting January 1, 2027, a company that chooses not to file a sustainability report must publish an announcement describing management's reasons.

Stability for adopters: those who voluntarily opt to report must maintain it for at least three consecutive fiscal years. To exit, they must notify the market one fiscal year in advance.

Accounting standard maintained: companies that decide to publish remain required to follow CBPS and ISSB standards. There is no "sustainability report light."

End of the "perpetual permanence clause": experimental voluntary reporting no longer creates a lifelong obligation. Previously, a single voluntary adoption forced the company to report forever.

CVM 218 repealed. What now?

For those already preparing, the news may sound like a relief. But climate risk has not disappeared.

The losses keep growing: BRL 184 billion in climate losses in Brazil between 2022 and 2024 (CNseg/EY, COP30), BRL 60 billion per year, 91% without insurance coverage. The frequency and severity of extreme events tripled over the last decade (Atlas Digital MDR). Demurrage at Brazilian ports reached US$ 2.3 billion in 2024 (Bain & Company / Valor Econômico).

Outside Brazil, climate regulation is advancing. IOSCO (the international organization of securities regulators) endorsed the ISSB standards. Europe, the United Kingdom, Japan, Australia and Canada are implementing mandatory requirements. Brazilian companies that raise capital abroad, export, or have a foreign parent will remain subject to these rules.

In addition, "comply or explain" shifts the burden of justification to management. Saying "we do not report because it is not mandatory" may not be enough for investors, analysts and insurers that already factor climate risk into their decisions.

Who comes out ahead

Voluntary disclosure becomes a competitive advantage. Companies that have already mapped critical assets, understand their exposure to extreme winds, floods, droughts and heat waves, and can translate that into auditable numbers will stand out.

Demand for high-resolution climate data did not vanish with the repeal. On the contrary: without regulatory pressure to level everyone, those who choose to report with quality will truly differentiate themselves. Data at a resolution of 1 to 3 km, versus the 25 km of public sources, makes the difference between a generic report and one that investors take seriously.

What to do now

Map the physical exposure of your critical assets: location, vulnerability, probability of extreme events. More than 100 assets have already been mapped in sectors such as ports, energy and mining.

Acquire high-resolution data to feed realistic scenarios. Without granularity, the report loses credibility.

Define management's position. If the choice is not to report, prepare the justification with transparency. If the choice is to report, start yesterday.

Integrate climate intelligence into internal risk management and compliance systems. Early warning is not bureaucracy. It is EBITDA protection.

CVM 218 was repealed. Climate risk was not. Those who treat transparency as strategy, not obligation, will reap the difference.

Sources: Resolution CVM 244/2026, CVM (gov.br), Mattos Filho Advogados, Capital Reset, Folha de S.Paulo, Valor Econômico, Migalhas.

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