On June 8th, 2026, the Institute of Collective Law (IDC) and the Association for Inclusive Sustainable Solutions (SIS) filed a Public Civil Action (ACP) with a request for urgent relief against the Securities and Exchange Commission (CVM), due to the issuance of CVM Resolution 244/2026, which revoked the mandatory disclosure of financial information related to sustainability previously provided for in CVM Resolution 193/2023. They argued that the previous rule was based on the scientific consensus that climate change already has concrete effects, including financial risks. In this context, the state adopted the ISSB/IFRS S1 and S2 standards for sustainability financial reporting by publicly traded companies, including greenhouse gas emissions inventories, identification of physical and transitional climate risks, mitigation strategies, climate-related corporate governance, and analysis of the financial impacts of climate change, with a transition regime with voluntary adherence in the fiscal years 2024 and 2025 and mandatory compliance from 2026 onwards. They plaintiffs argued that the regulatory change represents a serious regulatory and environmental setback, as it weakens access to essential information about the environmental, climate, and social risks associated with the activities of publicly traded companies, compromising the adequate pricing of these risks by the market and the ability of investors to direct capital to activities compatible with a resilient and low-carbon economy. They contend that the revocation of the mandatory requirements stipulated in the previous resolution occurred without adequate technical justification, without a regulatory impact analysis, and in contradiction to the previous opinion of the CVM's own technical area; which had recognized the relevance of the measure for market transparency, the management of climate risks, and Brazil's alignment with international best practices. The authors allege that the suppression of mandatory sustainability disclosure generates collective damage of a climate and informational nature, as it reduces the availability of reliable and comparable data on the impacts of business activities on the climate, increases informational asymmetry between companies and investors, favors greenwashing practices, and hinders the identification of companies more exposed to or prepared for the effects of climate change. They also argue that the measure violates Brazil's international commitments, such as those undertaken under the Paris Agreement and the Mercosur-European Union Partnership Agreement. Additionally, they claim that it also compromises the integrity of the capital market, penalizes companies that had already invested in implementing international sustainability standards, and weakens essential instruments for climate governance, such as the Brazilian Greenhouse Gas Emissions Trading System (SBCE). Therefore, the plaintiffs request the granting of urgent relief to immediately suspend the effects of CVM Resolution 244/2026, restoring the mandatory reporting of sustainability information as provided for in CVM Resolution 193/2023. In the final relief they seek a declaration of nullity of CVM Resolution 244/2026, due to flaws in its motivation, procedure, and violation of the principles of environmental protection and legal certainty; or, subsidiarily, a declaration of its illegality and that the CVM be ordered to conduct a public consultation and Regulatory Impact Analysis on the effects of Resolution 244, with suspension of its effectiveness during this process.


IDC and SIS vs. Comissão de Valores Mobiliários (Nullity of CVM Resolution 244/2026)

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IDC and SIS vs. Comissão de Valores Mobiliários (Nullity of CVM Resolution 244/2026) - complaint

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An aim to achieve a quantifiable outcome within a given time-frame, set by an institution such as a national government.

Policy instruments are techniques or tools used by governing authorities to promote certain policies in order to achieve predetermined goals. Put simply, instruments are how a government tries to achieve its goals, with this taxonomy being focused on national policy instruments.

Risk is the potential for adverse consequences resulting from the dynamic interplay between (climate-related) hazards, exposure, and vulnerability of affected human or ecological systems.

Groups  of people who are adversely affected by climate change or the response to it

A set of principles, processes, and practices that build economic and political power to shift from an extractive economy to a regenerative economy.

Justice is the ethical and political framework that addresses fairness, including issues of responsibility, rights, and structural inequity.

Renewable energy means all forms of energy produced from renewable sources in a sustainable manner.

Fossil fuel is a generic term for non-renewable energy sources such as coal, fossil gas, and oil (including crude oil, and petroleum products), that can be used for electricity and heat generation. Fossil fuels are hydrocarbons formed from pressurised and heated organic material buried over millions of years.

Molecules in the atmosphere that play a key role in the greenhouse effect by trapping heat radiating from Earth’s surface.

Area of the economy in which actors engage in identical or related activities.

In human systems, the process of adjustment to actual or expected climate change and its effects, in order to moderate harm, increase resilience or exploit beneficial opportunities. In natural systems, the process of adjustment to actual climate change and its effects; human intervention may facilitate adjustment to expected climate change and its effects.

The management and allocation of funds, assets and investments to meet various objectives

Financial support to help individuals manage the effects of unexpected events, securing their livelihoods and increasing the resilience of people and businesses to the changing climate. It’s especially vital in developing regions where everyday risks, climate-related weather extremes, or crop failures can push people into poverty. Without insurance, people may have to resort to selling assets or cutting consumption to cope with losses.

Tradable permits are market-based tools that grant permission for specific activities, frequently used to regulate emissions. These permits can be issued within a trading system to manage environmental impacts.

Codes and standards are regulatory instruments that specify minimum standards to protect health and safety. This ranges from performance standards, which prescribe outcomes while allowing flexibility to achieve compliance, to the more prescriptive approach of technology-specific standards.

The processes through which enterprises can identify, prevent, mitigate and account for how they address their actual and potential adverse impacts. Due diligence is the idea that reasonable precautions should be taken to avoid causing harm to people, the environment, or society. It also involves identifying and mitigating risks before they occur.

Financial actors and resources that are primarily directed towards climate change mitigation, adaptation and compensation.

Dedicated pool of financial resources for climate-related projects.

A financial institution that manages a country's currency and can promote climate-related initiatives through green monetary policy and other means.

Either money or something of monetary value is transferred between two or more organisations, people or countries.

Conditions that enhance the feasibility of adaptation options. Enabling conditions include finance, technological innovation, strengthening policy instruments, institutional capacity, multi-level governance and changes in human behaviour and lifestyles.

Actions or measures to adapt freshwater systems to climate change.

Actions to adapt human health, healthcare systems and well-being to climate change.

Actions and measures to adapt and increase resilience of societies and the economy to climate change.

Actions or measures to adapt freshwater, coastal and marine systems to climate change.

The release of heat-trapping gases, primarily from human activities such as burning fossil fuels, agriculture and industry.

Risks to the ecosystem health of the marine environment, including ocean warming, ocean acidification, and ocean deoxygenation, harming biodiversity, species health, ecosystem services, and coastal community livelihoods.

Extreme weather refers to events where a weather variable exceeds (or falls below) a threshold. Meaning it is significantly different from the average or usual weather pattern.

Terrestrial means "of the earth" and relates to the risks to ecological system that includes all living organisms and their interactions within land-based environments, such as forests, grasslands, and deserts.

Social inclusion is the process of improving the terms on which individuals and groups take part in society—improving the ability, opportunity, and dignity of those disadvantaged on the basis of their identity.

The activities of industries that transforms raw materials into finished goods through industrial processes.

This sector involves managing waste treatment, sanitation, pollution control and environmental cleanup.

Activities that involve planning, designing and building infrastructure, residential, and commercial structures.

This sector involves activities that impart knowledge and skills to individuals, including formal schooling, vocational training and educational support.

Activities of government agencies and institutions that provide public services, enforce laws and manage public resources.

This sector includes firms and individuals offering specialised expertise in fields such as law, accounting, consulting, science and engineering.

Activities of businesses and institutions that provide financial services and products to individuals and organisations.

Activities that involve the cultivation of crops and raising of livestock for food, fibre, and other products essential for human life and industry.

This sector involves the distribution, treatment, and conservation of water resources.

This sector provides medical services, manufactures medical equipment, and develops pharmaceuticals to maintain and improve health.

Slow onset events evolve gradually from incremental changes over many years or from increased frequency or intensity of recurring events. As defined in the Cancun Adaptation Framework (2010), slow onset events include risks and impacts from rising temperatures, desertification, biodiversity loss, land and forest degradation, glacial retreat, ocean acidification, sea level rise, and salinization.

IDC and SIS vs. Comissão de Valores Mobiliários (Nullity of CVM Resolution 244/2026) - complaint

Policy instrument

Risk

Impacted group

Just transition

Greenhouse gas

Economic sector

Adaptation/resilience

Finance