CVM Resolution 244 and non-mandatory nature. The difficult decision has only just begun, and some points will still generate discussion.

The repeal of the mandatory CBPS/ISSB requirement does not eliminate the demand for transparency. It transfers to companies the responsibility of evaluating, justifying, and supporting their disclosure strategy to investors and other stakeholders.

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Last Friday (29/05), the CVM Resolution 244 The regulation revoked the provision that would have made it mandatory, starting with fiscal years beginning in 2026, for publicly traded companies to report sustainability-related financial information in accordance with the CBPS/ISSB standard. Together with the @FersoESG team, we have compiled this more detailed analysis.

At first glance, it seems that the situation has "eased up," but the conversation among those on the board tells a different story.

What has actually changed:

  • The mandatory requirement is over. Participation is back to normal. volunteer.
  • But the technical standard remains: those who choose to disclose their information are still obligated to comply with CBPS/ISSB. in fullThere is no room for each company to create its own methodology.
  • Starting in 2027, the company that chooses to If you don't publish, you'll have to justify it. The decision is left to the market. It's the "comply or explain" model. Not being transparent is no longer an option..
  • Those who enter, make a commitment: minimum of three consecutive exercises, with one year's notice to discontinue.

Notice the shift. We've moved away from a world where the question was... "How to meet the deadline?" e we enter a point where the question becomes "Reporting is the best allocation of my investors' capital and my team's efforts; can I defend this choice publicly?".

This changes who decides and , the The decision is made. The agenda leaves the compliance department and goes to the strategy and governance areas.

Three points that will continue to generate discussion — and that few noticed on the first day:

  1. the rule of assurance It has not been revoked. Taken literally, reasonable assurance remains valid for those reporting from 2026 onwards—which makes voluntary adherence more challenging than it initially seems.
  2. Os deadlines tightened For those who choose to disclose: the reference date will be the date on the Reference Form starting in the first year.
  3. A Market pressure has not disappeared.CSRD in the European value chain, investor demands, and ISSB-aligned jurisdictions remain. Brazilian regulation has become lighter; the demand for reliable information has not.

Reading, then, is not "less work." It is different workTo decide methodically whether reporting is worthwhile, to justify the choice of who will not report, and, for those who do, to transform what was a minimum obligation into a differentiating factor of credibility and access to capital.

I've been talking to companies about this very decision point. For some, the way forward is to report well and use that as a signal of good governance. For others, it's about building a solid and defensible justification for why they're not reporting now. Neither can be resolved on the fly—and both have deadlines.

If your company is at this crossroads, the best time to formulate a response is before the market asks. I'm available to exchange ideas in the comments or privately.

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