Today (and not a moment too soon!), the implementation of the Brazilian Greenhouse Gas Emissions Trading System — SBCE is beginning to take on clearer contours, with the publication of CTCP/SBCE Resolutions No. 1, 2, 3, and 4/2026 by the Permanent Technical Advisory Committee of the SBCE (links at the end of this text).

It is worth emphasizing that these resolutions do not yet create direct obligations, but they are highly relevant because they expand the structuring of the technical governance framework that will guide the secondary regulation of the Brazilian Regulated Carbon Market.

Resolution No. 1/2026 approves the Internal Regulations of the CTCP/SBCE, a consultative body within the system responsible for providing input and recommendations for the improvement, implementation, and operation of the SBCE. The CTCP had already been regulated by Decree No. 12,768/2025, but the creation of the Internal Regulations is important because it formalizes the institutional environment in which highly diverse stakeholders — such as public agencies, economic sectors, academia, and civil society — will interact.

Meanwhile, Resolutions No. 2, 3, and 4/2026 establish three working groups on issues that are central to the credibility and operationalization of the system: financial aspects; monitoring, reporting, and verification of emissions — MRV; and methodologies for generating Verified Emissions Reduction or Removal Certificates — CRVEs. It can be said that these three pillars form the backbone of a functional carbon market: without secure financial rules, there is no liquidity or asset integrity; without robust MRV, there is no confidence in emissions data; and without consistent methodologies, there is no assurance regarding the environmental quality of credits and certificates.

The Financial Aspects Working Group will address financial instruments, market mechanisms, and risk management related to SBCE assets. This agenda is highly sensitive because the regulated carbon market will depend on secure infrastructure for registration, trading, custody, traceability, and asset integrity. It is also worth recalling that Law No. 15,042/2024, which established the SBCE, had already introduced innovation into Brazil’s capital markets legislation by incorporating carbon credits into the financial and capital markets.

On the other hand, the MRV Working Group may be the most relevant from a practical business perspective, as it will deal with defining the requirements for emissions monitoring, reporting, and independent verification. In other words, it is expected to provide decisive answers: who must report, how emissions must be measured, at what level of detail, according to which methodology, at what frequency, and under which verification standard. The robustness of this system will be absolutely critical to preventing inconsistencies and regulatory uncertainty.

Finally, the Methodologies Working Group plays an essential role in defining the technical criteria for accrediting and disaccrediting methodologies for generating CRVEs, as well as the requirements applicable to quantifying emissions reductions or removals. This point is also important because the environmental integrity of CRVEs depends on the adoption of rigorous, transparent criteria aligned with international best practices, while still taking Brazilian specificities into account.

From now on, an intense phase of secondary regulation is expected to begin. Suffice it to say that the Extraordinary Secretariat for the Carbon Market has announced as a goal the publication, by the end of this year, of all regulations necessary to implement Law No. 15,042/2024. In parallel, a platform under development by Serpro is expected to function as the central registry for the regulated market, bringing together emissions reporting, monitoring of decarbonization targets, and registration of tradable assets.

In this sense, I believe these resolutions should not be viewed as merely bureaucratic or procedural. They represent a bridge between the legislative and institutional phase and a new procedural regulatory stage, with the definition of technical, operational, and financial parameters that will enable the SBCE to operate with legal certainty, environmental integrity, and predictability for economic agents.

For potentially regulated companies, this is a time for preparation. Even before the market becomes operational, companies will need emissions inventories, internal systems for data collection and governance, assessments of regulatory risks, and identification of opportunities associated with decarbonization.

The SBCE is still under construction, but its technical foundations are now beginning to be laid.

https://www.in.gov.br/web/dou/-/resolucao-ctcp/sbce-n-1-de-11-de-maio-de-2026-704749212
https://www.in.gov.br/web/dou/-/resolucao-ctcp/sbce-n-2-de-11-de-maio-de-2026-704655774
https://www.in.gov.br/web/dou/-/resolucao-ctcp/sbce-n-3-de-11-de-maio-de-2026-704762640
https://www.in.gov.br/web/dou/-/resolucao-ctcp/sbce-n-4-de-11-de-maio-de-2026-704757098