On October 29, 2026, the Special Secretariat for Carbon Markets (SEMC) of Brazil's Ministry of Finance published Ordinance (Portaria) No. 3,199. It sets the official schedule for phasing in greenhouse gas monitoring, reporting and verification (MRV) obligations under the Brazilian Emissions Trading System (SBCE). The legal basis is Law No. 15,042 of 2024, and the system is being brought into operation in stages through 2030.

Emitters of 10,000 tCO2e or more, brought in over three stages

MRV obligations apply to operators emitting 10,000 tCO2e or more a year, which the Ministry of Finance says is fewer than 1% of national corporate registrations (CNPJ). From 2030, companies emitting more than 25,000 tCO2e will bear obligations under the National Allocation Plan (PNA).

  1. 2027
    Stage 1

    Aluminium, integrated steelworks, cement, oil and gas exploration and production, part of the chemicals sector, iron ore and bauxite mining, pulp and paper, glass

  2. By 2029
    Stage 2

    Ceramics, semi-integrated steelworks, chemicals not in Stage 1, food and beverages, other mineral extraction, oil refining, electricity

  3. 2030 onward
    National Allocation Plan (PNA)

    Cap on total emissions and allocation of emission allowances (CBE). 100% free allocation at the start

  4. By 2031
    Stage 3

    Road, rail and water transport

Each stage follows a four-year preparation cycle. In year 1, operators draw up a monitoring plan; in years 2–3, they monitor emissions; in year 4, they compile data for the PNA. The Ministry of Finance states that the ordinance does not require immediate submission of reports and imposes neither an emissions cap nor costs in the initial phase.

The lines have moved since the July draft

The ordinance was put out for public consultation from July 28 to August 28, 2026, and received 938 comments. Comparing the draft with the final version shows that the scope of Stage 1 has changed.

Sectors whose stage changed between the draft and the final version
Oil refining and aviation left Stage 1, while glass and iron ore and bauxite mining moved into Stage 1
SectorJuly draftOctober final version
Oil refiningStage 1Stage 2
Air transportStage 1Not in the three-stage list
GlassStage 2Stage 1
Iron ore and bauxite miningStage 2 (mining)Stage 1
ChemicalsStage 2Partly moved to Stage 1
Waste and sewage treatmentStage 2Not in the three-stage list

Compiled by comparing the Ministry of Finance announcements of July 28 and October 29

Next: accreditation rules for verifiers

Through a decree and a series of ordinances, SEMC is putting in place the Brazilian MRV Program (PB-MRV), which will set general MRV guidelines, measurement methodologies and accreditation rules for third-party verification bodies (OVV). Public consultation on the draft decree is scheduled for November 2026, with publication targeted before the end of the year. A draft decree for the offset system (PBCE) will also go to consultation in November, with the first methodologies to be accredited in 2027. Stage 1 sectors and the Regulatory Affairs Council (CAREG) are to be set up during 2026.

What it means for corporate planning and procurement teams

  • Emissions data for Brazilian materials gains regulatory backing: Stage 1 lists materials industries such as steel, aluminium, pulp and paper, and cement. Because covered companies will draw up monitoring plans from 2027, companies sourcing these materials from Brazil will find it easier to request primary data for Scope 3
  • Watch the link with CBAM: the EU CBAM allows carbon prices paid in the exporting country to be deducted. Because Brazil's allocation starts in 2030 and is free at first, there will be no deductible carbon price for the time being. Aligning measurement methods for emissions data with CBAM's verification requirements can reduce duplicate work
  • Emerging-market ETSs are entering the legal stage: Türkiye published and enacted its ETS regulation in the Official Gazette on August 27. Brazil, too, is starting reporting obligations before allocation. Companies with local operations need to get their emissions data in order before allocation begins
  • What is still undecided: measurement methodologies and accreditation rules for verifiers will be set by draft decrees from November onward. The total volume of allowances and the allocation by sector will not be shown until the 2030 PNA

Referenced Fact Cards