Your Brazilian customer has sent you an ESG questionnaire. Here is what the law requires of them — and what they need from you.
Brazil has introduced mandatory ESG reporting for all publicly listed companies from January 2026, based on 2025 data. The Brazilian Securities and Exchange Commission (CVM) resolution requires ISSB-aligned sustainability disclosures, making Brazil one of the first major emerging economies to mandate climate and sustainability reporting at this scale. Brazil is also hosting COP30 in Belém in November 2025, reinforcing its international commitment to climate action. If you supply goods or services to a Brazilian buyer, or if your Brazilian buyer supplies international markets, ESG compliance evidence is now a procurement and regulatory requirement.
Key regulations in Brazil — ESG & Sustainability Reporting Supplier Guide
CVM Resolution — Mandatory Sustainability Reporting
Brazil's Securities and Exchange Commission (Comissão de Valores Mobiliários — CVM) has mandated ISSB-aligned sustainability reporting for all publicly listed companies. Reports must cover IFRS S1 (general sustainability-related disclosures) and IFRS S2 (climate-related disclosures), including supply chain emissions and due diligence. The voluntary window has closed — mandatory compliance is now in effect.
Brazilian Taxonomy for Sustainable Finance
The Brazilian Sustainable Taxonomy was officially established on October 31, 2025 by Decree No. 12,705/2025, making Brazil one of the first major emerging economies to formalise a national sustainable finance taxonomy. Implementation is phased — voluntary initially, with mandatory requirements expected to follow within three years. The taxonomy will guide companies on what qualifies as sustainable economic activity and create additional supply chain disclosure requirements as it is implemented.
EU CSRD & CSDDD — Reach into Brazilian Suppliers
Brazilian companies that supply European buyers are already subject to ESG questionnaires driven by the EU Corporate Sustainability Reporting Directive and the incoming Corporate Sustainability Due Diligence Directive. The CSDDD transposition deadline for EU member states has been delayed to July 26, 2028, with compliance required by July 2029. European buyers are legally required to assess their supply chains — including suppliers based in Brazil. This is particularly relevant for Brazilian companies in agriculture, mining, manufacturing, and textiles that supply EU markets.
US SEC Climate Disclosure Rules / California SB 253
Brazilian companies supplying US buyers — particularly large US companies subject to SEC climate disclosure rules or California SB 253 — will receive ESG questionnaires as US buyers assess their supply chain emissions. California SB 253 requires companies with revenues over $1 billion doing business in California to disclose Scope 1, 2, and 3 emissions — which includes supply chain data from Brazilian suppliers.
LGPD — Lei Geral de Proteção de Dados (Brazil General Data Protection Law)
Brazil's LGPD requires organisations to notify the National Data Protection Authority (ANPD) and affected data subjects of security incidents that may cause significant risk or harm. ANPD guidance specifies notification within 2 working days of awareness. The ANPD can impose fines of up to 2% of Brazilian revenue, capped at R$50 million per violation. LGPD applies to any organisation processing personal data of individuals in Brazil, regardless of where the organisation is based. Brazilian companies in international supply chains must comply with both LGPD and the data protection laws of their buyers' jurisdictions (EU GDPR, UK GDPR, etc.).
What this means for you as a supplier
You may not be directly regulated by all of these frameworks. But your Brazilian buyer is — and so are the European and US buyers in your supply chain. CVM-listed companies must now disclose supply chain sustainability data under mandatory ISSB-aligned rules. European buyers must assess Brazilian suppliers under CSRD and CSDDD. US buyers must assess Brazilian suppliers under SEC and California rules. A non-response or a weak response increases your buyer's regulatory risk and makes you a liability in their supply chain.
Key dates
2024–2025
CVM voluntary sustainability reporting period — companies encouraged to adopt ISSB standards ahead of mandatory deadline
1 January 2026
CVM mandatory sustainability reporting in force — all listed companies must comply based on FY 2025 data
November 2025
COP30 hosted in Belém, Brazil — international spotlight on Brazilian climate commitments and corporate action
2026 onwards
Brazilian Taxonomy for Sustainable Finance — additional supply chain reporting guidance expected
2026
California SB 253 mandatory Scope 3 reporting — US buyers must disclose supply chain emissions including Brazilian suppliers
October 31, 2025
Brazilian Sustainable Taxonomy established by Decree No. 12,705/2025 — phased implementation begins
July 2029
EU CSDDD compliance required — EU companies must conduct active supply chain due diligence; Brazilian suppliers will receive structured questionnaires
Why Brazil's ESG requirements matter for suppliers
Brazil is one of the world's largest economies and a major supplier to EU, US, and Asian markets across agriculture, mining, manufacturing, and services. The CVM mandatory reporting requirement means that Brazilian listed companies — which include many of the country's largest buyers — must now disclose supply chain sustainability data. This creates a direct and legally grounded requirement for their suppliers to provide ESG evidence.
Brazil's role as COP30 host amplifies the regulatory momentum. International attention on Brazilian climate commitments is at its highest point in years, and companies that cannot demonstrate credible ESG practices face both regulatory and reputational pressure from buyers, investors, and international partners.
What your Brazilian buyer's questionnaire will ask
Brazilian ESG questionnaires draw on CVM/ISSB requirements, GRI Standards, and — for companies with international buyers — EU CSRD, US SEC, and California SB 253 requirements. The following areas are consistently covered.
Climate-related disclosures (IFRS S2)
Greenhouse gas emissions (Scope 1, 2, and Scope 3 supply chain emissions), climate risk assessment, and transition planning. The CVM mandate is ISSB-aligned — IFRS S2 is the framework. Your buyer needs your emissions data to complete their mandatory disclosure.
General sustainability disclosures (IFRS S1)
Material sustainability-related risks and opportunities affecting your business. How your company identifies, assesses, and manages sustainability risks. This is the broader context in which climate data sits.
Labour rights and social standards
Compliance with Brazilian labour law (CLT), fair wages, working hours, health and safety, and freedom of association. International buyers will additionally ask about ILO core conventions and living wage standards.
Deforestation and land use
Particularly relevant for agricultural, food, and forestry supply chains. EU buyers subject to the EU Deforestation Regulation (EUDR) must verify that products are not linked to deforestation. Brazilian suppliers in these sectors will receive specific deforestation due diligence questionnaires.
Human rights due diligence
A written policy covering forced labour, child labour, and non-discrimination. Evidence that you assess your own supply chain for human rights risks. EU CSDDD buyers require documented human rights due diligence from their Brazilian suppliers.
Governance and anti-corruption
Anti-bribery and anti-corruption policies aligned with Brazil's Clean Companies Act (Lei Anticorrupção). Board oversight of ESG matters, and whistleblowing mechanisms.
Brazil's COP30 moment and what it means for supply chains
Brazil hosting COP30 in Belém in November 2025 placed Brazilian climate commitments under intense international scrutiny. The CVM mandatory reporting requirement was timed to demonstrate that Brazil's corporate sector is aligned with its national climate commitments. For supply chains, this means the ESG questionnaire from your Brazilian buyer is backed by a regulatory framework that is explicitly designed to be internationally credible and comparable — not a domestic box-ticking exercise.
The ISSB alignment of the CVM framework means that Brazilian company ESG reports are directly comparable with those of companies in the EU, UK, Australia, Japan, and Singapore — all of which are adopting ISSB-aligned standards. Suppliers who build their evidence base to ISSB standards will be able to respond to questionnaires from buyers in any of these markets with the same underlying data.
What happens if your response is inadequate
- →Your CVM-listed buyer must disclose supply chain sustainability data — a non-response from you creates a gap in their mandatory disclosure
- →EU buyers subject to EUDR (Deforestation Regulation) cannot import products linked to deforestation — Brazilian agricultural and forestry suppliers who cannot provide deforestation evidence face market exclusion
- →EU buyers subject to CSDDD may be required to source from suppliers who can demonstrate compliance — a non-response puts your contract at risk
- →US buyers subject to California SB 253 must disclose Scope 3 supply chain emissions — they need your emissions data to comply
- →International investors applying ESG screens to Brazilian companies and their supply chains will flag weak ESG credentials — affecting access to capital
Last reviewed: April 2026. This guide is for general information only and does not constitute legal advice. Regulations change — verify current requirements with a qualified adviser.
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