SUSEP proposes expanding independent audit requirements for supervised entities in the S3 segment

Brazil’s Superintendence of Private Insurance (SUSEP) published in the Federal Official Gazette Public Consultation Notices No. 4/2026 and No. 6/2026, which submit for public consultation, respectively, the draft SUSEP resolution amending SUSEP Circular No. 648/2021 and the draft CNSP resolution amending CNSP Resolution No. 432/2021.

The drafts incorporate the same regulatory process and aim to allow the authority to require an independent audit of the interim financial statements of supervised entities in the S3 segment when, on an exceptional basis and for prudential reasons, it determines that such statements should be submitted.

Under the current rules, supervised entities in the S3 segment are not required to prepare interim financial statements, but SUSEP may, upon technical justification, request their submission (Article 111, Paragraph 3, of SUSEP Circular No. 648/2021). In such cases, however, the statements are exempt from audit (Article 112, sole paragraph, of the Circular), an exemption that reflects the waiver set forth in Article 137, sole paragraph, of CNSP Resolution No. 432/2021. As the circular is based on the resolution, SUSEP could not require, solely by its own regulation, audit documents whose preparation is waived by the CNSP; hence the need to amend both regulations.

To overcome this limitation, Public Consultation No. 6/2026 proposes amending the sole paragraph of Article 137 of CNSP Resolution No. 432/2021, which currently exempts supervised entities in the S3 and S4 segments from preparing and submitting to SUSEP the audit reports and other audit-related documents provided for in Article 136 (independent auditor’s report, detailed reports, and other documents requested by SUSEP) related to financial statements. Under the draft, the exemption would apply only to the S4 segment.

Complementarily, Public Consultation No. 4/2026 proposes amending Paragraph 3 of Article 111 of SUSEP Circular No. 648/2021 to:

• provide that SUSEP may request that S3 supervised entities “prepare” and submit interim financial statements; and
• include the corresponding independent auditor’s report among the documents comprising such statements. The draft also revokes the sole paragraph of Article 112, which currently exempts these statements from audit.

The proposals do not create a periodic obligation for S3 supervised entities to prepare interim financial statements. According to the comparison chart, supervised entities will only be required to prepare the documentation, including the independent auditor’s report, upon a specific and technically justified request from SUSEP.

According to SUSEP, the amendment is intended to attest to the reliability and regularity of interim financial statements required for prudential reasons, particularly in more severe prudential situations.

In this context, the independent accounting audit is treated as an important line of defense within the governance and internal controls framework, since accounting statements constitute essential input for the supervisory activities carried out by SUSEP.

From a practical standpoint, SUSEP itself acknowledges that including the independent auditor’s report among the documents that may be requested will increase costs for supervised entities. It is recommended that S3 supervised entities assess, together with their independent auditors, their ability to comply with potential requests within short timeframes. SUSEP proposed waiving the Regulatory Impact Analysis, as this measure is intended to preserve the liquidity, solvency, or soundness of the supervised markets (Article 4, V, “a”, of Decree No. 10,411/2020).

Interested parties may submit comments and suggestions within 30 calendar days from the publication of the notices (September 17, 2026), exclusively through the SUSEP Public Consultation System. Submissions made through other channels will be disregarded.

For more information, access: SUSEP Public Consultation System.

Demarest’s Insurance, Reinsurance, Health, and Private Pension team is closely monitoring the matter and remains available to assist in assessing the regulatory impacts of the proposals and preparing any contributions to the public consultations.