Client Alerts

Brazil’s Ministry of Finance sets out the implementation stages for MRV obligations under the SBCE

November 12th, 2026

Brazil’s Ministry of Finance has published Ordinance SEMC/MF No. 3,199/2026, which establishes the implementation stages for the measurement, reporting and verification (MRV) obligations applicable to greenhouse gas (GHG) emissions and removals under the Brazilian Greenhouse Gas Emissions Trading System (SBCE).

The ordinance follows the proposal submitted to public consultation in July and introduces material changes to the implementation timeline, the allocation of sectors among the different stages and the identification of the covered economic activities.

MRV Obligations Implementation Timeline

Ordinance SEMC/MF No. 3,199/2026 provides for a sequence of annual actions:

Year 1 (A1)	Submission of the monitoring plan to the SBCE managing body for review and approval.
Year 2 (A2)	Measurement of GHG emissions and removals throughout the ongoing calendar year, in accordance with the approved monitoring plan.
Year 3 (A3) onwards	Continued measurement of GHG emissions and removals in the ongoing year and submission to the SBCE managing body of the verified report covering emissions and removals for the previous calendar year.

Implementation will be phased in three stages and covers the following sectors:

First stage

(Y1 in 2027)

Aluminum, iron and steel (integrated mills), cement, oil and natural gas exploration and production, chemicals (manufacture of adipic acid, phosphoric acid, nitric acid, ammonia, ethylene, dichloroethane, vinyl chloride and carbon black), mining (iron ore and bauxite), pulp and paper, and glass.

Second stage

(Y1 by 2029)

Ceramics, iron and steel (semi-integrated mills), the chemical and mining segments listed in Annex II of the ordinance, food and beverages, oil refining and the power sector.

Third stage

(Y1 by 2031)

Waterway, rail and road transportation.

At least 150 days before the obligations are due, the managing body must publish the content and format requirements, as well as the deadlines and procedures for submitting the monitoring plan and the verified emissions and removals report.

From proposal to ordinance: key changes

Compared with the proposal submitted to public consultation, Ordinance SEMC/MF No. 3,199/2026 significantly alters sector allocation among the implementation schedule:

Chemicals and mining	Now split between Stages 1 and 2. Certain chemical activities and iron ore and bauxite mining were moved up to Stage 1.
Glass	Moved up to Stage 1.
Oil refining	Moved to Stage 2.
Waste and sewage	No longer included in the published timeline. According to the Ministry of Finance, these sectors will receive specific regulatory treatment.
Aluminum	The covered activities were changed.
Air transport	Originally slated for Stage 1 but no longer part of the timeline. The sector’s obligations will line up with the National Civil Aviation Agency (ANAC) regulations applicable to ProBioQAV (Brazil’s national sustainable aviation fuel program), with information interoperability mechanisms between ANAC and the SBCE managing body, in compliance with applicable law and SBCE regulations.

The annexes have also been reorganized and now list more specific National Classification of Economic Activities (CNAE) codes, reflecting, for instance, the split of chemical and mineral activities between the first two stages. Coverage analysis should therefore factor in the codes and activities listed in each annex, and not merely the general name of the economic sector.

However, although CNAE codes identify the covered sectors, such mention does not automatically subject every activity that falls under each code to MRV obligations. The managing body must specifically provide for the regulated sources, facilities and activities subject to MRV obligations, factoring in the particularities of MRV procedures applicable to each sector. In addition, the ordinance’s annexes establish that a regulated activity will be subject to MRV obligations even where it corresponds to the establishment’s secondary CNAE code.

Next steps

This year should also see the establishment of the Regulatory Affairs Chamber (CAREG), featuring sectors included in the first stage. In addition, the implementation of two key programs should be subject to public consultation:

Brazilian Measurement, Reporting and Verification Program (PB-MRV)
Brazilian Emissions Offset Program (PBCE)

These initiatives are expected to detail key elements for the operationalization of the SBCE, including MRV guidelines and methodologies, as well as criteria for the accreditation of methodologies aimed at generating Verified Emission Reduction or Removal Certificates (CRVEs).

Demarest’s Environmental and ESG teams are available to provide further clarification.