Agribusiness Newsletter | December 2025 and January 2026

The Agribusiness Newsletter brings information and news about the main regulations and legal texts relating to the regulation of agribusiness in Brazil. This initiative seeks to cover the agribusiness industry on its transactional, litigation, tax and regulatory levels, and is an invitation for all of those working in this market to both access important news and comments on vital topics from the sector.

This material is for informative purposes only, and should not be used for decision-making. Specific legal advice can be provided by our legal team.

Brazil’s capital market breaks historic record and closes 2025 with BRL 838.8 billion in public offerings

The Brazilian capital market ended 2025 with a historic performance, reaching BRL 838.8 billion in public offerings – a 6.4% increase from 2024 and the highest volume ever recorded since its launch in 2012.   The last quarter was decisive for this result, having concentrated 37.1% of the year’s funding. December 2025 registered the highest monthly volume in history, with BRL 116.1 billion in issuances.

The securitization segment showed substantial expansion, with Credit Rights Investment Funds (“FIDCs”) raising a record BRL 90.8 billion, representing 42% of the number of fixed-income offers in the year and surpassing 1,000 transactions – evidence of the growing use by companies of all sizes. Agribusiness Receivables Certificates (“CRAs”), which are directly associated with agribusiness, rose by 11.1%, having reached the mark of BRL 46.2 billion, consolidating as an essential tool for financing producers, trading companies, and companies in the agro-industrial sector.

As far as hybrid securities are concerned, Real Estate Investment Funds (“FIIs”) and Investment Funds in Agribusiness Production Chains (“FIAGROs“) raised a combined BRL 85.5 billion, with a 77.2% increase in FII offerings and BRL 6.4 billion raised by FIAGROs – a 31.3% increase over the year. The figures show the continued expansion of these products as vehicles to access the real estate and agribusiness markets via periodic income and quota appreciation.

For more information, access: Capital market offerings reach BRL 838.8 billion and break record in 2025.

CVM’s Open Data Portal publishes further data on investment funds

The Open Data Portal (“Portal Dados Abertos”) of Brazil’s Securities and Exchange Commission (CVM) has enabled a new feature to users: “Investment Funds: Documents: Submission”. The tool gathers metadata regarding the submission of periodic and occasional documents within the scope of investment funds from 2021 onwards.

CVM’s Open Data Portal, maintained by CVM’s Analytical Data Engineering Management, aims to ensure transparency and concentrate all the public information released by the CVM about the participants it regulates in a single channel, facilitating search and simplifying user access to data. Accordingly, the platform, which is integrated with the Brazilian Open Data Portal, also allows data exchange with other public bodies and entities.

For more information, access: CVM’s Open Data Portal provides new data on investment funds

MAPA publishes annual balance of pesticide and bioinput registrations for 2025

On January 04, 2026, the Ministry of Agriculture and Livestock (“MAPA”) published the annual balance of pesticide and related registrations granted in 2025, which was consolidated in Act No. 63 of the General Coordination of Pesticides and Related Products. The report shows a historical record of bio-input releases, as well as significant progress in modernizing the regulatory framework applicable to the sector.

Over the course of 2025, 912 registrations were granted, including 323 technical products (for industrial use), 101 equivalent products, 15 additional bio-inputs, and 1 new chemical active ingredient. The year was also marked by the approval of 162 products classified as bio-inputs – the highest volume ever recorded in Brazil.

In addition, 6 new technical products were registered and 19 products were formulated  based on new active ingredients, reinforcing the updating of the national phytosanitary portfolio by introducing more modern and sustainable technologies.

Among the key points addressed by the regulation, we highlight:

• New molecules such as Ipflufenoquine, Fluoxastrobin, Fluazaindolizine, Isopirazam, Fenpropidin, and Cyclobutrifluram have been added to the market, expanding the modes of action and strengthening integrated pest management.
• Contribution to reducing the risk of resistance, increasing agronomic efficiency, and stimulating national technological development.
• Issuance of Act No. 62/2025, which standardizes and centralizes the protocol, distribution, and processing of registration and post-registration applications in the country. As of September 15, 2025, all new applications will be filed exclusively through the Electronic Information System, and protocols filed directly with the Brazilian Health Surveillance Agency (“ANVISA”) or the Brazilian Institute for the Environment and Renewable Natural Resources (“IBAMA”) will no longer be considered for the purposes of organizing the queue.

• Public consultation on the National Strategy for Border Carbon Adjustment and Industrial Competitiveness closes on January 30, 2026

TAX REGULATION

Second part of Tax Reform on consumption published

On January 14, 2026, Supplementary Law No. 227/2026 was published, marking the second stage of the regulation of the Tax Reform on consumption and amending the provisions of Supplementary Law No. 214/2025. The new law formalizes the creation of the Goods and Services Tax (“IBS”) Management Committee – the body responsible for centralizing the collection and distribution of revenue between states, the Federal District, and cities, as well as standardizing procedures and interpretations. The regulation also establishes the basis for the administrative process, defines the rules for the transition of the Tax on the Circulation of Goods and Services (“ICMS”) until it is extinguished, in 2033, and amends numerous provisions in Supplementary Law No. 214/2025.

For more information, access: Supplementary Law No. 227/2026 on Tax Reform published

Brazil’s RFB publishes asset value update declaration

The Brazilian Federal Revenue Service (“RFB”) has published the Declaration of Option for the Special Regime for Asset Value Update (“DEAP”), which formalizes adherence to the Special Regime for Asset Update and Regularization – Update Modality (“REARP Atualização“), established by Law No. 15,265/25 and regulated by RFB Normative Instruction No. 2,302/25. REARP Atualização authorizes individuals and legal entities to update the value of movable and immovable assets, located in Brazil or abroad, acquired with resources of lawful origin until December 31, 2024. For individuals, the difference between the updated value and the acquisition value of the assets will be definitively taxed under the Individual Income Tax (“IRPF”) at a rate of 4%. For legal entities, the difference between the market value and the acquisition cost will be subject to the Corporate Income Tax (“IRPJ”) at a rate of 4.8% and Social Contribution on Net Profits (“CSLL”) at a rate of 3.2%, also definitively. The declaration must be submitted by February 19, 2026, in compliance with the RFB’s guidelines.

ENVIRONMENTAL REGULATION

• Soy Moratorium, concessions, and tax incentives

FEDERAL

Judicial intervention of Soy Moratorium halts proceedings before CADE; Mato Grosso issues regulations restricting tax incentives for companies that are signatories to environmental pacts

The future of the Soy Moratorium, a voluntary pact of Brazilian agribusiness, now depends directly on the Federal Supreme Court (“STF”) after an escalation of conflicts involving the Administrative Council for Economic Defense (“CADE”), the productive sector, and the state government of Mato Grosso.

In November 2025, CADE expanded its performance by opening a new investigation against 15 individuals linked to companies that executed the Soy Moratorium, seeking to ascertain individual responsibility regarding the execution and monitoring of the pact. In parallel, the Brazilian Association of Vegetable Oil Industries (“ABIOVE”) filed ADI No. 7774 with the STF, arguing that the existence of multiple lawsuits and administrative proceedings over the Soy Moratorium created legal uncertainty and the risk of contradictory decisions.

On November 05, 2025, Justice Flávio Dino granted ABIOVE’s request and ordered a nationwide suspension of all lawsuits addressing the legality or constitutionality of the Soy Moratorium. The decision was later upheld by the STF’s plenary session.  In compliance with the STF’s order, on November 11, 2025, CADE suspended all measures and investigations involving the Soy Moratorium until the final judgment by the STF.

While the judicialization progresses, on December 30, 2025, the government of Mato Grosso published State Decree No. 1,795/2025, regulating Article 2 of State Law No. 12,709/2024. The rule, whose effectiveness was re-established by the STF as of January 01, 2026, prohibits the granting of tax incentives and public land to companies that enter into commitments – either local or international – restricting agricultural expansion in areas that are not protected by law.

The restriction applies to companies and their economic groups, and also covers commitments undertaken as of December 31, 2025, or, when executed by representative entities – in the event that the company expressly adheres to them.

General tax benefits, granted regardless of accreditation or counterparts, remain outside the scope of the prohibitions. In addition, immunity, non-incidence, and operations with deferral or suspension of the ICMS do not constitute tax benefits – even if they depend on accreditation or a counterpart.

A central point of Decree No. 1,795/2025 is that mere participation in agreements or commitments is not enough to trigger the ban – proof is required that they result in restrictions on agricultural expansion. Decree No. 1,795/2025 also makes an exception for international treaties entered into by the Federative Republic of Brazil in the exercise of sovereignty, which do not impose restrictions for the purposes of the ban.

Finally, incentives granted from 2026 onwards can be revoked if the company adheres to restrictive commitments, with the obligation to repay the amounts.

• Environmental Rural Registry

TOCANTINS

State of Tocantins regulates procedure for challenging hydrography data on rural real estate in the CAR and in environmental licensing

On December 23, 2025, the Tocantins Nature Institute (“NATURATINS”) published Normative Instruction No. 4/2025, establishing procedures for challenging  hydrographic elements (rivers, streams, springs, lakes, and other bodies of water) represented in the official cartographic bases used by the agency in the Rural Environmental Registry (“CAR”), in Forest Exploration Authorizations, and in environmental licensing.

Objections can be filed whenever the interested party believes that the official hydrography does not correspond to reality in a certain field. To this end, the request must be accompanied by a technical report entered into by a qualified professional.

Verification by remote methods (satellite and drone images) is permitted in areas that are difficult to access, provided that it is adequately justified. NATURATINS’ technical team can conduct validations using remote sensing, request additions, or recommend in loco surveys.  The result will be formalized in a conclusive opinion, classifying the challenge as “granted”, “partially granted”, or “denied”. Denied challenges can be resubmitted based on new evidence.

PARÁ

State of Pará publishes new normative instruction on CAR cancellation and suspension

On January 13, 2026, the State Secretariat for the Environment, Climate, and Sustainability (“SEMAS”) published Normative Instruction (“IN”) No. 1/2026, establishing the administrative procedure for the cancellation and suspension of CAR registrations recorded in the National Rural Environmental Registry System (“SICAR”) within the scope of the state government of Pará.

IN No. 1/2026 defines the cases in which the CAR can be canceled on a definitive basis, such as duplicate registrations, unification of real estate, transformation into urban perimeter, court decision, overlapping above the tolerance limits with protected areas or regularly titled estate, submission of false or missing information, and justified requests from the owner. Cancellation can be carried out at the request of the interested party or ex officio by SEMAS in the event of technical or legal indications of irregularity.

With regard to the suspension of the CAR, a precautionary and temporary measure can be applied in situations such as evidence of falsehood in the information declared, non-compliance with notifications, relevant overlaps with protected areas or validated CARs, court orders, complex land disputes, or requests from control bodies. During suspension, the CAR will not take effect until there is a decision on its withdrawal, reactivation, or permanent cancellation.

For more information, access: SEMAS publishes regulation governing cancellation and suspension of CAR in Pará

• Environmental Licensing

FEDERAL

Special Environmental License created for strategic projects

On December 03, 2025, Brazil’s Senate approved Provisional Measure No. 1,308/2025, converted into Conversion Bill (“PL”) No. 11/2025, creating the Special Environmental License (“LAE”) for projects considered strategic by the Federal Government.

On December 23, 2025, the Federal Senate registered that Bill No. 11/2025 had been transformed into a legal norm. On the same date, Brazil’s Presidency sanctioned Law No. 15,300/2025. A draft legislative decree is currently awaiting a submission by the Joint Committee or the reporting officer for regulation.

The LAE will apply to activities or projects defined as strategic by decree, based on the Government Council’s biannual proposal. Among the cases expressly provided for are the reconstruction and resurfacing works on pre-existing highways connecting federal units, such as BR-319 highway, which links Porto Velho/RO to Manaus/AM. The regulation will also allow projects that use environmental resources and cause significant environmental degradation to apply for LAE, provided that they comply with the established conditions.

In parallel, the law has been the subject of legal challenges, via three Direct Actions of Unconstitutionality (“ADI”) – ADI No. 7913, ADI No. 7916, and ADI No. 7919 –, since December 2025, at the STF, by political parties (Partido Verde, Rede Sustentabilidade, and Partido Socialismo e Liberdade), as well as representative entities, such as the National Association of Municipal Environmental Bodies (“ANAMMA”), and the Articulation of Indigenous Peoples of Brazil (“APIB”). The entities challenge the provisions of both Federal Law No. 15,190/2025 and Federal Law No. 15,300/2025.

The proceedings indicate violations of constitutional principles, such as the right to a balanced environment (Article 225 of the Federal Constitution), the requirement for a prior environmental impact study, and the protection of indigenous peoples and traditional communities (Articles 216 and 231).

The proceedings were assigned to Justice Alexandre de Moraes and are currently in the initial stages with the STF. So far, there has been no preliminary injunction, no analysis of the merits, and no inclusion on the trial agenda.

For more information, access: Provisional Measure No. 1308, of 2025 / Political parties and associations question provisions of the General Environmental Licensing Law

IPHAN publishes new normative instruction and standardizes in environmental licensing actions

On December 01, 2025, the National Historical and Artistic Heritage Institute (“IPHAN”) published IN No. 6/2025, replacing IPHAN IN No. 01/2015 and reformulating the procedures for assessing impacts on cultural heritage in federal, state, district, and municipal environmental licensing.

In general terms, the normative instruction:

• Standardizes the analysis flow, broadens IPHAN’s integration with licensing bodies, and establishes more detailed requirements for projects with the potential to affect cultural assets (whether listed, registered, protected, valued, accredited, or in the process of recognition).
• Establishes a new analysis system based on the Activity Characterization Form (“FCA”), made available in the Heritage Impact Assessment System. The Specific Term of Reference is now issued automatically through the system, and is valid for two years, including the possibility of revalidation.
• Rearranges the required studies, with an emphasis on the Impact Assessment Reports for intangible, tangible, and archaeological assets, and formalizes the classification of projects by level, determining different requirements and field protocols for each type.
• The Impact Management Programs for cultural assets – including the management of intangible, tangible, and archaeological assets, and the integrated heritage education project – all interlinked with the content of the studies. Management reports and the Integrated Heritage Education Report are now a prerequisite for IPHAN’s conclusive opinion during the installation, operation, and renewal phases of the Operating License.

The regulation also established deadlines for IPHAN’s review and statements, ranging, for example, from 15 days for the analysis of FCAs to 60 days for the issuance of conclusive opinions – and up to 90 days in cases involving the preparation of an Environmental Impact Study and its corresponding report (“EIA/RIMA”).

For more information, access: New rules update IPHAN’s role in environmental licensing processes

PARANÁ

State of Paraná regulates exemption of several agricultural activities from environmental licensing

On January 06, 2026, the Water and Land Institute (“IAT”) published IN No. 1/2026 establishing the list of agricultural activities and projects considered to be unenforceable for environmental licensing in the state of Paraná.

The rule supplements the state framework introduced by State Law No. 22,252/2024, which provides general rules for environmental licensing, and by State Decree No. 9,541/2025, which regulates State Law No. 22,252/2024. Both regulations already provided for the possibility of exemption for low-impact activities.

The list of exempt activities is broad and includes traditional agricultural and livestock practices, routine rural production investments, and modernization initiatives. The list includes activities related to sustainable forest management, the establishment of planted forests, animal traceability, sanitary and environmental adjustments, pasture clearing without the commercial use of wood, among other low-impact rural measures.

IN No. 1/2026 also regulates the Declaration of Unenforceability of Environmental License (“DILA”), which can be requested by the interested party when there is a need to formally document the exemption from licensing. The DILA will be valid for 180 days and can be renewed, provided that the conditions that justified its issuance are maintained.

Any change in the conditions initially declared that increases the polluting potential or requires significant environmental intervention subjects entrepreneurs to apply for a license compatible with the new framework.

RIO GRANDE DO NORTE

State of Rio Grande do Norte regulates environmental licensing for green hydrogen production

On January 08, 2026, the State Environmental Council of Rio Grande do Norte (“CONEMA”) approved CONEMA Resolution No. 2/2025, defining the procedures, criteria, and parameters for environmental licensing of green hydrogen production projects.

The regulation is in line with the federal legal framework for low-emission hydrogen (Federal Law No. 14,948/2024) and the state legal framework for hydrogen and green industry (State Law No. 12,336/2025), structuring a specific procedure for the green hydrogen chain in the state of Rio Grande do Norte.

According to Resolution No. 2/2025, electrolyzers with a capacity of up to 10 megawatts are exempt from licensing, provided that the project is not located within a Conservation Unit or its Buffer Zone, a Permanent Preservation Area (“APP”), an area involving native vegetation suppression, priority conservation areas, or areas with technically justified socioenvironmental vulnerabilities.

Regardless of the size of the project, the Risk Analysis Study, the Risk Management Plan, and the Emergency Action Plan will be required as part of the environmental licensing.

Annex I of Resolution No. 2/2025 classifies the size of the project  according to the total power of the electrolyzers and their annual production (in terms of tons/year), indicating the environmental impact studies that must be prepared for each size, as follows:

• Micro and small size: Environmental Assessment Report;
• Medium and large size: Simplified Environmental Report; and
• Exceptional size: Environmental Impact Assessment and corresponding report.

TOCANTINS

State of Tocantins initiates studies to regulate new environmental licensing law

On January 20, 2026, NATURATINS and the Secretariat for the Environment and Water Resources (“SEMARH”) began drafting a new environmental licensing law for the State of Tocantins.

The initiative launches a new stage in Tocantins’ environmental policy and comes at a time when licensing is still governed by State Law No. 3,804/2021, which establishes  the procedures and instruments applicable to environmental licensing in the state.

The preliminary studies and discussions will be conducted in an integrated manner, including inter-institutional coordination and the participation of society and the productive sectors. The expectation is that the new regulations will improve rules, provide greater legal certainty, and increase the efficiency of state-level licensing procedures.

For more information, access: NATURATINS and SEMARH begin studies to regulate the new Environmental Licensing Law in Tocantins

PIAUÍ

State of Piauí extends environmental licensing requirement for project financing

On January 09, 2026, the Piauí State Council for the Environment (“CONSEMA/PI”) – linked to SEMARH – published CONSEMA Resolution No. 59/2026, which repeals CONSEMA Resolution No. 59/2026 and establishes a new extension to the deadline for environmental licensing requirements for agroforestry and livestock projects that apply for financing from financial institutions.

The regulation aims to review and extend the previously established deadline, postponing until December 31, 2027, the requirement for environmental licensing applicable to agroforestry and livestock activities to obtain bank financing for operating and investment expenses. The decision was adopted ad referendum to align the deadline with the production sector’s demands and CONSEMA/PI’s administrative guidelines.

According to the resolution, financial institutions must require, as a condition for the instruction and granting of financing, the presentation of the environmental licensing application protocol, to be carried out at SEMARH, regarding the project that will benefit from the credit. As a result, even if the licensing process has not been completed, proof of the application filing will be sufficient to access financing during the extended period.

With the enactment of Resolution No. 59/2026, CONSEMA Resolution No. 58/2025 is expressly repealed, consolidating a new time frame for the requirement of environmental regularization linked to rural credit in the state of Piauí. The measure seeks to reconcile the environmental protection policy with the continuity of agroforestry and livestock activities, ensuring predictability and legal certainty for both entrepreneurs and financial institutions.

• Climate change, decarbonization, and carbon credits

FEDERAL

Ministry of the Environment and Climate Change, Ministry of Finance, and BNDES initiate structuring study on carbon credit certification in Brazil; Public notice will select technical analysis partner

On January 08, 2026, the Ministries of the Environment and Climate Change and Finance, in collaboration with the National Bank for Economic and Social Development (“BNDES”), executed a technical cooperation agreement to structure the foundations of the Brazilian carbon credit certification system – a step considered essential to consolidate the national voluntary market and enable its future interface with the Brazilian Emissions Trading System (“SBCE”).

This development was accompanied by the publication, on January 05, 2026, of Public Selection FEP Fomento Notice No. 01/2026, aimed at hiring an executing partner to develop the technical study “Carbon Credit Certification in Brazil”, with a budget of up to BRL 10 million and a term of 6 months (extendable at the discretion of the BNDES).

The study will be exclusively descriptive and informative, with no normative proposals, and will cover five main pillars:

• Diagnosis of the range of certifiers and verification bodies (Validation and Verification Body – “VVB”);
• Analysis of methodological gaps in existing standards, with a focus on emissions reduction (“REDD+”), ARR (Afforestation, Reforestation, and Revegetation), blue carbon, regenerative agriculture, and waste;
• Consolidated guidelines of national standards applicable to the certification and MRV (Monitoring, Reporting and Verification); and
• Study on cost reduction, scalability, and inclusion of small producers, traditional communities, and indigenous peoples.

However, the FEP Fomento Public Notice imposes eligibility rules: Organizations serving as certifiers, VVBs/OVVs, carbon project developers, or consultants with direct links to developers are excluded to avoid potential conflicts of interest (item 4.9). Thus, the public notice tends to attract academic institutions, research centers, or generalist consultancies with no direct involvement in certification or project development.

The deadline for submitting proposals to the BNDES was February 09, 2026, exclusively through the BNDES Customer Portal, through e-CNPJ access, for those participants with a Gov.br silver or gold level account.

For more information, access: MMA, Treasury and BNDES sign technical cooperation agreement to structure carbon credit certification

DISTRITO FEDERAL

Federal District establishes Low-Carbon Hydrogen Policy

On December 24, 2025, Decree No. 48,103/2025 was published, instituting the Low-Carbon Hydrogen District Policy, which establishes its objectives, guidelines, and governance structure.

The regulation provides definitions such as “low-carbon hydrogen” (produced with emissions below the limits stipulated by Federal Law No. 14,948/2024, which establishes the legal framework for low-carbon hydrogen, including the use of carbon capture and storage technologies). The regulation also defines “green hydrogen” (produced by electrolysis using renewable energy), “hydrogen production chain” (covering the process from production to end use), and “hydrogen derivatives”, such as green ammonia and methanol.

The District Policy aims to promote the integrated development of the hydrogen chain, stimulate its application in strategic sectors – such as public transportation, agriculture, and industrial processes, foster technological innovation, increase the use of renewable energies, and contribute to meeting the district’s targets for reducing greenhouse gas emissions.

The regulation also aims to strengthen the Federal District’s competitiveness in the domestic and international hydrogen markets and to encourage the issuance of carbon credits under the SBCE, established by Federal Law No. 15,042/2024.

The guidelines include basing public actions on technical studies, integrating economic and logistical sectors, encouraging innovation, overcoming regulatory barriers, and prioritizing the use of low-emission hydrogen in carbon-intensive activities. The regulation ensures alignment with federal policies, such as the National Hydrogen Program (“PNH2”), the Brazilian Hydrogen Certification System (“SBCH2”), and the Special Incentive Regime for Hydrogen Production (“REHIDRO”).

The regulation also created the District Hydrogen Policy Steering Committee, which is responsible for coordinating and monitoring its implementation, proposing normative measures, fostering coordination between public and private institutions, and promoting social participation through consultations and thematic workshops.

The Management Committee is expected to be established within 90 days of the decree’s entry into force and will have 180 days to draft the first District Low-Carbon Hydrogen Plan, which will include targets, indicators, and at least 2 priority pilot projects.

PARÁ

State of Pará advances toward issuing jurisdictional carbon credits on the voluntary market

On January 08, 2026, the State Government of Pará received formal acceptance from the Architecture for REDD+ Transactions (“ART/TREES”) of the registration and monitoring documents submitted for international certification. The confirmation demonstrates compliance with the technical requirements for this phase and enables the state of Pará to proceed to the next stages of the process.

The documents submitted to ART/TREES demonstrate a reduction of 38 million tons of CO₂ by 2023, resulting from the measures implemented under Pará’s Jurisdictional REDD+ System. Considering the system’s structure and performance projections, the state government of Pará expects to reach the mark of 260 million tons of carbon credits by 2027.

In 2024, during the New York Climate Week, Pará executed an unprecedented agreement for the sale of 12 million tons in jurisdictional credits – a transaction estimated at almost BRL 1 billion. As a result, 26 million tons of carbon credit remain available for sale for 2023.

Commercialization, however, depends on the conclusion of the Free, Prior, and Informed Consultations (“CLPIs”) related to the Jurisdictional REDD+ System. The state of Pará is currently conducting the largest participatory process in its history, with 47 consultations planned – 15 of which have already taken place –, ensuring the social participation of indigenous peoples, traditional communities, and other interested groups.

For more information, access: Pará takes decisive step to issue jurisdictional carbon credits on the voluntary market

• Solid Waste and Reverse Logistics

SÃO PAULO

CETESB updates rules on proof of reverse logistics in licensing until 2029

On December 10, 2025, Companhia Ambiental do Estado de São Paulo (“CETESB”) published Board Decision No. 079/2025/A, amending Board Decision No. 051/2024/P, which establishes the procedure for demonstrating compliance with reverse logistics within the scope of environmental licensing.

The new regulation extends the obligations until December 31, 2029, rearranging deadlines, targets, and methodological criteria for the sectors subject to SMA Resolution No. 45/2015. The resolution defines the guidelines for implementing and operationalizing post-consumer responsibility in the state of São Paulo, including packaging in general, real estate paints, over-the-counter household disinfectants, electronics, light bulbs, batteries, tires, lubricating oil and packaging, edible oil, oil filters, household medicines and packaging for products that make up the dry fraction of urban solid waste, as well as packaging with a significant environmental impact, such as those used for pesticides and automotive lubricating oil.

The second phase of the reverse logistics program extended through the end of 2025, with submission of the Annual Results Report (“RAR”) for the 2025 base year, due by July 30, 2026. For the period from 2026 to 2029, the RARs must be submitted annually by July 30.

The regulation also requires reverse logistics systems to include, by March 31, 2026, proposals for new quantitative and geographical targets in the SIGOR Reverse Logistics system, with the possibility of revising the progression upon proof of technical and economic viability.

The quantitative targets will now be calculated based on the mass of products or packaging placed on the São Paulo market in the base year and on the waste collected and destined in the performance year. The geographical targets, in turn, consider the territorial scope of the system, including cities served, administrative regions covered, reception points installed, and proportional population service criteria.

For packaging in general, CETESB allows, exclusively for 2026, systems proven to be structural to meet 25% of the quantitative target, regardless of the type of material, provided that the requirements of Federal Decree No. 11,413/2023 are met. The decree establishes the Reverse Logistics Recycling Credit Certificate, the General Packaging Structuring and Recycling Certificate, and the Future Mass Credit Certificate, while the remaining 75% must be met by material type.

The board’s decision also establishes stricter criteria for document review. Only invoices issued in the base year or performance year will be considered. The use of surpluses from the base year in the following year is limited to 10% of the corresponding target, and will only apply if the target has been exceeded in the previous period.

Failure to meet quantitative targets implies an increase in the subsequent year’s target by the same amount, with liabilities exceeding 10% giving rise to immediate administrative sanctions under  Federal Decree No. 6,514/2008, in addition to the obligation to pay full civil reparation. Liabilities not settled within a year also result in sanctions, which must be remedied through pecuniary compensation aimed at promoting selective collection and the circular economy. For liabilities accrued up to 2025 and not settled by December 31, 2026, the rule provides exclusively for civil damages.

PERNAMBUCO

State of Pernambuco regulates submission of the Annual Solid Waste Declaration and Reverse Logistics Report

On December 19, 2025, the Pernambuco State Environment Agency (“CPRH”) published Ordinance No. 238/2025, establishing rules for submitting the Annual Solid Waste Declaration (“DARS”) for 2026 – for the base year 2025 –, and for submitting the Reverse Logistics System Report,  both through the Integrated Environmental Services System (“SISAM”).

The measure aims to adjust the state procedure to the obligations established in the National Solid Waste Policy, provided for by Federal Law No. 12,305/2010, and the mandatory use of the National MTR System, instituted by Ordinance No. 280/2020.

Ordinance No. 238/2025 establishes that the 2026 DARS must be accompanied by the documents generated in the National Waste Transportation Manifest System (“MTR”), temporarily replacing the Industrial Solid Waste Control and Management System (“SGRI”), which will remain suspended while the ordinance is in force.

The industries listed in the Single Annex of CPRH IN No. 001/2019 must submit, via SISAM, the Waste Handling Declarations (“DMRs”) of the National Solid Waste Management Information System (“SINIR”) relating to waste generated in 2025. Other non-industrial generators must also submit the DMRs issued in SINIR’s MTR through the same channel.

Companies responsible for packaging reverse logistics systems must file, by June 30, 2026, the Reverse Logistics System Report for packaging produced in 2024 and recycled or recovered in 2025, in compliance with State Decree No. 54,222/2022. The decree defines the guidelines for the implementation, structuring, and operation of the reverse logistics system for packaging in general.

All the documents provided for in Ordinance No. 238/2025 – including DARs, DMRs, and the Reverse Logistics Report – must be submitted in PDF format via SISAM, through the appropriate processes (DARs or general request, as the case may be), with a deadline of June 30, 2026.

PARAÍBA

State of Paraíba extends deadline for submitting Annual Performance Report on Reverse Logistics for General Packaging

On December 30, 2025, the Paraíba Environmental Administration Superintendence (“SUDEMA”) published Ordinance No. 120/2025, extending the deadline to February 28, 2026, for submitting the Annual Performance Report for the General Packaging Reverse Logistics System. The report must consider 2023 as the base year and 2024 as the performance year.

AMAPÁ

State of Amapá establishes the State Program to Encourage the Creation and Strengthening of Work Cooperatives

On January 08, 2026, State Law No. 3,419/2026 was published, establishing the State Program to Encourage the Creation and Strengthening of Work Cooperatives in Amapá, aimed at waste pickers, artisans, small‑scale fishers, smallholder farmers, extractivists from traditional communities, and ecotourism projects.  

Among the measures planned to implement the program, the state of Amapá will be able to finance equipment, machinery, and vehicles, build warehouses and sorting spaces for selective collection, offer training and technical assistance, adopt bureaucratic simplification actions, and grant specific tax exemptions, to be defined in future regulations.

The regulation also encourages municipal governments to hire waste picker cooperatives to carry out selective collection, in compliance with the instruments provided for in the National Solid Waste Policy (Federal Law No. 12,305/2010), encouraging the socio-economic inclusion of these workers in public waste management.

The implementation of the program’s measures will depend on its own budget appropriations, which may be supplemented. The State Executive Branch is expected to regulate the law to define criteria, access rules, support mechanisms, and details of the exemptions provided.

• Water Resources

SANTA CATARINA

Santa Catarina updates standards and control parameters for the discharge of unregulated industrial and sanitary effluents

On December 16, 2025, the Santa Catarina State Environmental Council (“CONSEMA/SC”) enacted CONSEMA Resolution No. 299/2025, establishing new standards, parameters, and conditions for the discharge of industrial effluents, similar effluents (such as those from commercial activities, services, and condominiums) and sanitary effluents from systems not regulated by sanitation agencies into inland water bodies, lagoons, estuaries, and the sea.

In general terms, the regulation:

• Consolidates the set of monitoring parameters and establishes minimum frequencies of analysis according to the type of activity and the design flow rate of the Effluent Treatment Plant (“ETE”). It also establishes that, during the commissioning of new ETEs, the discharge of effluents outside the conditions of the monitoring program can be authorized, exceptionally and for up to 180 days (extendable upon technical justification), in order to validate the efficiency of the treatment system.
• Incorporates guidelines for environmental licensing, such as the possibility of the environmental agency making conditions more restrictive or altering them based on the characteristics of the effluent generated, the classification of the water body, the presence of water abstractions, and criteria provided for in Resolution No. 430/2011 of the National Environment Council (“CONAMA”).
• Allows monitoring to be waived for parameters classified as Monitoring Parameters (“AP”), when the operational effectiveness of the treatment and the absence of environmental impact have been proven.
• Devotes a specific chapter to sanitary effluents from unregulated systems, regulates the monitoring of oils and greases, and provides for parameters that must be monitored even without a defined launch standard.
• Regulates ocean‑disposal systems, establishing requirements to ensure compliance with bathing‑water quality standards, the protection of shellfish‑farming areas, and the preservation of the region’s ecological characteristics.
• Provides for specific technical studies, hydrodynamic modeling, and the definition of initial dilution limits.

The treated effluent monitoring reports must be submitted annually by March 31, containing a history of the last 12 months, comparisons with the applicable standards, and technical statements on any non-conformities.

Finally, CONSEMA Resolution No. 299/2025 states that its provisions will apply within 12 months of publication, on December 16, 2025 – except when monitoring is already provided for in a current environmental license.

TOCANTINS

NATURATINS publishes ordinance standardizing procedures for granting water use in the state of Tocantins

On January 16, 2026, NATURATINS issued Ordinance No. 10/2026 , which standardizes the technical and administrative procedures for reviewing and regularizing the use of water resources in the state of Tocantins, replacing former Ordinances No. 904/2008 and No. 24/2022. 

The NATURATINS Ordinance establishes a mandatory Term of Reference for all regularization modalities – including the granting of the right of use, declaration of insignificant use or accumulation, Prior Approval for Drilling Wells, and declarations of water availability. The ordinance also defines the information that must be included in technical and calculation reports and in hydrological analyses.

In addition, the regulation provides for self-declaration procedures for low-impact interventions, such as DUIs, DAIs, ANPs, and simple civil works. Digital filing replaces technical reports, but responsibility remains with the applicant and the technical officer, who are subject to audits, ex-officio reviews, and sanctions in the event of inconsistencies.

For more information, access: Government of Tocantins establishes technical procedures for analysis and requests for regularization of water use

BAHIA

Bahia imposes temporary restriction on surface water withdrawal in the Jacuípe River sub-basin

On January 10, 2026, the Bahia Institute for the Environment and Water Resources (“INEMA”) issued INEMA Ordinance No. 34,276/2026, ordering a 50% reduction in the volumes withdrawn by users holding water‑use permits for surface‑water abstraction in the Jacuípe River sub‑basin, until further notice.

The measure applies to all active permits for surface‑water abstraction along the stretch that covers the headwaters of the Jacuípe River – including the reservoir of the França Dam – through to the São José do Jacuípe Dam reservoir, encompassing the main river and its tributaries. The restriction does not apply to withdrawals intended for human consumption and livestock watering, which remain expressly safeguarded under the regulation.

The regulation aims to address the water crisis in the region, ensuring the prioritization of essential water uses and the preventive management of water resources, in line with INEMA’s competence to regulate and supervise the use of water in the state of Bahia. By temporarily reducing authorized withdrawal volumes, the regulation seeks to mitigate the impacts of water scarcity on the sub‑basin’s water sources.

The ordinance also provides that, should hydrological conditions worsen, INEMA may adopt additional restriction measures to guarantee – as a priority – human supply and livestock watering. Thus, the ordinance establishes a dynamic management regime, subject to reassessment as the hydrological landscape evolves.

• IBAMA’s Federal Technical Register

IBAMA standardizes TCFA tax review procedure under the competence of the agency’s presidency

On December 04, 2025, IBAMA published Ordinance No. 158/2025, which establishes the Standard Operating Procedure (“POP”) for the tax review of the Environmental Control and Inspection Fee (“TCFA”) when conducted by the president of IBAMA or by formally delegated officials. The new regulation governs the procedure applicable to requests for review of definitively established claims.

The regulation states that the TCFA tax review should not be considered as a means of supplementing defenses, reopening discussions on the merits, or introducing evidence that could have been submitted in the litigation phase, except when related to factual supervening.

Ordinance No. 158/2025 will come into force on March 02, 2026.

IBAMA standardizes procedures for TCFA tax administrative process

On December 10, 2025, IBAMA issued Ordinance No. 160/2025, establishing the Standard Operating Procedure (“POP”) for the first‑instance administrative proceedings related to the TCFA.

The regulation consolidates and organizes the detailed flow of instruction, analysis, and judgment of challenges, with the aim of guaranteeing isonomy, legal certainty, and standardization of the activities of preparatory agents and judging authorities in all IBAMA superintendencies.

The POP outlines sequential steps – from verifying the formal admissibility of the challenge, conducting internal or external visits, issuing a technical opinion, issuing the first‑instance decision, and any mandatory referrals to the second instance. It also includes standardized document templates to be used by agency staff.

The regulation also reinforces criteria already addressed by IBAMA Normative Instruction No. 17/2011, such as the rules for analyzing statute‑of‑limitations issues, requests for visits and expert examinations, documentary instructions, the issuance of notifications, criteria for adjusting size‑category corrections, and limits for reviewing activities declared in the Federal Technical Registry (“CTF”). Among the key points, the text clarifies that untimely challenges do not preclude an analysis on the merits, since the mere filing of the challenge suspends the enforceability of the tax liability during the administrative dispute.

Ordinance No. 160/2025 comes into force on March 02, 2026, and the new procedure will be compulsorily applied to all challenges to tax assessment notices from the first quarter of 2026.

IBAMA updates rules on Federal Technical Registry and redefines procedures for registration, regularity, and modifications

On December 26, 2025, IBAMA published IN No. 23/2025, amending IN No. 13/2021.

The new normative instruction updates definitions, internal responsibilities, and operational workflows involving the CTF/APP, reinforcing the role of IBAMA’s President in proposing mechanisms and technical chambers to harmonize regulatory oversight of the registry. In addition, the regulation redistributes roles to the General Coordination of Environmental Quality Management, the Coordination of Management and Integration of Environmental Quality Instruments, the Superintendencies, and the Technical-Environmental Divisions.

The regulation also revises the criteria for defining the start and end dates of legal entities’ activities in the CTF/APP – aspects that are essential for calculating the TCFA.

The start date is now deemed to be the date on which the company is enabled to carry out the activity, with the most recent verifiable date prevailing, such as the filing of its articles of association, the state/district tax registration related to an activity subject to the CTF/APP, the granting of public authorizations, or the issuance of the first invoice. The end date, in turn, is deemed to be the earliest verifiable date, considering, for example, the cancellation of the CNPJ (tax ID), the filing of the dissolution instrument, the expiration of environmental authorizations/licenses, and the last invoice issued, including the possibility of setting the date based on an on‑site inspection.

With respect to the Compliance Certificate, the document may also certify information held by other administrative spheres and will have its validity canceled if environmental irregularities subsequently arise.

Another key point is the revision of procedures for registry modifications that impact the TCFA. When a change results in the reduction or elimination of the fee and does not affect periods that have already been assessed, are under litigation, or have been settled, the amendment may be processed directly by the Technical‑Environmental Divisions, with notice to the collection team. If the change affects periods in which assessments have already been made, the process must be analyzed by IBAMA’s collection department. Temporary suspension of activity based solely on tax or accounting documentation will also require specific analysis by the tax collection team.

The regulation further establishes challenge and appeal procedures in cases where a request for a registry amendment is denied, granting a 20‑day period for filing a challenge and providing for a single hierarchical appeal to the Environmental Quality Instruments Management and Integration Office.

IN No. 23/2025 will take effect 60 days after its publication.

• Payment for Environmental Services

SANTA CATARINA

State of Santa Catarina establishes state policy on payment for environmental services

On December 19, 2025, the state of Santa Catarina enacted State Law No. 19,677/2025, amending the State Environmental Code (State Law No. 14,675/2009) to create the State Policy on Payment of Environmental Services (“PSA”) and to structure the instruments, guidelines, and funding sources aimed at environmental conservation in the state.

The law defines the PSA as a voluntary transaction in which a payer – which can be the government, civil society organizations, or private agents – pays providers of environmental services for the maintenance, recovery, or improvement of natural areas and associated ecosystem services. The text also updates the code to allow the Annual Budget Law (“LOA”) to provide for specific appropriations regarding the PSA. The text further determines that the funds allocated for the State System of Conservation Units (“SEUC”) and the PSA be applied exclusively to program-related measures.

The measures range from the protection and restoration of native vegetation to the recovery of degraded areas, including the adoption of agro-ecological practices, the prevention of natural disasters, the conservation of fauna, the control of invasive exotic species, and nature-based urban actions for climate regulation and well-being. The law also allows for initiatives to fix and capture carbon, as well as reduce emissions from deforestation and conserve the genetic variability of flora and fauna.

Among the instruments for implementing the PSA, we highlight: Specific plans, programs, and projects; Incentives and conditional payments (pecuniary or non-pecuniary); Technical support and training; Priority areas for providing environmental services; and Creation of the State Registry for PSA Projects. Publicly funded projects must be registered in this registry, while private initiatives may join on a voluntary basis.

The law also provides for payment modalities, such as direct payment, the provision of social improvements to communities, mechanisms linked to REDD+, green bonds, lending and Environmental Reserve Quotas, among others that can be instituted through a future regulatory act.

• Rural Credit – Amortization and Settlement

FEDERAL LEVEL

Brazil’s CMN expands the scope of credit line for settlement and amortization of rural transactions affected by adverse events

On December 22, 2025, the Central Bank of Brazil published Resolution No. 5,276/2025, issued by the National Monetary Council (“CMN”), amending Resolution No. 5,247/2025. The resolution adjusts the conditions of the special credit line intended to settle or amortize rural credit transactions and Rural Product Notes (“CPRs”) held by producers affected by weather‑related events and other adverse occurrences.

Under the new wording of Resolution No. 5,247/2025, the special credit line can only be used to settle or amortize the following:

• working capital and investment operations and CPRs contracted up to July 30, 2024, that were in good standing on that date, but became past due on December 15, 2025, or that have been renegotiated with maturity between September 05, 2025, and December 31, 2027 – provided that they were in good standing when the new operation was contracted.
• Working capital operations contracted between July 01, 2024, and June 30, 2025, that were past due on December 15, 2025.
• Operations from the same period that have already been renegotiated or extended, regardless of whether they were in good standing or past due on that date.
• CPRs issued by rural producers to financial institutions between July 01, 2024, and June 30, 2025, that were past due on December 15, 2025.

The resolution also establishes that, in order to access the special line in cases of default, the borrower must pay – until the new operation is contracted – the financial charges past due on the operations that will be settled or amortized through the credit line.

• Environmental Compensation

CEARÁ

State of Ceará issues general regulation on environmental compensation

On December 31, 2025, the Ceará Secretariat for the Environment and Climate Change (“SEMA”) issued Normative Instruction No. 7/2025, establishing a new administrative procedure for the execution, oversight, amendment, and settlement of Environmental Compensation Commitment Agreements (“TCCA”).
The regulation also repeals Normative Instructions No. 02/2022 and No. 02/2023, which previously governed the matter at the state level.

The TCCA becomes a mandatory condition for the issuance of the Preliminary License and must be executed prior to the Installation License. The calculation of the amount due now follows an explicit formula that applies 0.5% to the project’s Reference Value – considered the total investment required for implementation –, excluding mitigation costs, environmental programs, financing arrangements, guarantees, and insurance.

The agreement may be carried out in physical, financial, or hybrid modalities, and SEMA’s State Environmental Compensation Chamber must approve in advance the Work Plan, as well as the related projects and schedules.

The regulation also establishes that non‑compliance with the TCCA can result in suspension of the license and restrictions on renewals, reinforcing the integration of the instrument into the environmental licensing process conducted by the State Environmental Superintendence.

• Environmental Infractions

AMAPÁ

State of Amapá systematizes administrative process for environmental infractions and toughens penalty criteria

On January 13, 2026, State Decree No. 230/2026 was published, aiming to modernize and systematize the administrative process arising from environmental infractions committed in Amapá – previously regulated by State Decree No. 3,009/1998.

The regulation typifies and consolidates environmental administrative infractions by theme, covering fauna, flora, fishing, pollution, waste, mining, environmental licensing, and water resources. The decree also establishes fine ranges that can reach up to BRL 50 million, as well as increases based on severity, recidivism, and context of the infraction.

Additionally, concepts such as “open fine”, “closed fine”, “daily fine”, “continuity of the infraction”, “economic capacity of the offender”, and “levels of severity” (from A to E) were established, creating technical parameters for the dosimetry of penalties, which can range from warnings to fines, including partial or total suspension of activities and restriction of rights.

Finally, the regulation also creates technical dosimetry tables (Annexes 1 to 4 of the regulation) – which link the final amount of the fine to the economic size of the offender and the environmental severity. The regulation also structures detailed rules for the seizure, embargo, demolition, and disposal of assets involved in the infractions.

• Vegetation Suppression and Environmental Compensation

PARANÁ

State of Paraná publishes new rules for suppressing native vegetation in state territory

On January 15, 2026, the IAT published IN No. 5/2026, providing procedures for authorizing the suppression of native vegetation in the state territory of Paraná, including technical criteria, inventory parameters, documentation requirements, and procedures for analysis, inspection, and environmental compensation.

Under the new regulation, vegetation‑suppression requests must now be submitted through the National System for the Control of the Origin of Forest Products, with mandatory vector files and precise delineation of the clearing polygons.

The regulation prohibits subdividing areas to circumvent legal requirements, as well as including Permanent Preservation Areas for suppression, under the Atlantic Forest Law.

For technical review purposes, the request will be evaluated based on the information submitted, on additional studies, as necessary, and on‑site inspection.

In general terms, authorizations will be valid for up to three years, renewable once, except in cases of public utility or social interest, which may reach five years.

SANTA CATARINA

Santa Catarina suspends criteria for compensation for the use of APPs

On January 19, 2026, the Environmental Institute of the State of Santa Catarina (“IMA/SC”) published IMA Ordinance No. 16/2026, suspending the effectiveness of IMA Ordinance No. 013/2025, which establishes minimum criteria for compensation for the use of APPs. The measure is the result of a court decision that overturned the legal basis that underpinned the regulation previously in force.

The suspension is directly related to the judgment, by the Santa Catarina Court of Justice (“TJSC”), of ADI No. 5041416-77.2024.8.24.0000, which declared the unconstitutionality of Article 122-D of the Santa Catarina State Environmental Code (State Law No. 14,675/2009). This provision served as the legal basis for IMA Ordinance No. 013/2025, which regulated environmental compensation for the use of APPs.

In view of the court decision and the guidance of the IMA’s Legal Prosecutor’s Office (“PROJUR”), IMA Ordinance No. 16/2026 recognizes that the declaration of unconstitutionality has immediate effect, invalidating the regulatory foundation of the subordinate rule. As a result, the minimum criteria previously established for compensation for the use of APPs in the state of Santa Catarina are temporarily suspended.

The regulation establishes that the suspension of the effectiveness of IMA Ordinance No. 013/2025 will remain in force until the final judgment of this ADI is issued by the TJSC. In practical terms, this means that until there is a final decision on the constitutionality of the legal provision in question, the state environmental agency will not be able to demand or apply the environmental compensation criteria established in the suspended ordinance.

IMA Ordinance No. 16/2026 comes into force on the date of its publication and takes effect immediately, directly impacting administrative processes, environmental licensing analyses, and other procedures involving the use of APPs and the requirement for compensatory measures in the state.

• Use of prescribed and controlled burning

RORAIMA

Roraima extends 16th Authorization Cycle for Controlled Burning and Prescribed Fire

On January 09, 2026, the Roraima State Foundation for the Environment and Water Resources (“FEMARH”) published FEMARH/PRES/DIRAF/DRH Ordinance No. 4/2026 (“FEMARH Ordinance”), which extended the 16th Authorization Cycle for Controlled Burning and Prescribed Fire until January 08, 2026. The measure considers the forecast for the rainy season, technical analyses based on scientific data, and deliberations by the state committee for preventing and controlling burning and fighting wildfires.

The FEMARH Ordinance is based on applicable federal and state legislation, including the National Integrated Fire Management Policy, the Forest Code, and the Roraima State Plan for Deforestation and Burn Control. The normative act recognizes that the use of fire can be allowed in specific situations for conservation, research, and management purposes, provided it is previously authorized by the competent environmental agency and complies with all technical and environmental safety standards.

According to the FEMARH Ordinance, burning activities can be suspended at any time, based on a technical assessment by the State Wildfire Committee, considering factors such as wildfire risk, data from the National Institute for Space Research (“INPE”) Fire Database, and alerts from the State System for Wildfire Prevention and Control.
 Thus, extending the cycle does not preclude the imposition of new restrictions if environmental conditions so require.

The regulation further provides that the use of fire in agroforestry‑pastoral areas without FEMARH authorization, or in violation of the established conditions, constitutes unlawful activity, subject to sanctions under the applicable state decree, including fines of BRL 10,000 per hectare or fraction. The provision reinforces the exceptional nature of the use of fire and the need for strict compliance with the authorizations granted.

Additionally, the FEMARH Ordinance automatically renews the authorizations for the use of fire previously granted during the 16th Cycle, under the terms of the ordinances issued in October, November, and December 2025, limiting the validity of these authorizations to the term of the FEMARH Ordinance – that is, until February 08, 2026. As a result, previously authorized beneficiaries will be able to continue using fire, provided that the technical and time conditions established are observed.

The act also consolidates the documentation requirements for obtaining authorization, including a specific application, a declaration of environmental responsibility, personal documents, proof of ownership, maps, a descriptive memorial, the CAR registration, and current environmental licensing, if applicable. Technical and preventive rules are also established for the use of fire, such as prior communication to neighbors, civil defense agencies, and firefighters, the maintenance of firebreaks, the choice of safer times, and the adoption of measures to prevent the undue spread of fire.

MAPA initiates public consultation on list of notifiable diseases affecting aquatic animals

On January 19, 2026, through the Secretariat of Agricultural and Livestock Defense (“SDA”), MAPA published SDA/MAPA Ordinance No. 1,443/2025, which submits to public consultation the proposed ordinance determining the list of notifiable diseases affecting aquatic animals to the Official Veterinary Service.

The initiative aims to update and standardize the epidemiological surveillance requirements applicable to the aquaculture sector, reinforcing prevention, early detection, and rapid response to diseases of sanitary relevance.

Among the key points discussed, we highlight:

• Contribution period: From December 05, 2025, to January 21, 2026.
• Submission of suggestions: Exclusively through the Regulatory Acts Monitoring System (“SISMAN”), as well as the official regulatory monitoring and participation platform. To access SISMAN, users must first register with the Access Request System (“Solicita”) linked to MAPA.
• Assessment of contributions: Assessments will be carried out under the responsibility of the Department of Animal Health, which will make the relevant adjustments for subsequent publication of the ordinance in Brazil’s Federal Official Gazette.

For more information, access: “MAPA ORDINANCE No. 1,476/2025

Minimum Subdivision Size reduced for rural real estate

The Constitution, Justice, and Citizenship Committee (“CCJ”) of the House of Representatives approved Bill No. 6,088/2023, which reduces the Minimum Subdivision Size (“FMP”) for rural real estate across Brazil to 5,000 square meters (0.5 hectare).

The FMP represents the smallest area legally permitted for the subdivision of rural real estate. Currently, the minimum size varies by city, between two and five hectares, which limits the registration of smaller plots with the National Institute for Colonization and Agrarian Reform (“INCRA”). The change seeks to modernize the agrarian legal system, aligning it with current production conditions and the demands of small landowners.

Thus, the approved proposal reduces this parameter, enabling subdivision into smaller areas, provided that they are compatible with economically viable activities and the real estate’s social function.

Reducing the FMP represents a necessary degree of flexibility, given current agricultural techniques that enable high productivity even on smaller areas. In addition, the measure tends to reduce bureaucratic obstacles for small producers and facilitate land regularization. The initiative also considers the development of agricultural techniques, which enable significant productivity in reduced areas.

The proposal is being addressed conclusively and will be analyzed by the Federal Senate, except in the event of a request for a vote in the Plenary of the House of Representatives. If approved by the Senate and subsequently sanctioned, the change could modernize the legal regime for small rural properties, including benefiting producers and heirs that face difficulties in legally subdividing their land.

Bill proposes minimum standardization for real estate registrations in registry offices

Bill No. 817/25 establishes minimum mandatory information requirements for real estate registrations nationwide. The measure aims to standardize registration data, increase legal certainty, and reduce inconsistencies between registry offices.

The text establishes that all registrations must contain essential information, such as: Complete identification of the real estate; location; perimeter description; ownership; history of transfers; and any encumbrances. The initiative aims to solve the current asymmetry of information between different registry offices, which often hinders real estate transactions, financing, and risk analyses.

According to the bill, standardization reinforces transparency and predictability in the real estate market, benefiting owners, registrars, financial institutions, and legal operators. In addition to improving the traceability of real estate, the measure tends to facilitate audits, reduce litigation, and improve the business environment.

The proposal is still pending and is expected to be voted on by the House of Representatives’ Plenary.  If approved, the bill will represent an important step towards modernizing the Brazilian registry system, aligning it with practices already adopted in countries with unified, interoperable registries.

Ordinances establish new criteria for allocating federal real estate

Brazil’s Federal Government has published two ordinances that define the rules and procedures for allocating federal real estate, with a focus on strengthening governance, transparency, and rationality in asset management. The measures seek to modernize the decision-making process and ensure that the use of public assets is aligned with public policies and the social interest.

MGI Ordinance No. 11,384/2025 establishes a new governance regime designed to conduct, verify, and guide decisions related to the allocation of federal real estate. The ordinance establishes that the process must comply with criteria such as adequate justification, publicity, motivation, and coordination with states and municipalities.

As part of the new structure, the Special Allocations Committee (“CDE”) was created and is in charge of analyzing specific cases of allocations and issuing general guidelines on procedures, always considering:

• Possibility of onerous disposal;
• Existence of social housing programs;
• Urban land regularization situations;
• Compliance with federal public policies; and
• Conservation and the socio-environmental function of heritage.

SPU/MGI Ordinance No. 11,423/2025, in turn, details the cases in which the prior manifestation of the CDE is mandatory prior to the allocation of federal real estate, such as in the case of:

• Real estate valued at BRL 100 million or more;
• Real estate intended for the payment of Real Estate Investment Fund quotas (Law No. 13,240/2015);
• Real estate intended for social housing;
• Real estate intended for indirect Urban Land Regularization of Specific Interest (“REURB-E”);
• Multi-use developments or large-scale innovative initiatives coordinated by federal agencies;
• Authorization for sustainable use when involving challenges from private individuals or matters related to traditional communities; and
• Granting of occupancy registration or free leasing, as provided for in the applicable legislation.

The new rules reinforce the importance of careful technical assessment and increase the standardization of processes, reducing legal risks and ensuring greater control over the use of public assets.

The ordinances represent a significant step in modernizing the Federal Government’s real estate management, as they standardize decision-making flows, increase transparency and legal certainty, reduce asymmetries between different types of destination, and encourage the efficient and socially-oriented use of public real estate.