SUSEP proposes new regulatory framework for sustainability reporting and alignment with international standards

The Superintendence of Private Insurance (“SUSEP”) submitted a draft SUSEP resolution for public consultation intended to revoke and replace SUSEP Circular No. 666/2022, which currently establishes sustainability requirements applicable to insurance companies, open private pension entities (“EAPCs”), capitalization companies, and local reinsurers. The proposal also includes a new version of the Guidance Manual on the Standard Tables for the Sustainability Report (Manual de Orientações sobre as Tabelas Padrão para o Relatório de Sustentabilidade).

The review stems from the evolution of international sustainability-related disclosure standards, particularly following the issuance of IFRS S1 and IFRS S2 by the International Sustainability Standards Board (ISSB), as well as the incorporation of these standards into the Brazilian regulatory environment through CBPS Statements No. 01 and No. 02. According to SUSEP, the proposal seeks to align Brazilian rules with international best practices, improve regulatory oversight of the sector, and make the information disclosed by companies clearer and more comparable.

Among the main proposed changes are the expansion of the regulation’s scope to include insurance cooperatives, the express incorporation of the concept of “sustainability opportunities” alongside traditional climate, environmental, and social risks, and the requirement that such factors be considered in governance processes, strategic planning, risk management, underwriting, investments, and the preparation of sustainability reports. The draft resolution also defines “climate scenario analysis” and extends to all supervised entities, subject to proportionality and materiality criteria, certain risk management requirements that currently apply only to segments S1 and S2, such as the incorporation of long-term projections into quantitative measurement methodologies.

The proposal also introduces important changes to the way companies will be required to present their sustainability information. The new rules expand disclosure requirements regarding how sustainability-related risks and opportunities are monitored, how such factors may affect business activities, and how companies prepare for future climate scenarios. In addition, more detailed information on sustainability-related metrics, targets, and results will be required, in line with international standards.

The proposal maintains proportionality measures by segment. The GVR (governance), EST (strategy), and GER (risk management) tables will be mandatory for all supervised entities, while the climate scenario analysis item within the EST table and the MEM (metrics and targets) table will be mandatory only for segments S1 and S2 and optional for segments S3 and S4. Additionally, supervised entities in segments S1 and S2 will be required to include climate scenario analysis in their reports as a strategic planning and risk management tool.

Another relevant change is that the OPO table, currently dedicated exclusively to business opportunities related to sustainability, will no longer exist as a separate section. Information on opportunities will instead be incorporated into the GVR, EST, GER, and MEM tables and presented alongside risk-related information to simplify reporting and avoid duplicative disclosures.

The draft resolution also provides for a simplification applicable to entities that already prepare and disclose sustainability reports in accordance with CBPS Statements No. 01 and No. 02. In such cases, submission of the report to SUSEP will no longer be required, provided that the document is published together with the financial statements, is subject to reasonable assurance by an independent auditor, complies with the minimum requirements established by the resolution, and remains accessible to the supervisory authority.

The public consultation concluded in October, and if approved as submitted, the new resolution will enter into force on December 31, 2026, and will repeal SUSEP Circular No. 666/2022 (Article 19). According to the reporting director’s opinion, information will be collected throughout fiscal year 2027 and disclosed in 2028. The draft further provides that future amendments to the standard tables will only take effect for disclosure purposes as of the fiscal year following their publication on SUSEP’s website.

For more information, please access: Laws and Regulations

Demarest’s Insurance, Reinsurance, Health and Private Pension team is closely monitoring the matter and remains available to assist with assessing regulatory impacts, preparing submissions for public consultations, and implementing future sustainability and disclosure requirements.