Contributions to Brazilian Central Bank consultation on disclosure regulation

On November 4th, 2025, the Brazilian Central Bank opened public consultation 127/2025, on a draft regulation regarding disclosure requirements. Overall, the requirements represent a significant improvement towards transparency and more detailed reporting.

In our feedback on the consultation, we included requests for more detailed reporting on exclusion policies, on transition plans, on exposure to deforestation and to projects that impact indigenous peoples and local communities.

Despite considerable improvements, the text of this draft regulation is still strongly focused on single materiality – focusing on the risks for financial institutions. To make these disclosures really meaningful, a stronger double materiality approach should be included. This means that banks would also have to report on how they are impacting people and nature.

The IPBES report on Business and Biodiversity, launched earlier this week, highlights that all businesses, including financial institutions, depend on and impact biodiversity, and that they all have a responsibility to address their impacts. Disclosing those impacts is a key first step in that process.