Regulated carbon market sets timeline for industry to begin measuring emissions
The federal government has established a timeline for the gradual inclusion of economic sectors into the Brazilian Greenhouse Gas Emissions Trading System (SBCE)—the cornerstone for structuring a regulated carbon market in the country. Ordinance No. 3,199, issued on October 28, 2026, by the Ministry of Finance through the Extraordinary Secretariat for the Carbon Market (SEMC), defines the phases for implementing obligations related to the Measurement, Reporting, and Verification (MRV) of greenhouse gas emissions and removals. This measure prepares large industrial operators to monitor their carbon footprints on an annual basis—a process integral to Brazil’s decarbonization strategy and its commitment to achieving emissions neutrality by 2050.
Three implementation phases prepare productive sectors for the carbon market, beginning in 2030
MRV obligations will apply to operators with annual emissions equal to or exceeding 10,000 tonnes of CO₂ equivalent—a group estimated to represent less than 1% of all registered business entities (CNPJs) in the country. Meanwhile, companies with annual emissions exceeding 25,000 tonnes will, from 2030 onwards, be subject to the requirements set forth in the National Allocation Plan (PNA). The schedule organizes the integration of these sectors into three phases: the first begins in 2027 and covers aluminum, integrated steelmaking, cement, oil and gas exploration and production, specific segments of the chemical industry, iron and bauxite mining, pulp and paper, and glass. The second phase, slated for completion by 2029, includes ceramics, semi-integrated steelmaking, remaining chemical segments, food and beverage, other mining activities, oil refining, and the electricity sector. The third phase, extending to 2031, encompasses road, rail, and waterborne transport. Each stage will have a four-year preparatory cycle, consisting of the development of a monitoring plan in the first year, the tracking of emissions in the second and third years, and the consolidation of information in the fourth year, to provide input for the PNA.
At this stage, the publication of the ordinance does not impose any immediate requirements for the submission of reports, nor does it set emission limits or costs for participants. The overall cap and the allocation of Brazilian Emission Quotas (Cotas Brasileiras de Emissões) will be defined within the National Allocation Plan (PNA)—scheduled to take effect from 2030—with an initial allocation that will be 100% free of charge. The development of these rules was preceded by a public consultation that received 938 contributions from companies, associations, academia, and civil society. Upcoming steps include the establishment of a Regulatory Affairs Chamber, involving sectors included in the first phase, and the creation of the Brazilian Measurement, Reporting, and Verification Program, which will define the methodologies and criteria for the accreditation of bodies responsible for the independent verification of data.
