Brazil's regulated carbon market now has dates. The Secretaria Extraordinária do Mercado de Carbono (SEMC, the finance ministry's carbon market secretariat) published on the night of Thursday, 29 October, Ordinance No. 3,199, signed on the 28th, setting out when each sector of the economy must begin measuring, reporting and verifying its greenhouse gas emissions under the Sistema Brasileiro de Comércio de Emissões (SBCE, Brazil's emissions trading system), created by Law No. 15,042 of 2024.
The obligation is known as MRV — measurement, reporting and verification. It does not demand emissions cuts or set a price: it is the step before that, building the accounts the market will run on.
Who is covered, and when
The ordinance applies to operations emitting 10,000 tonnes of CO2 equivalent a year or more. According to the ministry, that threshold reaches fewer than 1% of the country's registered companies.
The calendar has three phases:
- From 2027: aluminium; integrated steel plants; cement; oil and natural gas exploration and production; some chemical segments; iron ore and bauxite mining; pulp and paper; glass.
- By 2029: ceramics; semi-integrated steel plants; the remaining chemical segments; food and beverages; mining of other minerals; oil refining; the electricity sector.
- By 2031: road, rail and waterway transport.
Each phase follows a four-year cycle. The first year goes to drafting the monitoring plan; the next two to tracking emissions; and the fourth to consolidating the data that will feed the Plano Nacional de Alocação (PNA, the national allocation plan).
The order of the queue is not random. Steel, aluminium and cement are among the products covered by the European Union's Carbon Border Adjustment Mechanism (CBAM), which charges for the carbon embedded in imports. Measuring emissions at home, with a recognised methodology, is what allows a Brazilian exporter to deduct there what it has already paid here.
No cap and no cost, for now
The ordinance creates no emissions ceiling and no cost for companies at this initial stage. The system's cap and the distribution of Cotas Brasileiras de Emissão (CBEs, Brazilian emission allowances) are left to the national allocation plan, expected from 2030, and the initial allocation will be entirely free. After 2030, companies emitting more than 25,000 tonnes of CO2e a year will also fall under the plan's obligations.
"Over the next four years, the focus is on learning to measure and report" in a standardised way, said Cristina Reis, the extraordinary secretary for the carbon market, describing the period as a learning curve for the country. She frames the regulated market as industrial policy, not only environmental policy.
The ministry intends to set up a regulatory affairs chamber with first-phase sectors before the end of 2026, and to open public consultations in November on its PB-MRV and PBCE programmes.
Aviation is out — and has rules of its own
Air transport was in the proposal taken to public consultation, but it has been dropped from the SBCE timetable. The stated reason is to avoid double regulation: airlines will report emissions under rules from the Agência Nacional de Aviação Civil (Anac, Brazil's civil aviation agency), inside ProBioQAV, the national sustainable aviation fuel programme created by the Lei do Combustível do Futuro (the Fuel of the Future law) — which also takes effect in 2027.
Anac put its draft resolution out for consultation in September. The Agência Nacional do Petróleo (ANP, Brazil's oil and gas regulator) approved a consultation and a public hearing on the ProBioQAV rules, with the hearing set for 18 November; the text is expected to cover sustainability criteria, a carbon intensity methodology, and the issuance and trading of CS-SAF certificates. An August decree set 18 December 2026 as the deadline for Anac and the ANP to publish the operational rules.
The Fuel of the Future law, signed in October 2024, requires domestic flight operators to cut emissions by 1% from 1 January 2027 through the use of sustainable aviation fuel (SAF). Airlines have raised the possibility of a postponement, a discussion under way inside the government, according to sources cited by the outlet eixos.
Sanitation and waste are also absent from the timetable, an exclusion that drew a reaction from the sector. The Associação Brasileira das Empresas de Saneamento (Abcon, Brazil's water and sewage companies association) argues that "the water and sewage segment generates significant environmental and social benefits" and has potential in the voluntary carbon market.
With information from eixos, Money Times, Portal Energia Limpa and Brazil's Ministério da Fazenda.
