This report synthesizes the main legal highlights of 2025 in the fields of environment and sustainability and outlines perspectives for 2026. The topic is broader in scope and will remain on the radar through other developments throughout the year; this report records cross-cutting facts and agendas with impacts across different sectors, both nationally and internationally.
COP30: Among the main outcomes of COP30, held in November 2025 in Belém (Pará), were the Global Stocktake Decision, which reinforced the implementation of the Paris Agreement, support for NDCs and national adaptation plans; progress toward a climate finance program to triple resources for the most vulnerable countries; and the commitment of the Brazilian presidency to present “roadmaps” to curb deforestation and reduce dependence on fossil fuels.
General Environmental Licensing Law: Law No. 15,190/2025 (LGLA) was enacted on August 8, 2025, with presidential vetoes later overturned by Congress, and Law No. 15,300/2025 instituted the Special Environmental License (LAE) on December 22, 2025. Public debate focused on expanding the simplified licensing regime (LAC) to medium-scale activities/pollution potential, on exemptions from prior assessment, and on the accelerated procedure of the LAE for “strategic projects,” a framework that led to judicial challenges and the suspension of the effects of the LGLA by the Supreme Federal Court (STF).
Climate Plan and implementation: On December 15, 2025, Brazil’s Interministerial Committee on Climate Change approved the Climate Plan, validating the National Mitigation Strategy (ENM), the National Adaptation Strategy (ENA), and sectoral plans through 2035, and forwarding the National Adaptation Plan to the UNFCCC. The act guides the implementation of the NDC (a 59%–67% reduction in net emissions by 2035) and structures targets across eight mitigation sectors and sixteen adaptation agendas.
Brazilian Sustainable Taxonomy (TSB): Decree No. 12,705/2025 established the TSB as an instrument of the Ecological Transformation Plan, defining principles (science-based approach, just transition, interoperability), governance by the CITSB, sectoral handbooks, and an MRV system (Monitoring, Reporting and Verification). Its guiding nature extends to public policies and private economic decisions.
Adaptation and resilience: infrastructure and health: The New PAC Selections, the federal government’s Growth Acceleration Program, allocated BRL 11.7 billion to urban drainage and slope-stabilization works in 235 municipalities (announcement on September 18, 2025), signaling climate-proofing in projects financed with federal resources. In the health sector, on December 5, 2025, the Ministry of Health launched the National Guide for Resilient Health Facilities, incorporated into the Health PAC, with standards for water and energy autonomy and reinforced structures to operate under extreme events, aligned with AdaptaSUS (MoH).
Case law: climate due diligence and imprescriptible liabilities: On August 22, 2025, the 9th Federal Court of Porto Alegre (Public Civil Action No. 5050920-75.2023.4.04.7100) suspended the licenses of the Candiota III Thermal Power Plant and the Candiota Mine, characterizing the case as structural climate litigation and ordering climate-related conditions and a transition plan with deadlines and daily fines (TRF4/JFRS). At the STF, Theme 1,194, with the decision published on April 8, 2025, established the imprescriptibility of enforcement claims for environmental damage remediation, including when converted into monetary damages, with general repercussion (STF – Theme 1,194; ARE 1,352,872). Also at the STF, the Court set aside the temporal framework of Law No. 14,701/2023, reaffirming the unconstitutionality of the criterion and establishing guidelines for the demarcation of Indigenous lands.
IFRS/ISSB reporting becomes the information core: The Brazilian Securities Commission (CVM) recognized IFRS S1/S2 standards and structured their adoption in Brazil through CVM Resolution No. 193/2023 (consolidated text), with adjustments introduced by CVM Resolution No. 227/2025 to enable voluntary adoption in 2025. Mandatory application applies to fiscal years beginning on January 1, 2026. CBPS 01 and 02 mirror the general sustainability requirements and climate disclosures to be integrated into financial statements, including governance, GHG metrics, targets, and scenarios, subject to assurance and double materiality.
Financial system: climate risk and prudence: The Central Bank maintained the GRSAC Report (Report on Social, Environmental and Climate Risks and Opportunities) and launched Public Consultation No. 127/2025 (November 4, 2025) to include quantitative requirements aligned with BCBS Pillar 3 and the ISSB, with a timeline providing for initial disclosures from 2028 for larger institutions (reference date 2027). The stated objective is to reduce asymmetries and standardize transparency, impacting credit documentation and pricing.
International climate finance: At COP30 (Belém), the Board of the Fund for Responding to Loss and Damage (FRLD) advanced the 2025–2026 start-up modalities and an initial call for proposals, with an envelope of USD 250 million and expectations of approvals beginning in 2026, according to official documents and pending decisions.
EUDR postponed and simplified, without relaxing its core: On December 23, 2025, the EU published Regulation (EU) 2025/2650, postponing the application of the EUDR to December 30, 2026 (medium and large companies) and June 30, 2027 (micro and small companies), and concentrating due diligence on the first operator (“first placing on the market”). Printed products were excluded, and a review and simplification by April 30, 2026 was предусмотрed, while preserving geolocation and legal compliance requirements in the country of production.
Legal perspectives for 2026, nationally and internationally
- Implementation of the Climate Plan through secondary regulation is expected to affect licensing, public procurement, and financing criteria;
- Consolidation of IFRS/ISSB reporting will require integrated data governance, materiality assessment, and assurance within financial statements;
- The financial system is likely to incorporate environmental reports, with quantitative climate-risk disclosures and contractual effects on provisions and insurance;
- With respect to the EUDR, export chains to the EU will require geolocated traceability and contractual allocation of responsibilities, mindful of the 2026/2027 timeline and the April 30, 2026 review;
- Pending judgments on actions challenging the LGLA, regulatory prudence is expected: robust mapping of conditions and studies, analysis of competences under Complementary Law No. 140/2011 (referenced in the LGLA itself), and contractual adjustments (procurement, EPC, financing) with triggers for rescheduling, provisions, and termination clauses in the event of changes in case law;
- Following approval of the Brazilian Emissions Trading System (SBCE) in 2024, 2025 and 2026 mark Phase I of the regulation of Law No. 15,042/2024. Accordingly, advances are expected this year in the rules for trading carbon credits in the regulated market, given the challenge of structuring a robust domestic system with clear rules, reliable methodologies, and environmental integrity—key to stimulating investment, strengthening the market, and contributing to sustainable development in Brazil;
- Despite the United States’ withdrawal from the Paris Agreement and its absence from COP30, with expected impacts on the global climate agenda, negotiations continue and COP31 will be held in Turkey, with Australia presiding over the negotiations. The presentation of the “roadmaps” announced in Belém is expected, aimed at a just transition away from fossil fuels and reversing deforestation, as well as monitoring the targets set at COP30;
- Although oil and natural gas continue to show significant demand globally, renewable energy sources maintain a more dynamic growth pace. In 2025, these sources surpassed fossil fuels in the global energy mix, according to a report by the Ember think tank, marking an important milestone in the advancement of the energy transition heading into 2026.
