Who Must Comply with Brazil’s SBCE: The 10,000 and 25,000 tCO2e Thresholds Explained

If you searched for SBCE to find out whether your company is covered, the answer comes from three things: two numbers in the law, a sector calendar that is still a draft, and the status of the acts that will turn both into obligations. This guide puts them side by side so you can place your company and decide what to prepare first. Status checks below are dated October 21, 2026.

What the SBCE is

The SBCE is the Brazilian Greenhouse Gas Emissions Trading System, created by Law 15.042 of December 11, 2024. It is Brazil’s regulated carbon market. Operators of regulated installations and sources must submit a monitoring plan, report emissions and removals, and, for the larger band, report a periodic reconciliation of obligations (art. 29).

The law does not say in which year your sector starts. That depends on regulation by the SBCE managing body, which is still being written.

How the two thresholds work

Art. 30 sets two bands, and each one switches on a different list of duties from art. 29:

• Above 10,000 tCO2e per year: the duties in art. 29, items I, II and IV. That means submitting a monitoring plan, sending the emissions and removals report according to the approved plan, and meeting other obligations set by decree or by the managing body.
• Above 25,000 tCO2e per year: items I, II, III and IV. The added item III is the periodic reconciliation report, where emissions are matched against SBCE assets.

Three details in art. 30 matter in practice. Paragraph 1 allows the managing body to raise both thresholds by specific act, considering cost-effectiveness and Brazil’s climate commitments. Paragraph 2 limits the duties to activities that have consolidated measurement, reporting and verification (MRV) methodologies, as the managing body defines. Paragraph 3 exempts solid waste and effluent treatment units that prove they adopt systems and technologies to neutralize their emissions.

Who is covered by the SBCE

Read the text of art. 30 closely: it applies to the operators responsible for the installations and sources that emit above each number. The unit of measurement is the installation or source, not the corporate group.

An example with invented numbers. A cement group operates two plants. Plant A emits 12,000 tCO2e a year and plant B emits 30,000. Reading art. 30 as written, the operator of plant A falls in the first band (plan and report) and the operator of plant B in the second band (plan, report and reconciliation). The group total of 42,000 does not move plant A into the second band. How the regulation will define installation, source and operator in edge cases, such as shared sites, should be checked in the final acts.

Free guide (PDF): Brazil SBCE timeline 2024 to 2031 Download →

Size is only one filter. Sector and activity are the other, and that is where the calendar comes in.

The sector calendar: still a draft

The Ministry of Finance opened a public consultation on the sector phasing of MRV obligations on July 28, 2026, open until August 28, 2026, and describes the text as preliminary (gov.br notice). The proposed sequence:

• Stage 1, start expected in 2027: pulp and paper, integrated iron and steel, cement, primary aluminum, oil and gas exploration and production, petroleum refining and air transport.
• Stage 2, start expected by 2029: mining, recycled aluminum, semi-integrated steel, electricity, glass, ceramics, food and beverages, chemicals, solid waste and sewage treatment.
• Stage 3, start expected by 2031: road, rail and waterway transport.

The Ministry states that including a sector in MRV obligations does not by itself subject it to emission limits or reconciliation. Those pieces are to be defined later (gov.br notice on the MRV schedule). The notices I reviewed do not say whether the stage dates apply per installation or per company, so wait for the final text on that point.

Status of each act

According to the SBCE Scoreboard, updated on October 19, 2026, the consultation on the draft MRV phasing ordinance is closed and the final ordinance, planned for September 2026, is marked as late. The decrees on the MRV program and the emissions trading program, together with the MRV norms, are planned for December 2026. Until the final ordinance appears in the Official Gazette (DOU), every year in the list above is a proposal. This status will change, so check the Scoreboard before you act on any date.

Step by step: how to place your company

1. List your installations and sources. Build the latest annual inventory in tCO2e for each one, with the method written down.
2. Compare each one with the bands. Below 10,000, between 10,000 and 25,000, or above 25,000, keeping in mind that paragraph 1 allows the managing body to raise the bands.
3. Find your CNAE and your activity. Check whether it appears in Stage 1, 2 or 3 of the draft, and whether the activity has a consolidated MRV methodology (art. 30, paragraph 2).
4. Mark the status of each date. Draft, consultation closed, or published in the DOU.
5. Set a working date. A Stage 1 operator should plan for 2027 as a hypothesis, not a fact.

Common mistakes

• Treating the draft years as law. Law 15.042 does not fix 2027, 2029 or 2031.
• Adding up all facilities and comparing the total with the bands, when art. 30 speaks of installations and sources.
• Assuming that a sector in MRV is also subject to emission limits or reconciliation.
• Relying on an estimated inventory with no documented method.
• Waiting for the final ordinance to start collecting data.

What to do now

Start with the installation level inventory, because every other decision depends on it. Then read arts. 29 and 30 in the official text and mark where each installation falls. Check your sector against the draft stages and note the earliest year. If an installation sits close to 10,000 or 25,000 tCO2e, a change in the calculation method can move it across a band, so document the method now. Finally, follow the final ordinance and the decrees and update your plan when they are published.

Read next: Brazil SBCE tracker: every act with its primary source.

Sources

• Planalto: Lei nº 15.042, de 11 de dezembro de 2024
• Ministério da Fazenda: consulta pública sobre cobertura setorial do mercado regulado de carbono
• Ministério da Fazenda: consulta pública sobre o cronograma de MRV no mercado regulado de carbono

Read next

• Brazil SBCE tracker: every act with its primary source
• Free PDF guides on carbon markets
• Brazil SBCE timeline 2024 to 2031 (PDF)

Free guide (PDF): Brazil SBCE timeline 2024 to 2031 Download →