MRV in Brazil’s Regulated Carbon Market: What Operators Must Monitor, Report and Verify

If you run a cement plant, a refinery or an airline in Brazil, carbon MRV is the first part of the regulated market that will land on your desk. Long before there is a cap, a quota or an auction, the Brazilian Emissions Trading System (SBCE) asks operators to measure their emissions, report them and have the numbers checked by a third party. This guide covers what Law 15,042/2024 already requires, what the draft ordinance put out in Public Consultation 1/2026 proposes, and which pieces are still missing.

Carbon MRV: what the acronym covers in the SBCE

MRV stands for monitoring, reporting and verification. The law uses a close variant, measurement, reporting and verification, and defines it in article 2, item XVIII, as the set of guidelines and rules used to measure, report and verify, in a standardised way, emissions by sources and removals by sinks.

In practice these are three separate deliverables. Monitoring is the internal system that collects fuel, process and production data. Reporting is the annual document sent to the managing body. Verification is the independent check of that document before it counts for the system.

The core instrument is the monitoring plan. Article 2, item XXIII, defines it as the document drawn up by the operator describing how it will implement its MRV routine. Without an approved plan there is no valid report.

How the three-year cycle works

Articles 29 to 34 of Law 15,042/2024 set the obligations. The operator must submit a monitoring plan to the managing body (article 29, I), send an annual report of emissions and removals under the approved plan (article 32) and, above the higher threshold, send a periodic reconciliation report (article 34).

The draft ordinance published by the Extraordinary Secretariat for the Carbon Market (SEMC) in Public Consultation 1/2026, open from 28 July to 28 August 2026, turns this into a fixed calendar in its article 2:

• Year 1 (A1): the operator submits the monitoring plan to the managing body for review and approval.
• Year 2 (A2): actual monitoring of emissions and removals across the calendar year, following the approved plan.
• Year 3 onward (A3): the operator keeps monitoring and files the verified emissions and removals report for the previous year.

The sole paragraph of that article says minimum content, format, deadlines and procedures will come in a separate act of the managing body, published at least one hundred and twenty calendar days before the obligations start. All of this is a proposal. The final ordinance had not been published when this guide was written.

A concrete example: a cement plant in the first stage would use 2027 to build and file its plan, 2028 to measure, and 2029 to deliver its first verified report covering 2028.

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

Who is covered: thresholds and stages

Article 30 of the law sets two thresholds. Installations and sources emitting more than 10,000 tCO2e a year must have a monitoring plan and report. Above 25,000 tCO2e a year, periodic reconciliation is added, meaning the duty to surrender assets (CBEs or CRVEs) matching emissions. Paragraph 1 lets the managing body raise those thresholds. Paragraph 2 limits the obligations to activities with consolidated MRV methodologies.

Article 3 of the draft phases sectors in over three stages, identified by CNAE activity codes in Annexes I and II:

• Stage 1, A1 in 2027: primary aluminium, integrated steel, cement, oil and gas exploration and production, refining, pulp and paper, and air transport.
• Stage 2, A1 by 2029: secondary aluminium, semi-integrated steel, chemicals, mining, food and beverages, waste, sewage, ceramics, glass and the power sector.
• Stage 3, A1 by 2031: waterborne, rail and road transport.

Two caveats. Being under a listed CNAE code does not automatically bring an activity into MRV: the regulated sources, installations and operators will be defined by the managing body in a separate act (article 3, paragraphs 1 to 3). And the consultation page on Brasil Participativo states that joining MRV does not, by itself, create an emissions cap or any duty to buy or sell assets.

Step by step: building the MRV routine

1. Map installations and sources. The law defines an installation (article 2, XV) as the physical site holding one or more stationary sources, and a source (article 2, XII) as any fixed or mobile process or activity under the operator’s control. List everything by legal entity and address.
2. Estimate emissions per installation. Compare against the 10,000 and 25,000 tCO2e thresholds. A corporate GHG Protocol inventory helps, but the SBCE counts per installation, not per company.
3. Place your sector in a stage. Check the draft annexes and the final act once published.
4. Write the monitoring plan. Describe sources, gases, calculation or direct measurement method, emission factors, data frequency, responsible staff, quality controls and the document trail. Official templates do not exist yet, so treat this as a draft to adapt.
5. Run monitoring for a full year. Keep evidence: fuel invoices, mass balances, meter calibration records.
6. Hire verification. Article 32, sole paragraph, requires conformity assessment by an inspection body accredited under an act of the managing body.
7. File the verified report. Under article 33, validated data goes into the SBCE Central Registry in the operator’s own account.

What to expect from the verifier

The law speaks of an accredited inspection body. At the first meeting of the MRV working group (GT MRV) on 12 May 2026, Inmetro argued for keeping accreditation separate from enforcement, and the SEMC coordination said independent verification will be paid for by regulated operators. Accreditation, conduct and supervision of verifiers are among the topics assigned to the group by article 2, IV, of Resolution CTCP/SBCE 3/2026.

Until the rule comes out, prepare for what verifiers in emissions trading systems usually do: site visits, sampling of primary data, emission factors cross-checked against the official source, meter calibration checks and uncertainty analysis. Unresolved discrepancies become qualifications in the opinion, and the working group is also tasked with procedures for handling inconsistencies (article 2, VII).

Common mistakes

• Confusing the corporate inventory with regulated MRV. Voluntary inventories aggregate by company and include scope 3. The SBCE looks at installation and source.
• Waiting for the official template to start. The plan needs a data history. Whoever starts collecting only when the ordinance is out arrives late to A1.
• Treating a CNAE listing as automatic coverage. The draft is explicit that final coverage depends on an act of the managing body.
• Ignoring reconciliation. Above 25,000 tCO2e, reporting is only the start; assets will have to be surrendered once the first National Allocation Plan arrives.
• Underestimating penalties. Article 37 provides for fines of up to 3 percent of gross revenue from the previous year, rising to 4 percent for repeat offences, plus embargo and suspension of activity.

What has not been published yet

As of October 2026, this was the picture according to the ESG Minute SBCE Scoreboard:

• The final ordinance on MRV stages, expected in September 2026, had no number and no publication in the Official Gazette.
• The Regulatory Affairs Chamber (CAREG), provided for in article 9, paragraph 2, of the law and in Decree 12,768/2025, had not yet been constituted by ordinance.
• The decree for the Brazilian MRV programme, which the market calls PBMRV and the working group minutes call the Brazilian Emissions Reporting Programme (PBRE), and the technical MRV rules are scheduled for December 2026. That is a timetable target, not a rule in force.
• There is still no official monitoring plan template, no list of accredited verifiers and no official sector methodologies.

The GT MRV, created by Resolution CTCP/SBCE 3/2026 (Official Gazette of 12 May 2026), has a mandate of up to one year from its first meeting, renewable once (article 9). Its recommendations feed the managing body, a role currently exercised on a transitional basis by the SEMC.

What to do now

1. Identify installations above 10,000 tCO2e and, among them, those above 25,000.
2. Confirm your CNAE codes and the stage proposed in the draft.
3. Start collecting activity data per source in 2026, with an evidence archive.
4. Write a version zero of the monitoring plan to adjust once the official template is out.
5. Approach inspection bodies with greenhouse gas verification experience and watch for the accreditation call.
6. Track the status of each act on the SBCE Scoreboard and follow public consultations on Brasil Participativo, which article 8, paragraph 1, of the law makes mandatory for MRV rules.

Sources

• Law 15,042 of 11 December 2024 (Planalto)
• Public consultation on MRV obligations under the SBCE, draft ordinance (Brasil Participativo)
• Ministry of Finance: public consultation opened on the MRV timeline (gov.br)
• Resolution CTCP/SBCE 3 of 11 May 2026 (Official Gazette, via gov.br)
• Minutes of the first GT MRV meeting, 12 May 2026 (gov.br)

Read next

• Brazil SBCE tracker: every act with its primary source
• Free PDF guides on carbon markets

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