Consulta Pública SDM 02/2025

For compliance teams at firms that issue, use, or distribute credit-rated instruments, the proposal signals tighter expectations around rating agency governance, methodological transparency and cross-border comparability. The immediate action is to monitor the consultation outcome and assess whether current counterparty and vendor due diligence frameworks can accommodate EU-aligned criteria. Firms relying on ratings for capital, collateral or investment mandates should review internal policies, rating use and fallback arrangements.

Credit rating agencies and market infrastructure providers may face higher operational and disclosure burdens. Although the consultation deadline appears to have passed, the 'Norma publicada' phase suggests firms should prepare for final requirements. UK and European firms with Brazilian exposure should consider equivalence and group-wide policy alignment.

Opportunities include improved comparability of ratings, stronger investor confidence and smoother cross-border issuance, but only if compliance teams update training, documentation and monitoring.