The Brazil Securities Commission's Superintendence of Corporate Relations has published Circular Letter CVM/SEP 4/2026 to guide administrators of organized markets on the procedures for migrating a public company registration to smaller company status under CVM Resolution 232. The guidance clarifies the conditions to be checked in the migration process, centered on issuer size and investor consent. When assessing a migration request, market administrators must verify that consolidated annual gross revenue is below BRL 500 million based on the financial statements for the end of the last fiscal year. They must also confirm the consent of holders of outstanding securities. Once the migration request is approved, the market administrator must send a communication to the CVM through the Digital Protocol system, addressed to the Superintendence of Corporate Relations, requesting the registration migration.
Brazil Securities Commission (CVM)2026-07-10
Brazil Securities Commission issues guidance on migrating public company registrations to smaller company status under the BRL 500 million revenue threshold
The Brazil Securities Commission has issued guidance for organized market administrators on migrating a public company registration to smaller company status under CVM Resolution 232. Administrators must verify consolidated annual gross revenue below BRL 500 million and obtain consent from holders of outstanding securities. After approval, they must notify the CVM to request the migration.