The Brazilian Superintendence of Private Insurance (SUSEP) published guidance on the next steps for regularising mutual patrimonial protection operations under Complementary Law No. 213/2025, setting out a three-phase process and emphasising that no firms are currently authorised to act as administrators. Phase I (registration) closed on 15 July 2025 with more than 2,000 associations registered, which SUSEP described as a necessary condition for an entity to be considered regular in the future. Phase II (rulemaking), now under way, covers drafting the subordinate regulation that will establish the criteria, parameters and obligations for authorising mutual patrimonial protection administrators. Phase III (regularisation) will begin only after the regulation is issued and administrators are authorised, at which point registered associations will have to enter into a contract with an authorised administrator and submit it to SUSEP within deadlines still to be defined; any contract submitted before the National Council of Private Insurance (CNSP) approves the rule and SUSEP authorises administrators will not be valid for regularisation purposes. SUSEP added that administration of these operations will be exclusive to previously authorised administrators and that operating without SUSEP authorisation constitutes an infringement subject to sanctions. The draft regulation is in its final stages and will be submitted to a public consultation shortly, after which SUSEP will assess contributions and seek final approval from SUSEP’s Board and the CNSP before announcing authorised administrators and the timelines for associations to complete regularisation.

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