GRSAC: applicability and transition matrix
Separate segment, reporting perimeter, table, reference date and deadline before deciding what to disclose.
Short answer: applicability has several dimensions
Do not determine a GRSAC obligation solely from an organization’s commercial size. Check institution type, regulatory segment, disclosure perimeter, table, reference date and transition rules. This page provides a preparation matrix, not a legal applicability determination.
Source status: official communication describes S1–S4 coverage and phased implementation of the new regime from 2027. GOV-2026:scope GOV-2026:transition Full operative provisions still need confirmation. A “pending” cell below is neither an exemption nor an extended deadline.
Decision matrix by entity and perimeter
| Dimension | What to record | Evidence needed before concluding |
|---|---|---|
| Entity type | Institution category and relevant authorization | Classification validated by regulatory staff |
| Segment | S1, S2, S3 or S4, where applicable | Regulatory record, not a revenue-based guess |
| Perimeter | Individual entity, conglomerate and relevant special treatment | Consolidated provision and reconciled organization chart |
| Table | Code, purpose, scope and conditions | Rule and incorporated layout version |
| Time | Effective date, reference date, deadline, first application | General and transitional provisions separately |
| Decision | Applicable, not applicable or pending, with rationale | Real reviewer, date and source locator |
Partial reference: article 2 of Resolution 139 addresses segments and consolidated basis; specific conditions, including cooperative arrangements, require full reading before use. BCB-139:scope Do not automatically carry earlier treatment into the new regime.
Enverium interpretation: an industrial company merely borrowing money does not become required to publish GRSAC because it receives a questionnaire. Assess contractual duties or other regimes applicable to that company separately.
Nominal table map in the consulted file
File contents, not final applicability confirmation: the BCB-hosted PDF lists the scopes below. Its headers say “Interno,” and OPO leaves a resolution number blank. Confirm the version adopted by IN 772 before treating this matrix as a rule. BCB-772:layout
| Family / code in PDF | Summarized topic | Nominal segments in file |
|---|---|---|
| CRFRA-GOV | Governance | S1–S4 |
| CRFRA-EST; CRFRA-GER | Strategy; management | S1–S3 |
| CRFRB | Climate risk and concentrations | S1–S3 |
| CRFR1; CRFR1 Agro | Sector exposures/emissions; agriculture by region | S1–S3 |
| CRFR2 Chuva Intensa; CRFR2 Seca | Exposures and physical risk | S1–S3 |
| PTC1; RSA1 | Transition plan; social and environmental risk | S1–S3 |
| COMP1; COMP2 | Commitments | S1–S4 |
| OPO | Opportunities | Optional, all segments in file |
Locators: BCB-LAYOUT:governance, BCB-LAYOUT:climate and BCB-LAYOUT:other. This map summarizes headings, not all row conditions. “S1–S3” alone does not establish the first reference date, every field’s obligation or treatment of irrelevant information.
Time matrix: known and outstanding
| Reference | Consulted status | Do not conclude without review |
|---|---|---|
| Resolution 139 / IN 153 | Earlier regime identified in the official index through the end-2026 transition | That every provision remains unchanged until the same date |
| Resolution 586 / IN 772 | New regime indicated from January 1, 2027 | That all tables share the same first delivery |
| Transitional provisions | Phased implementation announced | Deadline in days, first reference date or S3/S4 phasing |
The instrument relationship is supported by BCB-INDEX:grsac. Explicit regulatory issue: confirm each commencement, repeal and transition article in BCB-586:transition. We do not publish delivery dates inferred from secondary news reports.
Institution workflow
Enverium practice: complete the matrix by entity and period before assigning tasks. Do not let a software column determine an obligation. If the corporate structure or segment changes, retain the previous matrix and document the new conclusion.
Then connect each table to its data and owners. Record “outside scope,” “field not relevant under a confirmed rule” and “missing data” separately. These states require different rationales and should not produce the same unexplained blank cell.
Counterparty workflow
Enverium practice: ask the bank for the requested field’s definition and period. If it requests establishment-level data, do not silently send only a holding-company total. If banks request different formats, retain your own evidence base and document every transformation.
Do not try to choose the lender’s regulatory segment yourself. The company can clarify its perimeter and supply evidence; the institution must determine its obligation and appropriate use of received information.
Fictional cases to test the matrix
Case A, S2 institution: the team finds CRFR1 in the new file and starts collecting emissions data. Preparation can proceed, but the matrix retains first reference date and deadline as pending until the provisions are validated. Preparing data is not asserting a legal date.
Case B, S4 institution: the nominal map highlights governance and commitments. The team does not conclude “no climate obligations”: other regulatory layers and conditions still require analysis. Nor does it automatically assume every S1–S3 table.
Case C, Horizonte company: receiving a request for locations and emissions does not turn it into a regulated institution. The company responds to the bounded request and explains limitations; the bank remains responsible for its GRSAC matrix.
All cases are fictional and do not classify any real customer.
Matrix approval checklist
- Institution type and segment evidenced.
- Perimeter and any consolidation confirmed against a provision.
- Layout version checked against its incorporating rule.
- Effective date, reference date and deadline recorded separately.
- Table conditions and transitions verified without automatic inference.
- Issues resolved by an expert and bilingual review recorded.
Use limitations
This edition is deliberately incomplete as a legal calendar: essential primary-source confirmations remain outstanding. Do not use its tables to omit disclosure, promise compliance or configure a production deadline. Its immediate purpose is to organize research and prevent different dimensions from being confused.
Further reading
See the GRSAC overview and evidence chain. Taxonomy classifies activities under a different instrument; it does not determine an institution’s regulatory segment.
Primary sources and locators
Reference codes in the text identify the source and the locator below. “Verified” means the relevant source content was read, not that an expert approved this guide. Source titles and locator descriptions retain their registered language.
BCB-INDEX · Regulação prudencial — normas
Banco Central do Brasil · Index consulted 19 September 2026 · Checked: 2026-09-19 · Source read
Indexed official text identifies the 139/153 and 586/772 regime transition. This index is not a substitute for the operative provisions.
- grsac: Relatório GRSAC: Resolução BCB 139 / IN BCB 153 and Resolução BCB 586 / IN BCB 772
- framework: Responsabilidade social, ambiental e climática / gerenciamento de riscos
BCB-139 · Resolução BCB nº 139, de 15 de setembro de 2021
Banco Central do Brasil · Including indexed amendments; full consolidated-text confirmation pending · Checked: 2026-09-19 · Partial verification
Official search-index excerpts read. Direct HTTP retrieval returned an application shell, not the consolidated norm. Do not infer verification from HTTP 200.
- scope: Article 2: segments and consolidated basis; verify all paragraphs and current amendments
- tables: Articles 5–7: GVR, EST, GER, MEM and OPO; table presentation
BCB-586 · Resolução BCB nº 586, de 3 de setembro de 2026
Banco Central do Brasil · 3 September 2026 · Checked: 2026-09-19 · Partial verification
Instrument identified through official index and government announcement; full operative text not retrieved. Article-level deadlines, exceptions, commencement and repeal require expert verification.
- transition: Commencement, transitional provisions, deadlines and repeals — precise article locator pending verification
BCB-772 · Instrução Normativa BCB nº 772, de 3 de setembro de 2026
Banco Central do Brasil · 3 September 2026 · Checked: 2026-09-19 · Partial verification
Instrument identified in official index; operative text and incorporation of the published layout require confirmation.
- layout: Adoption/version of layouts — precise article locator pending verification
BCB-LAYOUT · Leiautes do Relatório GRSAC — v1
Banco Central do Brasil · PDF hosted by BCB; metadata dated 2 September 2026 · Checked: 2026-09-19 · Partial verification
PDF text read and first page visually checked. Headers say “Interno”; OPO contains an unresolved resolution-number placeholder. Table descriptions are evidence of this file's contents, not confirmation of the final legally adopted version.
- governance: CRFRA-GOV, CRFRA-EST, CRFRA-GER: headings and scope fields
- climate: CRFRB, CRFR1, CRFR1 Agro, CRFR2 Chuva Intensa, CRFR2 Seca: headings and scope fields
- quality: CRFR1: accompanying narrative on emissions-data quality levels 1–3
- other: PTC1, RSA1, COMP1, COMP2 and OPO: headings, scope and instructions
GOV-2026 · Novas regras ampliam transparência sobre riscos sociais, ambientais e climáticos no Sistema Financeiro Nacional
Ministério da Fazenda / BCB · 15 September 2026 · Checked: 2026-09-19 · Source read
Official government explanation, not the binding norm. Supports high-level transition only.
- transition: Paragraph beginning “As novas exigências entram em vigor em 1º de janeiro de 2027”
- scope: Paragraph beginning “A norma alcança as instituições enquadradas nos segmentos de 1 a 4”
How to cite this edition
Enverium. GRSAC: applicability and transition matrix. v1.0.0, 2026-09-19. Section: [#section-anchor].
Canonical URL: https://br.enverium.com/en/docs/grsac/aplicabilidade/.
Use the official source when citing a binding requirement. This explanatory guide does not replace legal or technical advice.