On March 16, 2026, Brazil’s Federal Government launched the new National Climate Change Plan (the “Climate Plan” — Plano Clima 2024-2035), a central instrument of the National Policy on Climate Change (PNMC), establishing guidelines and targets to steer greenhouse gas (GHG) emissions mitigation and climate adaptation efforts in Brazil over the next decade.
The Climate Plan consolidates Brazil’s strategy to implement its Nationally Determined Contribution (NDC), which provides for a reduction in net emissions of between 59% and 67% by 2035 (compared to 2005 levels), as well as the achievement of climate neutrality by 2050.
The new version of the Climate Plan—the revision process of which began in 2023—was developed under the coordination of the Civil House and the Ministry of Environment and Climate Change (MMA), with the participation of more than 25 ministries, as well as public consultations.
The Climate Plan is structured around three main pillars: (i) National Mitigation Strategy; (ii) National Adaptation Strategy; and (iii) Cross-Cutting Strategies for Climate Action, including topics such as climate finance, governance, monitoring, and just transition.
Under the mitigation pillar, the Climate Plan establishes eight sectoral plans, covering energy, industry, transport, cities , waste, and land use change, among other uses. Under the adaptation pillar, 16 sectoral and thematic plans have been defined, addressing sectors such as agriculture, water resources, infrastructure, health, and coastal zones.
Key elements of the Climate Plan include:
- Definition of sectoral emissions trajectories through 2035, with differentiated targets across sectors, including, in certain cases, the possibility of controlled emissions growth (notably in industry and transport), reflecting economic and structural trade-offs;
- Segmentation of land use across different regulatory fronts, with emphasis on the distinction between (i) public lands and protected areas; (ii) private rural lands; and (iii) agricultural activities, indicating a more granular approach to deforestation and land-use policies;
- Integration between mitigation and adaptation, with emphasis on nature-based solutions (NbS) and ecosystem-based adaptation (EbA) as tools for reducing climate risks and generating co-benefits;
- Strengthening of economic and financial instruments, including mechanisms such as the Climate Fund, Eco Invest Brazil and the Brazil Platform for Climate and Ecological Transformation Investments (BIP), with the expectation of mobilizing significant public and private resources; and
- Establishment of a governance and continuous monitoring framework, with periodic assessment cycles (annual reporting, biennial evaluations and structural reviews every four years), reinforcing the dynamic and adaptive nature of the Plan.
From a regulatory and market perspective, the Climate Plan is expected to have significant implications for companies across multiple sectors, particularly as it guides the development of public policies, secondary regulations and economic instruments associated with the climate agenda.
In particular, the following potential impacts on the private sector stand out:
- Energy and oil & gas: Reinforcement of the decarbonization agenda, with increased incentives for renewable sources, biofuels and low-carbon solutions.
- Industry: Increased regulatory and market pressure to reduce emissions and improve energy efficiency.
- Transport and aviation: Advancement of policies aimed at decarbonizing mobility, including sustainable fuels and electrification.
- Agribusiness: Greater scrutiny over emissions and land use, with incentives for sustainable production, but also potential regulatory challenges related to deforestation reduction and traceability.
- Infrastructure and cities: Growing incorporation of climate resilience criteria into projects, with impacts on permitting, financing and concession structuring.
- Financial sector: Expansion of climate finance instruments and increased integration with sustainable taxonomies.
In this context, companies are advised to assess the potential impacts of the Climate Plan on their business models, decarbonization strategies and exposure to regulatory and climate-related risks, as well as to closely monitor the evolution of sector-specific regulations stemming from the Plan.
Tauil & Chequer Advogados in association with Mayer Brown’s Environmental, Climate Change and Sustainability Practice remains available to provide further clarification on the impacts of the Climate Plan and to support the strategic assessment of its regulatory developments.
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