CVM/SRE Circular 4/2026 redraws Brazil’s automatic-offering application route

Lead coordinators must now record prior self-regulatory review inside the filing instead of selecting a separate "- AR" application. CVM/SRE Circular 4/2026 also changes mandatory issuer-status fields for offerings by unregistered companies. CVM said implementation was to be completed by 24 August.

The new fields apply to automatic-registration public offerings submitted to prior review by a self-regulatory organization. The SRE circular guides lead coordinators handling public offerings under the automatic-registration procedure, where a self-regulatory entity conducts prior review under Articles 94 and 95 of CVM Resolution 160. It also changes the parameters for offerings by unregistered issuers under CVM Resolution 232.

The circular separates the application name from the review disclosures and distinguishes that workflow from the fields used for unregistered issuers.

Three applications replaced

For offerings submitted to self-regulatory review, CVM will deactivate these applications:

- OPD Aut Profissional - com bookbuilding - AR
- OPD Aut Público em Geral ou Qualificado - com bookbuilding - AR
- OPD Aut Público em Geral ou Qualificado - sem bookbuilding - AR

Each will be replaced by an existing application with the same name, without the final "- AR" designation. The circular provides a table matching the deactivated applications to their replacements.

The replacement applications add three mandatory fields in the "Informações da Oferta" section. Applicants must indicate whether the offering received prior review from a self-regulatory entity, identify that entity and provide its process number. The replaced applications no longer carry the "- AR" ending, while the review status, reviewer identity and process reference move into required data fields.

This changes the filing mechanism, not the underlying prior-review procedure. Coordinators using the automatic-registration route with prior self-regulatory review must record the review organization and process number.

Unregistered issuers receive separate fields

Applications for offerings by unregistered issuers, identified by the expression "- emissores não registrados," receive a modified "Tipo Societário" field and a new conditional question. Applicants must answer whether the issuer qualifies as a small company, selecting "Sim" or "Não." Both fields are mandatory.

Where the corporate type is "Limitada," the answer to the small-company question must be "Não," because Article 2 of RCMV 232 applies the status only to sociedades anônimas. Filers for unregistered issuers must complete the corporate-type information and, where applicable, the conditional small-company field.

The changes took effect from publication of the circular and were scheduled for completion by 24 August. The source does not provide a separate transition period for applications already submitted or explain how incomplete filings will be handled during the changeover.

For applicants, the immediate requirement is to use the replacement applications and complete the new mandatory fields. The CVM directs questions about the SRE system exclusively to suporte-sistemasre@cvm.gov.br. No further implementation event or clarification is identified in the official record.