GRSAC applicability and transition

GRSAC applicability criteria

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.

Official communication describes S1–S4 coverage and phased implementation of the new regime from 2027. GOV-2026:scope GOV-2026:transition This edition does not confirm every provision defining deadlines and conditions of application. A “pending” cell below is neither an exemption nor an extended deadline.

Decision matrix by entity and perimeter

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

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.

Regulatory transition deadlines

The instrument relationship is supported by BCB-INDEX:grsac. The commencement, repeal and transition articles in BCB-586:transition are not confirmed in this edition. The general announcement does not establish each table’s first delivery date.

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.
• Applicability and calendar validated by the responsible regulatory team.

Use limitations

The matrix organizes applicability criteria and the data needed to prepare the report. Because this edition does not confirm every transitional provision and the adopted layout version, it does not establish exemptions or delivery deadlines. Those decisions require analysis of the rules applicable to the institution.

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.