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Brazil – New Gender-Equity Disclosure Requirements
Law No. 15.177/2025 introduces comprehensive gender-equity transparency requirements for all Sociedades Anônimas (S.A.) companies in Brazil, marking a significant advancement in corporate governance and workplace equality standards.
This amendment to the Brazilian Corporations Law mandates detailed reporting on women’s representation and compensation across all organizational levels.
Key Requirements
Companies must now include the following detailed disclosures in their management reports:
- Numerical and proportional representation of women at each hierarchical level
- Women’s representation in management and board positions
- Gender-segregated compensation analysis, including:
- Fixed compensation
- Variable compensation
- Additional benefits
- Year-over-year comparative analysis of all indicators
Implementation Timeline
The requirements took effect on the 24th of July 2025, with first disclosures due at the 2026 Annual General Meeting.
Companies must report on the financial year ending in 2025, necessitating immediate action to establish data collection and reporting mechanisms.
Scope of Application
The law applies to:
- All S.A. entities (both listed and non-listed)
- Private and public companies
- Companies regardless of size or revenue
Compliance Requirements
Organizations must:
1. Formalize or update gender equity policies
2. Establish data collection mechanisms
3. Revise reporting templates to include required disclosures
4. Prepare comparative analyses between fiscal years
5. Include gender equity information in management reports
Risk Mitigation
Non-compliance carries serious consequences including:
- Suspension of board decision-making powers until compliance is achieved
- Potential regulatory penalties
- Reputational damage
- Impact on investor relations and stakeholder trust
Best Practices for Implementation
Companies should:
- Begin data collection processes immediately
- Review current gender distribution across all levels
- Analyze existing compensation structures
- Develop standardized reporting templates
- Establish internal monitoring mechanisms
How Mercator® by Citco (Mercator) Can Help
Our team can assist with reporting template preparation and ongoing compliance monitoring. We help organizations navigate these complex requirements while ensuring accurate and timely submissions.
For support with your regulatory reporting obligations in Brazil, contact mercator@citco.com
