ANBIMA and CVM Expand the Public Offering Matrix to Include Companies Under the EASY Regime

The Brazilian Association of Financial and Capital Market Entities (ANBIMA) announced, on September 28, 2026, the expansion of the public offering matrix of the technical cooperation agreement maintained with the Securities and Exchange Commission (CVM) (“Agreement”), which now includes offerings from companies opting for the FÁCIL Regime. With this change, these smaller companies will have access to the prior analysis procedure conducted by ANBIMA, followed by automatic registration by the CVM.

What is the public offering matrix?

The matrix lists the types of public offerings covered by the agreement between ANBIMA and CVM. In these offerings, ANBIMA analyzes the requests beforehand and, once the analysis is complete, registration is automatically obtained from the CVM, in accordance with CVM Resolution No. 160. The expansion took effect with the publication of the new public offering matrix, as per the expansion procedure foreseen in the Agreement itself.

With this inclusion, companies under the FÁCIL Regime will now have access to the same procedure already available for other types of offerings covered by the agreement.

The path to expansion

The inclusion was approved in the first half of 2026 by the CVM/ANBIMA Agreement Administration Committee. However, implementation depended on alignment with the CVM's Superintendency of Corporate Relations (SEP) regarding the scope of work, a step completed on September 9, 2026, thus fulfilling the condition established by the regulatory body for the change to take effect.

According to Guilherme Benaderet, Superintendent of Market Supervision at ANBIMA, the measure allows companies under the EASY Regime to "also use an analysis process that already works for other types of offerings." For Luis Miguel Sono, Superintendent of Securities Registration at the CVM, the expansion contributes to making the EASY Regime more effective and represents progress in implementing "regulatory treatment proportionate to its size, without neglecting investor protection and market integrity.".

The EASY Regime

As provided for in CVM Resolution No. 232, the EASY Regime establishes simplified rules for the participation of smaller companies in the capital market, including the exemption from certain information disclosure obligations and requirements for conducting public offerings, under the conditions stipulated by the regulation. Inclusion in the parent company adds to these simplifications access to a registration process already used in other offering modalities.

What companies should observe.

Companies considering opting for the EASY Regime now have another alternative for structuring their public offerings. The new public offering matrix should be consulted to verify the eligibility of each operation under the Agreement procedure, and more information about the agreements and cooperation agreements is available on the ANBIMA portal.

Mazzucco & Mello Advogados closely monitors these updates and advises its clients on structuring public offerings and adapting to regulatory requirements.

Article prepared by: Antonio Mazzucco, Paula Suraci and Marcos Buzo.

• “The inclusion of the EASY Regime in the agreement's framework brings smaller companies closer to a registration process already consolidated in other offering modalities, with prior analysis by ANBIMA and automatic registration with the CVM.”