Why your organization should conduct a carbon inventory by 2026: legislation, competitiveness, and positive impact.

By 2026, measuring and reporting greenhouse gas (GHG) emissions will no longer be a “nice to have” but a competitive differentiator—and, in many cases, an irreversible path to meet regulations, major clients, and investors. This guide summarizes the Brazilian regulatory landscape, global climate reporting trends, and practical steps for you to start (or improve) your corporate inventory, aligned with the GHG Protocol and international best practices.

Key context:
In 2024, Congress approved the regulation of the Brazilian carbon market, creating the Brazilian Emissions Trading System (SBCE) , with gradual implementation over six years . This accelerates carbon pricing, strengthens MRV (monitoring, reporting, and verification), and makes GHG inventories even more strategic for companies of all sizes.

Sources: Chamber of Deputies; Ministry of Development, Industry, Trade and Services (MDIC).
 

2026: The time to transform emissions measurement into a competitive advantage.

 

Over the past two years, Brazil has made progress in its carbon legal framework. With the SBCE ( Brazilian Carbon Emissions Control System) approved by Congress and awaiting sanction in 2024, the agenda for pricing and sectoral targets is now on the radar of compliance and corporate strategy. In practice, this means your company will need to accurately measure its emissions to:

  • Comply with regulatory requirements in a phased manner (SBCE will be implemented gradually);
  • Negotiating with more power in supply chains that already demand data and reduction targets;
  • To raise funds on better terms from investors who price in climate risk.

 
Furthermore, the Brazilian capital market is aligning its climate financial reporting with international standards IFRS S1/S2 (ISSB) . B3 announced early voluntary adoption —a clear signal to the market that climate risks and opportunities will be included in financial statements. Companies that arrive early with auditable data will have credibility and access to capital .

Sources: B3; EXAME; Grupo Report.
B3 – ISSB/IFRS S1 and S2 announcement | EXAME | Grupo Report – From TCFD to IFRS S2

 

What is a carbon inventory and why is it the foundation of everything?

The GHG inventory is the “X-ray” of a company’s emissions and largely follows the GHG Protocol — a globally recognized standard adopted in Brazil by the Brazilian GHG Protocol Program . It classifies emissions into:

  • Scope 1 (direct): combustion in boilers and own fleet, processes and fugitive emissions (e.g., refrigerants).
  • Scope 2 (indirect – energy): emissions associated with purchased electricity ( location-based and market-based ).
  • Scope 3 (indirect – value chain): purchases of goods and services, contracted transportation, travel, product use, end-of-life, among other upstream and downstream categories.

 
Measuring all three scopes is what allows for the definition of robust, comparable, and auditable goals—and achieving, for example, the “Gold Seal” in the public registry of the Brazilian GHG Protocol Program (requires complete coverage and third-party verification). In 2024, the number of inventories with the Gold Seal grew, reflecting market pressure and the imminence of carbon regulations .

Sources: WRI Brazil; Valor Econômico.
WRI Brazil – GHG Protocol and scopes  |  Valor – Gold Seal on the rise
 

Legislation and regulatory guidelines in Brazil: what changes for your company?

  • Regulated Carbon Market (SBCE): the project approved in 2024 stipulates a regulated and voluntary market , gradual targets, and robust MRV ( Monthly Reliability Report ). Implementation will be progressive over six years , which requires a history of reliable data from now on.
    Sources: Chamber of Deputies; MDIC (Ministry of Development, Industry and Foreign Trade).
    Chamber – approval | MDIC
  • Subnational movements: States like São Paulo (CETESB) are making the submission of inventories by specific sectors mandatory , even for emissions below 20,000 tCO₂e/year, expanding the scope of reporting.
    Source: CETESB (board decision and sectoral analyses).
    Analysis – mandatory requirement in São Paulo.
  • Capital markets and climate reporting: Brazil was one of the first countries to internalize IFRS S1/S2 standards through the CVM (Brazilian Securities and Exchange Commission), with voluntary adoption before it became mandatory . Leading companies, such as B3 ( Brazilian Stock Exchange), are accelerating the movement, and investors are beginning to demand quality and financial integration of climate data.
    Sources: B3; EXAME.

B3 – early adoption | EXAME
 
 

Customers, talent, and capital: why inventory attracts and retains value.

 

  1. Major players demand data and targets: multinational companies in sectors such as technology, automotive, food & beverage, and retail require complete inventories and SBTi targets from suppliers. Those who measure, prove, and reduce emissions remain eligible in global supply chains.
    Sources: Global Compact (SBTi); market analyses.
    Global Compact – SBTi in Brazil
  2. Reputation and talent attraction: qualified professionals seek companies with a real purpose , transparency, and impact. Reports aligned with TCFD/IFRS S2 and inventories with independent verification increase the confidence of employees and the market.
    Sources: Grupo Report; B3.
    From TCFD to IFRS S2 | B3 – ISSB/IFRS
  3. Access to capital and lower risk costs: banks and investors incorporate transition and physical risk into decisions. Reliable inventories and clear transition plans broaden eligibility for sustainable finance and improve credit conditions.
    Sources: B3; EXAME.
    B3 – announcement | EXAME

 

Positive impact and leadership: setting an example and preparing for the future.

Inventorying emissions is management , not just compliance. With data in hand, your company can define reduction levers (efficiency, electrification, renewables, product redesign, green logistics, circularity) and guide investments with returns and risk reduction . By publishing results and goals, you inspire partners, customers, and competitors—and leave a legacy of corporate sustainability.

To contextualize the strategy within the Brazilian reality (sectors and territories), use public data such as SEEG , which presents historical series of emissions by sector, state, and municipality. This helps prioritize actions and communicate the impact of your journey with credibility.
Sources: SEEG (Climate Observatory).
SEEG – Platform | SEEG – About

 

Step-by-step: how to do a (proper) carbon inventory in 2026

 

Define governance and boundaries.

 

  • Appoint an executive sponsor and a multidisciplinary team (sustainability/ESG, operations, procurement, finance, legal, IT).
  • Choose the boundary approach (equity share or operational control) and document all units (plants, distribution centers, fleet, franchises, joint ventures).

Reference: GHG Protocol – Fundamentals of Scope and Boundaries.
WRI Brazil – GHG Protocol

 

Map sources and data (Scopes 1, 2 and 3)

 

  • Scope 1: Fuels (diesel, LPG, natural gas), processes, refrigerants (HFCs).
  • Scope 2: electricity ( location-based and market-based ), contracts in the ACL and certificates (e.g., I-RECs).
  • Scope 3: purchases of goods and services, outsourced transportation, travel, product use, end-of-life, capital goods, etc.

 
Tip: prioritize Scope 3 material categories with primary supplier data and evolve over time (climate materiality matrix).
Sources: WRI Brazil; Anthesis.
WRI – scopes | Anthesis – scopes guide

 

Apply emission factors and ensure audit trails.

 

  • Use standardized GHG Protocol methodologies and recognized emission factors.
  • Structure evidence (notes, contracts, invoices, consumption reports, measurements), with versioning and access control.

 

Plan for third-party verification.

  • Seek assurance (limited, then reasonable) from an accredited verification body ; this increases market confidence and makes obtaining the Gold Seal in the Brazilian GHG Protocol Program viable.
    Source: Valor Econômico.
    Reports on the Gold Seal .

 

Connect inventory to goals and reduction plan.

 

  • Establish SBTi targets (short-term and Net Zero) and prioritize real reductions ; use offsetting only for residual emissions , in accordance with best practices.
    Sources: Global Compact (SBTi); recent analyses on credits.
    Global Compact – SBTi | ClimaInfo – debate on credits

 

Structure financial reporting and integration.

 

  • Align your climate report with the TCFD/IFRS S2 framework (governance, strategy, risk management, metrics and targets, scenarios).
  • Integrate the material impacts of climate change into the financial narrative and prepare for the requirements of the Brazilian Securities and Exchange Commission (CVM) .
    Sources: B3; Grupo Report.
    B3 – announcement | Grupo Report – IFRS S2

 

Anticipate SBCE and MRV compliance.

 

  • Maintain regulatory monitoring and be prepared to report when your sector/size falls under the new regulations. Historical data from 2025–2026 will be valuable for your compliance trajectory.
    Sources: Chamber of Deputies; MDIC (Ministry of Development, Industry and Foreign Trade).
    Approved regulation | MDIC Note

 

Frequently Asked Questions (FAQ) for those starting out in 2026

 
“My company isn’t a major issuer. Do I still have to inventory?”
Yes. In addition to any state/sectoral requirements (such as in São Paulo), supply chains and investors are already requesting data and targets — and the SBCE (Brazilian System for the Control of Electronic Bills) will be implemented gradually. Those who get ahead reduce risks and gain preference in contracts.
Sources: CETESB; Chamber/MDIC.
Mandatory in São Paulo | SBCE approved in Congress

“Do I need to measure Scope 3 right from the start?”
Ideally, yes, for the most material categories . Many companies start with 1 and 2, but the trend (and client demand) is for broad coverage , especially to validate SBTi and obtain Gold Certification in Brazil.
Sources: WRI Brazil; Valor.
GHG Protocol – scopes | Gold Certification

“Does offsetting solve the problem?”
Offsetting (credits) does not replace real reductions and should be reserved for residual emissions . Best practices and recent debates reinforce this priority, especially for Scope 3.
Sources: Global Compact (SBTi); ClimaInfo.
SBTi in Brazil | Debate on credits

“How do I contextualize my plan within the reality of Brazil?”
Use SEEG data to understand the sectoral/state trajectory and cite public references (e.g., factors in the electricity matrix, regional trends). This enriches the materiality analysis and communication with stakeholders.
Sources: SEEG.
SEEG – platform

Get started now with a simple and effective roadmap.

 

Sustain Quality can support you in starting and scaling your carbon inventory with GHG Protocol methodology , independent assurance , SBTi targets , and TCFD/IFRS S2- aligned reporting — ready for the SBCE regulatory journey .

Suggested itinerary (90 days):

  1. Executive workshop (2h) : GHG Protocol, SBCE, IFRS S2 and definition of limits/scopes.
  2. Data roadmap : energy, fuels, critical inputs, logistics, refrigerants (with climate materiality matrix).
  3. Inventory based on the year 2025 and publication in 2026 with independent verification and a decarbonization plan prioritized by ROI and risk.
  4. SBTi/TCFD/IFRS S2 Roadmap : goals, governance, financial integration and audit trails.

 
Ready to take the first step? Talk to Sustain Quality for an initial diagnosis and a plan tailored to your industry and value chain.