BR-Listed Companies

One consolidated report a month

Brazilian directors and officers do not publish their own trades. They report them to the company, which gathers the month's movements and files them with the Comissão de Valores Mobiliários (CVM) and with the market operator where its shares trade. The rule sits in article 11 of CVM Resolution 44 of 23 August 2021, in force since 1 September 2021. It replaced CVM Instruction 358 of 2002, which older documents still cite.

Who reports, and on what timetable

Article 11 covers the executive officers (diretores), the board of directors, the fiscal council and any technical or advisory body created by the bylaws. Each member must tell the company about every trade within five days, and about existing holdings on the first business day in office. The report gives quantity, price and date, the position before and after, and securities held by a spouse or partner, by dependants declared on the member's income-tax return and by companies the member controls. Derivatives referenced to the company's securities count too.

The company then has 10 days after the end of the month in which a position changed to send the information to the CVM, and the investor relations officer signs off the transmission. Holdings of board members, officers and fiscal council members appear consolidated by body, with no individual names. The CVM releases these monthly statements as an open dataset refreshed every week.

Controllers and the 5% steps

Article 12 sets a separate duty. Controlling shareholders, shareholders who elect board or fiscal council members, and any person or group acting together must notify the company immediately when their stake in a class of shares crosses 5%, 10%, 15% and each further five-point step, upwards or downwards. The notice states the purpose of the stake and whether the buyer seeks to change control.

Article 14 bars the company, its controlling shareholders, officers, directors and fiscal council members from trading in the 15 days before the release of quarterly and annual financial statements.

Reading Brazilian filings on this site

We ingest the CVM monthly statements as individual movements with quantity and unit price, so the feed counts as per-trade. Since the source withholds names, each filing attaches to a corporate body: insider pages show one anonymous entry per role, such as the board of directors or the executive officers. Amounts convert to euros, with the original reais shown when available. Allow for the lag: a trade made on the first day of a month can reach the CVM about 40 days later. The methodology explains how we process these filings.