Circular Letter CVM/SEP 02/26

SECURITIES AND EXCHANGE COMMISSION OF BRAZIL
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Circular Letter No. 2/2026-CVM/SEP
Rio de Janeiro, May 18, 2026.
Subject: Guidelines for organized market administrators to obtain initial registration of securities issuers from smaller companies (CMP).

Dear Representatives of Organized Market Administrators,

1. This Circular Letter aims to guide organized market administrators ("Market Administrators") regarding the procedures to be observed for the initial registration of securities issuers by smaller companies (“CMP”), in accordance with CVM Resolution No. 232/25, especially regarding the supervision exercised by such entities and the operational flow of communication with the CVM.

2. Initially, Market Administrators must analyze listing applications from smaller companies in accordance with the rules set forth in the Technical Cooperation Agreement entered into with the CVM and in compliance with the provisions of CVM Resolution No. 232/25. In this initial stage, the analysis of the documentation presented by the company must be carried out outside the Empresas.Net System (“E-NET System”).

3. After the approval of the listing application, the Market Administrator must send a notification to the CVM, through the Digital Protocol (https://www.gov.br/cvm/pt-br/canais_atendimento/protocolo-digital), addressed to the Department of Corporate Relations ("SEP"), informing the listing of the smaller company, for the purpose of obtaining automatic registration as a securities issuer, in accordance with CVM Resolution No. 232/25.

4. The Market Administrator must certify that the CMP has made the payment of the due inspection fee, in accordance with Law No. 7.940/89, as well as that the amount paid corresponds to that established in Annex V of the aforementioned Law.

Circular Letter 2 (2678311) SEI 19957.005197/2026-40 / pg. 1

5. The protocolled communication must present:

a) the following attachments (i) PDF version of the Registration Form (correctly filled out by the issuer), which will be used to fill out the CVM systems; and (ii) copies of the Payment Guide and the proof of payment of the inspection fee made by the issuer; and

b) a list of the documents analyzed by the Market Administrator, which must be made publicly available by the E-NET System, after obtaining registration with the CVM, in accordance with CVM Resolutions No. 80/22 and No. 232/25, following the model of the table below:

Nº	Documents	Associations in the E-NET System
	Registration Form 202X	As provided for in CVM Resolution No. 232/25, Annex A, Article 1, item VII. We highlight that the document must have the following fields properly filled out: “Registration Status”, “CVM Registration Date”, “Start Date of Registration Status” and registration in the current category, and the “Securities” field must be updated, if applicable.
	CMP Category
	Reference Form 202X or FÁCIL Form	Reference Form, as provided for in Article 22, item II c/c Article 25, both of CVM Resolution No. 80/22, if opting not to submit the FÁCIL Form. or FÁCIL Form 202X, as provided for in Article 22, § 4º, of CVM Resolution No. 232/25, if opting not to submit the Reference Form.
	CMP Category or CMP Category Reference Form or FÁCIL Form
	Quarterly Information Form (“ITR”) or Semi-Annual Information Form ("ISEM")	Quarterly Information Form, as provided for in Article 22, item V, c/c Article 31, both of CVM Resolution No. 80/22, if opting not to submit the Semi-Annual Information Form (“ISEM”). or Semi-Annual Information Form, as provided for in Article 22, § 9º, of CVM Resolution No. 232/25, if opting not to submit the Quarterly Information Form (“ITR”).
	CMP Category or CMP Category ITR – Quarterly Information Semi-Annual Information Form ISEM
	Consolidated Bylaws	In observance of the provisions of CVM Resolution No. 232/25, Annex A, Article 1, item IV.
	CMP Category Bylaws
	Financial statements, audited and prepared in accordance with Law No. 6.404/76, and with CVM norms	In accordance with CVM Resolution No. 232/25, Annex A, Article 1, item VIII.
	CMP Category Type or CMP Category Type Species
	Economic-Financial Data
	Complete Annual Financial Statements
	Economic-Financial Data
	Additional Financial Statements Specifically Prepared for Initial Registration
	Copies of shareholder agreements or other social pacts filed at the issuer's headquarters	In accordance with CVM Resolution No. 232/25, Annex A, Article 1, item X.
	CMP Category Shareholder Agreement
	List of waivers of regulatory obligations	In accordance with Article 16 of CVM Resolution No. 232/25.
	CMP Category List of Waiver of Regulatory Obligations
	Minutes of the general assembly or corporate act that approved the listing request	In accordance with CVM Resolution No. 232/25, Annex A, Article 1, item II.
	CMP Category Type Species
	General Assembly
	EGA, EGA/E or EGA/E
	Minutes

Circular Letter 2 (2678311) SEI 19957.005197/2026-40 / pg. 3

Corporate act designating the investor relations director	In accordance with CVM Resolution No. 232/25, Annex A, Article 1, item III.
CMP Category Type Species
Administration Meeting
Board of Directors
Minutes

6. After carrying out internal procedures, the SEP will send an RIC Letter to the CMP, with a copy to the Market Administrator, informing the approval of the registration and the CVM code of the company. At this moment, the SEP will have already enabled the CMP's IRD's access to the E-NET System, which will be enabled to send the relevant documents for registration.

7. Once the documents have been sent by the CMP through the E-NET System, which must occur immediately after the registration is granted, it will be the responsibility of the Market Administrator to verify if the documents made available correspond to those analyzed within the scope of the listing application, if all were sent in the correct associations of the E-NET System, and if they remain available on the Market Administrator's page on the worldwide web, in accordance with § 2º of art. 14 of CVM Resolution No. 80/22.

8. If the Market Administrator finds that any document was not sent, is incorrectly filled out, or has been made available in an incorrect association, it must contact the company immediately so that the inconsistency is remedied.

9. We emphasize that any problems or difficulties in sending these documents must be reported, on business days, from 8 am to 8 pm, to the CVM's external support, by email: suporteexterno@cvm.gov.br or by phone: 0800 944-3535.

Sincerely,

FERNANDO SOARES VIEIRA
Department Head of Corporate Relations

Document electronically signed by Fernando Soares Vieira, Department Head, on 05/18/2026, at 09:22, based on art. 6 of Decree No. 8.539, of October 8, 2015.
The authenticity of the document can be checked on the site https://sei.cvm.gov.br/conferir_autenticidade, informing the verification code 2678311 and the CRC Code CEA32A57.

This document's authenticity can be verified by accessing https://sei.cvm.gov.br/conferir_autenticidade, and typing the "Verification Code" 2678311 and the "CRC Code" CEA32A57.

Circular Letter 2 (2678311) SEI 19957.005197/2026-40 / pg. 4

Reference: Process No. 19957.005197/2026-40 SEI Document No. 2678311 Circular Letter 2 (2678311) SEI 19957.005197/2026-40 / pg. 5