Circular Letter CVM/SRE 02/26

SECURITIES AND EXCHANGE COMMISSION OF BRAZIL
Rua Sete de Setembro, 111/2-5th and 23-34th Floors, Centro, Rio de Janeiro/RJ – CEP: 20050-901 – Brazil - Tel.: (21) 3554-8686 Rua Cincinato Braga, 340/2nd, 3rd and 4th Floors, Bela Vista, São Paulo/ SP – CEP: 01333-010 – Brazil - Tel.: (11) 2146-2000 SCN Q.02 – Bl. A – Ed. Corporate Financial Center, S.404/4th Floor, Brasília/DF – CEP: 70712-900 – Brazil - Tel.: (61) 3327-2030/2031 www.cvm.gov.br Circular Letter No. 2/2026/CVM/SRE Rio de Janeiro, March 12, 2026. Subject: Guidelines on procedures to be observed by coordinators in registration requests for public distribution offers of securities (OPD) or public acquisition offers of shares (OPA) in case of unavailability of the SRE System.

Dear Director,

1. This Circular Letter contains guidelines regarding the procedures to be observed by lead coordinators or intermediary institutions (in the case of OPAs) in registration requests for public distribution offers of securities or public acquisition of shares in case of unavailability of the SRE System.

I - Unavailability of the SRE System

2. Unavailability of the SRE System is understood as the impossibility of accessing the system or any problem that prevents the submission of electronic registration requests for public offers, caused by failures in CVM's systems or infrastructure.

3. It should be noted that only systemic events that affect all or the vast majority of system users and are identified as such by CVM's Information Technology teams fall under the concept of Unavailability of the SRE System.

4. Point-of-access difficulties by participants, related to their own infrastructure or system operation, do not fall under this concept.

5. Unavailability of the SRE System will be considered if the system is unavailable during business hours and remains inoperative after 6 PM.

II - Procedure to be adopted by lead coordinators or intermediary institutions (in the case of OPA) in case of Unavailability of the SRE System

6. In case of Unavailability of the SRE System, the lead coordinator or intermediary institution (in the case of OPA) must:

1) In the submission of new electronic registration requests for public distribution offers (OPD) that follow the automatic procedure and use the market phase before registration (offers with bookbuilding, or that require the market phase before registration is granted):
(i) Publish the public documents of the offer in all locations provided for in art. 13 of RCVM 160; (ii) Send the documentation required for the submission of the electronic request to the support email: suporte-sistemasre@cvm.gov.br, in order to prove the existence/completeness of the documents necessary for the request at the time of Unavailability of the SRE System; (iii) Send along with the email to support evidence that the SRE System was unavailable throughout the day, demonstrating such situation in at least 4 (four) attempts spaced by at least 1 hour, with 1 (one) of them after 6 PM; (iv) Submit the electronic registration request and insert all relevant documentation in the SRE System as soon as the system returns; (v) After the successful attempt to submit the electronic request, reply to the email opening the ticket with support informing that the request was submitted successfully (we ask that you observe the ticket number of the call in the SUBJECT field of the email, to avoid opening a new call to deal with already forwarded demands).

2) In the submission of new electronic registration requests for public distribution offers (OPD) that follow the automatic procedure and do not use the market phase before registration (offers without bookbuilding, or that do not require the market phase before registration is granted, i.e., offers registered at the time of submission of the request) provided that the start of distribution is scheduled for the date on which the Unavailability of the SRE System occurs [1]:
(i) Publish the public documents of the offer in all locations provided for in art. 13 of RCVM 160, with the alert "registration pending due to SRE System failure"; (ii) Send the documentation required for the submission of the electronic request to the support email: suporte-sistemasre@cvm.gov.br, in order to prove the existence/completeness of the documents required for the request at the time of Unavailability; (iii) Send along with the email to support evidence that the SRE System was unavailable throughout the day, demonstrating such situation in at least 4 (four) attempts spaced by at least 1 hour, with 1 (one) of them after 6 PM; (iv) Submit the electronic registration request and insert all relevant documentation in the SRE System as soon as the system returns; (v) After the successful attempt to submit the electronic request, reply to the email opening the ticket with support informing that the request was submitted successfully (we ask that you observe the ticket number of the call in the SUBJECT field of the email, to avoid opening a new call to deal with already forwarded demands).

3) In the submission of new electronic registration requests for public distribution offers (OPD) that follow the ordinary procedure, as well as in the processing between phases in such requests:
(i) Evaluate whether the submission of the electronic request on another date compromises the offer schedule, so that, if there is no effective compromise, the guideline is for the regulated entity to wait for the return of the SRE System or the deadline so that there is no compromise of the schedule provided for the offer; (ii) If applicable, that is, from the moment the offer goes to market, publish the public documents in all locations provided for in art. 13 of RCVM 160. If the offer goes to market only upon the publication of the Start Announcement and Final Prospectus, said documents must contain the alert "registration pending due to SRE System failure"; (iii) Send the documentation required for the submission or processing of the electronic request to the support email: suporte-sistemasre@cvm.gov.br, in order to prove the existence/completeness of the documents required for the request at the time of Unavailability; (iv) Send along with the email to support evidence that the system was unavailable throughout the day, demonstrating such situation in at least 4 (four) attempts spaced by at least 1 hour, with 1 (one) of them after 6 PM; (v) Submit or process the electronic registration request, inserting all relevant documentation in the SRE System as soon as the system returns; (vi) After the successful attempt to submit or process the electronic request, reply to the email opening the ticket with support informing the success of the operation (we ask that you observe the ticket number of the call in the SUBJECT field of the email, to avoid opening a new call to deal with already forwarded demands).

4) In the submission of new electronic registration requests for public acquisition offers of shares (OPA) that follow the ordinary procedure:
(i) Publish the public documents of the offer (Draft of the OPA Instrument and eventually the Valuation Report) in all locations provided for in § 1 of art. 23 of RCVM 215; (ii) Send the documentation required for the submission of the electronic request to the support email: suporte-sistemasre-opa@cvm.gov.br, in order to prove the existence/completeness of the documents required for the request at the time of Unavailability of the SRE System; (iii) Send along with the email to support evidence that the SRE System was unavailable throughout the day, demonstrating such situation in at least 4 (four) attempts spaced by at least 1 hour, with 1 (one) of them after 6 PM; (iv) Submit the electronic registration request and insert all relevant documentation in the SRE System as soon as the system returns; (v) After the successful attempt to submit the request, reply to the email opening the ticket with support informing that the request was submitted successfully (we ask that you observe the ticket number of the call in the SUBJECT field of the email, to avoid opening a new call to deal with already forwarded demands).

5) In the submission of new electronic registration requests for public acquisition offers of shares (OPA) that follow the automatic procedure:
(i) Publish the public documents of the offer (Definitive OPA Instrument and eventually the Valuation Report) in all locations provided for in § 1 of art. 23 of RCVM 215, with the alert "registration pending due to SRE System failure"; (ii) Send the documentation required for the submission of the electronic request to the support email: suporte-sistemasre-opa@cvm.gov.br, in order to prove the existence/completeness of the documents required for the request at the time of Unavailability of the SRE System; (iii) Send along with the email to support evidence that the SRE System was unavailable throughout the day, demonstrating such situation in at least 4 (four) attempts spaced by at least 1 hour, with 1 (one) of them after 6 PM; (iv) Submit the electronic registration request and insert all relevant documentation in the SRE System as soon as the system returns; (v) After the successful attempt to submit the request, reply to the email opening the ticket with support informing that the request was submitted successfully (we ask that you observe the ticket number of the call in the SUBJECT field of the email, to avoid opening a new call to deal with already forwarded demands).

III - Guidelines for resolving the most frequent problems of difficulty accessing the SRE System

7. In case of problems or difficulty accessing the SRE System, we suggest following the following steps:
   (i) check if the user has access permission to the SRE System; (ii) log out and log in again to the SRE System; (iii) to ensure that there are no conflicts due to any system update, perform the following procedure to empty the browser cache, according to the guidance below:
   (a) with the SRE System window open in the browser, press F12 to open the developer tool; and (b) in the browser window, right-click on the page reload button, and select the option "Empty cache and hard reload", as shown in the image below:

IV - Final Provisions

9. It is important to highlight that the SRE System is subject to periods of unavailability, and the service to users external to the systems made available by CVM to the market is carried out between 8 AM and 8 PM from Monday to Friday. Information about this support is available at https://www.gov.br/cvm/pt-br/canais_atendimento/suporte-a-sistemas.

10. In this sense, we advise that operations that have sensitivity regarding the date of going to market or even distribution be presented or have the bookbuilding informed in the SRE System considering that any technological problem can only be treated within the aforementioned hours.

11. We alert that the sending of any documentation outside the SRE System has no validity for the purposes of compliance with RCVM 160, so that the registration will only be considered as granted, or even the offer will be considered to market, once the Electronic Request Form has been presented, under penalty of irregular conduct of public distribution offer, except in the cases of Unavailability of the SRE System described in this Circular Letter.

12. The procedures described in this Circular Letter apply only to cases of Unavailability of the SRE System. If the system failure is not proven or if a failure on the part of the lead coordinator is found, the adoption of the aforementioned procedures may constitute irregularity.

V - Support Contact

12. We reiterate the guidance that inquiries regarding the SRE - Offers Registration System should be directed exclusively to the emails:
    (i) Public Distribution Offer (OPD - automatic or ordinary procedures): suporte-sistemasre@cvm.gov.br; or (ii) Public Acquisition Offer (OPA - automatic or ordinary procedures): suporte-sistemasre-opa@cvm.gov.br

13. Only electronic messages directed to such addresses will be answered, and it is not necessary to send a copy to any other address.

Sincerely,

LUIS MIGUEL R. SONO
Superintendent of Securities Registration
_________________________________________________ [1] If the Start Announcement is not scheduled to be published on the date on which the Unavailability of the SRE System occurs, the regulated entity must wait for the return of said system to carry out the registration request.

Document electronically signed by Luis Miguel Jacinto Mateus Rodrigues Sono, Superintendent of Registration, on 03/12/2026, at 14:09, 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 2626014 and the CRC code 881DEBF7.
This document's authenticity can be verified by accessing https://sei.cvm.gov.br/conferir_autenticidade, and typing the "Verification Code" 2626014 and the "CRC Code" 881DEBF7.
Reference: Process No. SRE Circular Letters 2026 SEI Document No. 2626014