Circular Letter CVM/SRE 03/2026

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. 3/2026/CVM/SRE Rio de Janeiro, March 26, 2026. Subject: Supplementary guidelines on filling out registration requests for public offerings of distribution of securities with tax benefits (Law No. 12.431/11 and Law No. 14.801/24).

Dear Director,

1. This Circular Letter contains supplementary guidelines to Circular Letter No. 1/2026/CVM/SRE, issued by the Securities Registration Superintendence (SRE) on 02/26/2026, regarding the procedures to be observed by lead coordinators in public offerings of securities with tax benefits, in accordance with the provisions of Decree No. 11.964 of March 26, 2024 (“Regulation” or “Decree 11.964”), which regulated art. 2 of Law No. 12.431/2011 and Law No. 14.801/2024, which in turn establish the securities that count with tax benefits when they are the subject of a public offering.

2. Since the publication of Circular Letter No. 1/2026/CVM/SRE, the SRE has received inquiries containing doubts regarding the filling out of the new parametrized fields, which we will seek to clarify in this Circular Letter.

3. Furthermore, new parametrized fields have been included to address cases where an offering component (series of debentures or CRI and sub-class of FIDC) is associated with more than one investment project.

4. Finally, new parametrized fields have been included in the registration requests for public offerings of shares of Investment Funds in Participations to reflect the tax benefit existing in the issuance of shares of FIP in Infrastructure (FIP-IE) and shares of FIP in Intensive Economic Production in Research, Development and Innovation (FIP-PD&I).

5. The supplementary guidelines are presented below.

I. Public offerings associated with investment projects that are not associated with a single pair of geographic coordinates

6. For the purposes of filling out the SRE System, whenever the investment project is not associated with a single pair of geographic coordinates capable of fully representing the enterprise (examples: telecommunications towers, highways, rails, etc.), we advise the lead coordinator to inform the pair of coordinates associated with the point they consider most representative of the project.

7. In case of doubts and for standardization purposes, the starting point of the enterprise can be used as a reference.

II. Additional parametrized fields included in the SRE System in Debenture, CRI and FIDC offerings, to handle cases where the offering component is associated with more than one investment project.

8. The fields listed in sections II and III of Circular Letter No. 1/2026/CVM/SRE, must be filled out with the information of the main investment project associated with the offering component (series of debentures or CRI and sub-class of FIDC).

9. If the offering component is associated with more than one investment project, the information regarding the other investment projects must be provided in the new parametrized fields below:

10. New fields of information requested by the SRE System (all fields, when requested, are mandatory for submission of the request):

a) Is the offering component associated with more than one investment project?
[answer "yes" if the offering component is associated with more than one investment project];

b) Information regarding other investment projects associated with the offer [this field is only available in case of answer "yes" in the previous field; in the field, information regarding authorizing ordinances, if they exist, or protocol numbers of the investment projects in the sectoral ministries, sector and subsector of the investment projects, object of the investment projects, geographic coordinates of the investment project [longitude and latitude]

11. Documents requested by the SRE System:

a) Proof of project protocol at the Sectoral Ministry if title with tax benefit [this document is mandatory for submission and is only requested in case of answer "no" in the field 'Does the project foresee an authorizing ordinance or are public services the property of subnational entities?'. Proof of protocols must be sent for all investment projects associated with the offer]

III. Registration request in offerings of Investment Funds in Participations (FIP-IE and FIP-PD&I - Law No. 11.478/07)

12. The registration requests for offerings of FIP shares have been adjusted to enable the identification of offerings of shares of Investment Fund in Participations in Infrastructure (FIP-IE) or shares of Investment Fund in Participation in Intensive Economic Production in Research, Development and Innovation (FIP-PD&I).

13. FIP-IE and FIP-PD&I are investment funds in participations established by Law No. 14.708/07 and regulated in accordance with article 16 of Annex IV of CVM Resolution No. 175/2022.

14. Fields of information requested by the SRE System (all fields, when requested, are mandatory for submission of the request):

a) Fund classified as Infrastructure or R&D? [answer "yes" if the fund is classified as FIP-IE or FIP-PD&I; answer no in other cases];

b) Does the offer include a tax benefit? [this field is only available in case of answer "yes" in the previous field; the only option available is "yes"]

c) Type of tax benefit [this field is only available in case of answer "yes" in field 'a)' above; the only option available is "Law 11.478/07"]

IV. Final Provisions

15. We alert about the importance of the completeness and correct filling out of the information related to the tax benefit requested by the SRE System, in accordance with this Circular Letter, for the adequate supervision and monitoring of public policy by the competent bodies (Secretariat of Economic Reforms of the Ministry of Finance and Special Secretariat of the Federal Revenue of Brazil of the Ministry of Finance). Incorrect or incomplete information may lead these bodies to consider the offerings not covered by the respective legal provisions and understand that the tax benefit does not apply to the concrete case, which may cause consequences for the issuers.

16. This Circular Letter complements Circular Letter No. 1/2026/CVM/SRE of 02/26/2026.

V. Support Contact

17. We reiterate the guidance that inquiries regarding the SRE - Offering Registration System should be directed exclusively to the email suporte-sistemasre@cvm.gov.br. Only electronic messages directed to such address 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

Document electronically signed by Luis Miguel Jacinto Mateus Rodrigues Sono, Superintendent of Registration, on 03/26/2026, at 16:34, 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 2632939 and the CRC code B1F6521C.
This document's authenticity can be verified by accessing https://sei.cvm.gov.br/conferir_autenticidade, and typing the "Verification Code" 2632939 and the "CRC Code" B1F6521C.
Reference: Process No. SRE Circular Letters 2026 SEI Document No. 2632939