Circular Letter CVM/SRE 04/26, of August 18, 2026

SECURITIES AND EXCHANGE COMMISSION OF BRAZIL
Rua Sete de Setembro, 111/2-5th and 23-34th Floors, Center, 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. 4/2026/CVM/SRE Rio de Janeiro, August 18, 2026. Subject: New guidelines on requests for automatic registration of public distribution offers of securities: (i) offers submitted to prior analysis by a self-regulatory entity, in accordance with CVM Resolution No. 160/2022; and (ii) offers by unregistered issuers, in accordance with CVM Resolutions Nos. 160/22 and 232/2025 (FÁCIL Regime).

Dear Director,

1. This Circular Letter contains guidelines to be observed by lead coordinators in public offerings of securities carried out under the automatic registration procedure provided for in art. 26 of CVM Resolution No. 160/2022 ("RCVM 160"), through the SRE System.

2. In particular, this Circular Letter contains guidelines on offers submitted to prior analysis by a self-regulatory entity, in accordance with arts. 94 and 95 of RCVM 160, as well as on new fields made available for offers by unregistered issuers within the scope of CVM Resolution No. 232/2025 ("RCVM 232").

3. The complementary guidelines are presented below.

I. Public offers submitted to prior analysis by a self-regulatory entity

4. The SRE has observed the recurrent occurrence of incorrect selection of requests intended exclusively for offers that have undergone prior analysis by a self-regulatory entity, identified by the suffix "- AR".

5. With the objective of simplifying the list of available requests and reducing the incidence of selection errors, the following requests will be disabled:
   OPD Aut Professional - with bookbuilding - AR; OPD Aut General or Qualified Public - with bookbuilding - AR and OPD Aut General or Qualified Public - without bookbuilding - AR.

6. To replace this functionality, conditional fields will be included in the relationships (request x security), as per the table below:

REQUEST_TYPE SECURITY
OPD Aut Professional - with bookbuilding
Shares
Share deposit certificates (Unit)
Convertible Debentures
OPD Aut General or Qualified Public - with bookbuilding Shares Share deposit certificates (Unit) Real Estate Receivables Certificates FIAGRO Quotas FIDC Quotas FII Quotas Infra Funds Quotas Debentures Convertible Debentures Promissory Notes Other securitization titles OPD Aut General or Qualified Public - without bookbuilding Real Estate Receivables Certificates FIAGRO Quotas FIDC Quotas FII Quotas Infra Funds Quotas Debentures Promissory Notes Other securitization titles

From today until August 24, 2026, adjustments will be made in these relationships, which will henceforth also include offers previously analyzed by self-regulatory entities, with the concomitant disabling of their corresponding counterparts with the suffix "- AR" as the adjustments are carried out.

New parametrized fields

7. In the "Offer Information" tab, the following mandatory completion fields will be created:
   Does the offer have prior analysis by a self-regulatory entity?
   Self-Regulatory Entity
   Process number at the self-regulatory entity

8. If the "Yes" option is selected in the first field, the other fields related to the self-regulatory entity will be displayed, whose completion will be mandatory for the conclusion of the request.

9. If the "No" option is selected, the coordinator may proceed normally with the request, with it being recorded that the offer was not submitted to prior analysis by a self-regulatory entity.

10. It is noted that, in offers submitted to prior analysis by a self-regulatory entity, the document "Report of the self-regulatory entity" remains mandatory for obtaining the registration of the offer, and must be attached in the "Document Submission" tab.

11. Furthermore, we clarify that, regarding requests made before the implementation of this change, no additional measures or adjustments will be necessary.

II. Fields with conditional parametrization in offers by unregistered issuers

12. With the objective of adequately identifying the corporate type of issuers of securities not registered with the CVM and their status as small-cap companies within the scope of CVM Resolution No. 232/2025 ("RCVM 232"), which provides for the Facilitation of Access to Capital and Incentives for Listings Regime (FÁCIL), the requests made available in the SRE System and identified by the expression "- unregistered issuers" will be altered.

13. In this context, the "Corporate Type" field, which is mandatory to complete, will be altered in the "Offer Information" tab. The field has the options "Closed-end SA" and "Limited", which must be chosen according to the corporate type of the issuer. We alert that the "Limited" option is not available in requests for public offerings of debentures, given that the issuance of debentures is an exclusive prerogative of corporations, in accordance with Law No. 6.404/1976.

14. Moreover, the conditional field "Issuer qualifies as a small-cap company?" will be created, which is mandatory to complete, with the options "Yes" or "No". If the chosen "Corporate Type" is "Limited", the conditional field will only present the "No" option, given that the status of small-cap company only applies to corporations, in accordance with art. 2 of RCVM 232.

15. We emphasize that small-cap companies that have registration with the CVM, classified as CMP, must use specific requests for registered issuers, that is, those that do not have the identification "- unregistered issuers".

16. The alterations in the relationships below will begin from today until August 24, 2026:

REQUEST_TYPE SECURITY
OPD Aut Professional - with bookbuilding - Unregistered Issuer Financial Rural Product Certificate Agricultural Credit Rights Certificate Debentures Commercial Notes Promissory Notes Other securitization titles OPD Aut Professional - without bookbuilding - Unregistered Issuer Financial Rural Product Certificate Debentures Commercial Notes Promissory Notes Other securitization titles OPD Aut Qualified - with bookbuilding - Unregistered Issuer Debentures OPD Aut Qualified - without bookbuilding - Unregistered Issuer Debentures

III. Support Contact

17. We reiterate that inquiries related to the SRE System must be sent exclusively to the email address suporte-sistemasre@cvm.gov.br.

18. Only messages sent to this address will be answered, and it is not necessary to send them, in copy, to any other CVM email addresses.

Sincerely,

LUIS MIGUEL R. SONO
Superintendent of Securities Registration

Document electronically signed by Luis Miguel Jacinto Mateus Rodrigues Sono, Superintendent, on 08/18/2026, at 11:37, based on art. 6 of Decree No. 8.539, of October 8 of 2015. The authenticity of the document can be verified at https://sei.cvm.gov.br/conferir_autenticidade, by entering the verification code 2635384 and the CRC code EC4EDB82. The authenticity of this document can be verified by accessing https://sei.cvm.gov.br/conferir_autenticidade, and typing the "Verification Code" 2635384 and the "CRC Code" EC4EDB82. Reference: Process No. SRE Circular Letters 2026 SEI Document No. 2635384