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2025-12-18 | Resolução CMN 5272

CMN Resolution No. 5,272 — Governs the Investment of Resources of Own Social Security Regimes (RPPSs)

The National Monetary Council issued Resolution No. 5,272 to regulate the investment of resources for Brazil's Own Social Security Regimes (RPPSs), mandating strict adherence to principles of security, liquidity, and transparency. The resolution establishes specific allocation limits across fixed and variable income segments, linking higher investment privileges to institutional governance certification levels. It further requires formal investment policies, rigorous risk management, and the segregation of RPPS assets from federal entity resources to ensure actuarial balance.

Brazil

Banco Central do Brasil

CMN RESOLUTION NO. 5,272, OF DECEMBER 18, 2025

Governs the investment of resources of the own social security regimes – RPPSs.

The Central Bank of Brazil, in accordance with Article 9 of Law No. 4,595, of December 31, 1964, makes it public that the National Monetary Council, in a session held on December 18, 2025, based on Article 6, caput, item IV, and sole paragraph, of Law No. 9,717, of November 27, 1998, and on Article 9, caput and § 7º, of Constitutional Amendment No. 103, of November 12, 2019,

RESOLVES:

Art. 1º The resources of the own social security regimes – RPPSs established by the Union, the States, the Federal District, and the Municipalities, in accordance with Law No. 9,717, of November 27, 1998, must be invested in accordance with the provisions of this Resolution.

§ 1º In the investment of the resources referred to in this Resolution, those responsible for the management of the RPPS must:

I - observe the principles of security, profitability, solvency, liquidity, motivation, adequacy to the nature of their obligations, and transparency;

II - exercise their activities with good faith, loyalty, diligence, timeliness, and prudence;

III - ensure high ethical standards;

IV - adopt rules, procedures, and internal controls aimed at ensuring compliance with their obligations, observing:

a) the current investment policy;

b) the segments, limits, and other requirements provided for in this Resolution;

c) the public nature of the regime's management and the applied resources, and the observance of the principles of security, protection, and financial prudence, provided for in Article 6, sole paragraph, item I, of Law No. 9,717, of November 27, 1998;

d) the protection and financial prudence conditions provided for in Article 43, § 1º, of Complementary Law No. 101, of May 4, 2000; and

e) the parameters established by the Ministry of Social Security in the general norms for the organization and functioning of these regimes, which must consider their segmentation by size, complexity, and level of adherence to best governance practices;

V - diligently carry out the selection, monitoring, and evaluation of contracted service providers;

VI - provided that Article 21, § 2º is observed, carry out prior accreditation, monitoring, and evaluation:

a) of the manager and administrator of the investment funds;

b) of the banking financial institution that will administer the portfolio of securities or whose assets are selected for the investment of resources;

c) of the financial institution authorized to operate by the Central Bank of Brazil, which will be directly responsible for the intermediation of the purchase and sale of assets; and

d) of the custodian; and

VII - identify, analyze, evaluate, control, monitor, and manage the risks, costs, and expected return of investments.

§ 2º To ensure compliance with the principles and guidelines established in this Resolution, those responsible for the management of the RPPS and the other participants in the investment decision-making process must prove professional experience and technical knowledge, in accordance with requirements established in the general norms of these regimes.

§ 3º The parameters for the accreditation provided for in item VI of § 1º must cover, among others:

I - the history and experience of operation;

II - the volume of resources under the management and administration of the institution;

III - the financial solidity;

IV - the exposure to reputational risk;

V - the ethical standard of conduct;

VI - the adherence of profitability to performance indicators; and

VII - the compliance by institutions with the conditions provided for in Article 21, § 2º.

§ 4º Those considered responsible for compliance with the provisions of this Resolution, by action or omission, to the extent of their duties, are:

I - all persons who participate in the analysis, advisory, and decision-making processes within the RPPS, including:

a) members of the board and councils;

b) the person responsible for the management of resource applications and for providing information related to the regime's applications, in the form of § 8º;

c) attorneys with management powers;

d) members of the investment committee; and

e) consultants and other professionals; and

II - agents of the financial market and capital market who participate in the distribution, intermediation, management, and administration of RPPS resources and other service providers contracted by these regimes.

§ 5º The RPPS must formally and clearly define the separation of responsibilities of all agents participating in the analysis, evaluation, management, advisory, and decision-making processes regarding resource application, including the definition of decision-making authority for each instance.

§ 6º The RPPS must maintain a digital record of all documents supporting decision-making in the application of resources.

§ 7º For the purposes of this Resolution:

I - references to investment funds include investment funds, investment funds in fund shares, investment funds in market index – ETF, and all their classes of shares and subclasses, in accordance with the regulation established by the Securities and Exchange Commission (CVM);

II - references to "class" and "share classes" encompass investment funds that issue shares in a single class; and

III - references to "regulation" and "fund regulation" encompass the descriptive annexes of share classes and the appendices of subclasses.

§ 8º The body or entity managing the RPPS must inform the Ministry of Social Security of the person responsible for the management of resource applications and for providing information related to the regime's applications.

§ 9º The applications referred to in the caput encompass the process of investment, management, and divestment of resources.

§ 10. Risk management referred to in item VII of § 1º must:

I - encompass credit, market, liquidity, operational, legal, systemic, and other risks inherent to each operation;

II - use the assessment of a risk rating agency, without prejudice to the necessary risk analysis;

III - consider, in the risk analysis, when deemed material and relevant, aspects related to the economic, environmental, social, and governance sustainability of investments; and

IV - evaluate and provide transparency to the environmental, social, or governance impacts of the RPPS investment portfolio.

CHAPTER I OF THE ALLOCATION OF RESOURCES AND INVESTMENT POLICY

Section I Of the allocation of resources

Art. 2º Subject to the limitations and conditions established in this Resolution, RPPS resources must be allocated in the following application segments:

I - fixed income;

II - variable income;

III - investments abroad;

IV - structured investments;

V - real estate funds; and

VI - payroll-deducted loans.

§ 1º For the purposes of this Resolution, structured investments are considered:

I - shares of classes of investment funds typified as "Multimarket";

II - shares of classes of investment funds in participations – FIP;

III - shares of classes of investment funds typified as "Stocks – Access Market"; and

IV - shares of classes of Investment Funds in the Agroindustrial Productive Chains – Fiagro.

§ 2º RPPSs may only invest resources in classes of investment funds, ETFs, and classes of investment in shares of investment funds registered with the Securities and Exchange Commission (CVM) and whose portfolios observe the requirements, limitations, and conditions established in this Resolution.

§ 3º The bodies or entities managing RPPSs must evaluate and publicize the costs resulting from applications, including those made through investment funds or administered portfolios, and provide:

I - prior obtaining of information regarding the remuneration of all service providers involved in the administration, management, distribution, and custody of invested assets, including the values or percentages actually practiced; and

II - quarterly disclosure, at minimum, to the regime's insured persons and beneficiaries, of expenses with invested assets, including those obtained in the form of item I, and with the hiring of service providers by the regime.

§ 4º Except for rules expressly provided for in this Resolution, the limits of concentration by issuer and by financial asset modality and other criteria defined by the Securities and Exchange Commission (CVM) in specific regulation apply to investment funds.

§ 5º The classes of investment funds and classes of investment in shares of investment funds subject to application by RPPSs must contain a provision in their regulation limiting the liability of the shareholder to the value subscribed by them.

Art. 3º For the purposes of this Resolution, resources are considered:

I - the availability derived from current and capital revenues;

II - other financial inflows earned by the RPPS;

III - financial applications;

IV - titles and securities;

V - assets linked by law to the RPPS; and

VI - other goods, rights, and assets with pension purposes.

§ 1º RPPS resources aim at the constitution of guaranteeing reserves for benefits granted and to be granted by the regime and must be maintained and controlled in a manner segregated from the resources of the federative entity and managed in accordance with the current investment policy and criteria for accreditation of institutions and contracts, independently.

§ 2º To guarantee the segregation referred to in § 1º, RPPS resources must be linked to a body or entity managing the regime or to pension funds with specific registration in the National Registry of Legal Entities (CNPJ).

§ 3º The provisions of this Resolution apply to the resources of the RPPS administration fee and to funds established for the purpose of segregating the mass or for other pension purposes.

§ 4º The injection of goods, rights, and assets referred to in items IV to VI of the caput and the destination, by law, of future revenue flows to the RPPS must:

I - be based on a technical study contained in a transparent process of evaluation and economic-financial feasibility analysis; and

II - observe the provisions of Article 6, §§ 1º and 2º, and the parameters established in the general norms of these regimes.

Section II Of the investment policy

Art. 4º Those responsible for the management of the RPPS, before the fiscal year to which it refers, must define the annual resource application policy in a way that includes, at minimum:

I - the management model to be adopted and, if applicable, the criteria for hiring service providers, based on the provisions of Article 21, § 5º, and Article 24;

II - the strategy for allocating resources among the various application segments and their respective investment portfolios;

III - the profitability parameters pursued, which must seek compatibility with the profile of their obligations, considering the need to seek and maintain financial and actuarial balance and the diversification and concentration limits provided for in this Resolution;

IV - the limits used for investments in titles and securities issued or co-obligated by the same legal entity;

V - the methodology, criteria, and reference sources to be adopted for pricing the assets referred to in Article 3º;

VI - the methodology and criteria to be adopted for the prior analysis of investment risks, as well as guidelines for their control and monitoring;

VII - the methodology and criteria to be adopted for evaluating and monitoring the expected return of investments; and

VIII - the contingency plan, to be applied in the following fiscal year, with the measures to be adopted in case of non-compliance with the limits and requirements provided for in this Resolution and the parameters established in the general norms of RPPSs, excessive exposure to risks, or potential losses of resources.

§ 1º Justifiably, the annual investment policy may be reviewed during its execution, including for the purpose of adaptation to the market or new legislation.

§ 2º The elaboration, revision, and information contained in the investment policy must observe the parameters established in the general norms of RPPSs.

Art. 5º The annual investment policy of RPPS resources and its revisions must be approved by the deliberative council or equivalent body before its implementation.

CHAPTER II OF THE APPLICATION SEGMENTS AND LIMITS

Art. 6º For the purposes of calculating the limits defined in this Resolution, the resource applications referred to in Article 3º, caput, items I, II, III, and IV are considered, excluding the resources referred to in Article 3º, caput, items V and VI, the financial availability maintained in checking accounts, and the shares of classes of real estate investment funds referred to in Article 11, § 3º.

§ 1º The applications and continuity of investments in the assets referred to in Article 3º must observe the compatibility of the invested assets with the terms, amounts, and rates of the present and future actuarial obligations of the RPPS, with the objective of maintaining the economic-financial balance between the regime's assets and liabilities.

§ 2º To guarantee the compatibility referred to in § 1º, those responsible for the management of the RPPS must:

I - maintain formalized internal procedures and controls for the management of liquidity risk of applications so that resources are available on the date of payment of benefits and other obligations of the regime; and

II - monitor the payment flows of assets, ensuring compliance with the terms and amounts of the regime's obligations, in the case of own or administered portfolios.

§ 3º The assets and their respective application limits will be differentiated for RPPSs that prove the adoption of good governance practices in pension management, attested according to the different levels of adherence to the institutional certification program established by the Ministry of Social Security, being:

I - RPPS without a level of adherence to the institutional certification program;

II - RPPS with level I of adherence to the institutional certification program;

III - RPPS with level II of adherence to the institutional certification program;

IV - RPPS with level III of adherence to the institutional certification program; and

V - RPPS with level IV of adherence to the institutional certification program.

§ 4º The institutional certification program referred to in § 3º must include, among other aspects:

I - the continuous improvement of investment management, especially regarding efficiency, security, prudence, diligence, transparency, and governance;

II - the standards recognized in the financial market and in the management of pension resources, aiming at risk mitigation and the promotion of high ethical standards in the conduct of operations;

III - the definition of criteria for analysis, accreditation, resource allocation, and contracts based on technical requirements and independently, as provided for in Article 3º, §§ 1º and 2º;

IV - the efficiency of technical, operational, and control procedures for applications; and

V - the continuous training of the persons referred to in Article 1º, § 4º, item I.

Section I Of the fixed income segment

Art. 7º In the fixed income segment, the application of RPPS resources is subject to the following limits:

I - up to 100% (one hundred percent) in shares of classes of investment funds typified as "Fixed Income", constituted in an open regime, or shares of classes of ETFs, negotiable on stock exchanges, whose regulations determine that their resources be invested exclusively in titles issued by the National Treasury, or committed operations backed by these titles;

II - up to 100% (one hundred percent) in titles issued by the National Treasury, registered in the Special Settlement and Custody System – Selic, acquired in primary offering or on electronic trading platforms, in the form of § 2º, items I and II;

III - up to 100% (one hundred percent) in titles issued by the National Treasury, registered in Selic, acquired, in the form of § 2º, item III, through the intermediation of a financial institution that meets the requirements provided for in Article 21, § 2º, item I;

IV - up to 5% (five percent) directly in committed operations, backed exclusively by titles issued by the National Treasury, registered in Selic;

V - up to 80% (eighty percent) in shares of classes of investment funds typified as "Fixed Income", constituted in an open regime, and shares of classes of fixed income ETFs, negotiable on stock exchanges, both without the suffix "Private Credit";

VI - up to 20% (twenty percent) directly in fixed income financial assets issued with an obligation or co-obligation of banking financial institutions authorized to operate by the Central Bank of Brazil;

VII - up to 20% (twenty percent) in shares of classes of investment funds typified as "Fixed Income" and designated with the suffix "Private Credit", constituted in an open regime;

VIII - up to 20% (twenty percent) in shares of classes of investment funds referred to in Article 3º of Law No. 12,431, of June 24, 2011, or whose net worth is represented by infrastructure debentures provided for in Law No. 14,801, of January 9, 2024; and

IX - up to 20% (twenty percent) in senior subclasses of shares of investment funds in credit rights – FIDC.

§ 1º The application of resources in the assets referred to in this article will observe the levels of adherence of the RPPS to the institutional certification program provided for in Article 6º, § 3º, considering the following application criteria:

I - assets referred to in items I and II of the caput are accessible to all RPPSs, including those that do not prove a level of adherence;

II - assets referred to in items III and IV of the caput are exclusive for RPPSs with level I or higher adherence;

III - assets referred to in items V and VI of the caput are exclusive for RPPSs with level II or higher adherence;

IV - assets referred to in items VII and VIII of the caput are exclusive for RPPSs with level III or higher adherence; and

V - assets referred to in item IX of the caput are exclusive for RPPSs with level IV adherence.

§ 2º Subject to the provisions of Article 22, operations carried out directly by RPPSs in titles issued by the National Treasury must be carried out:

I - on electronic trading platforms administered by institutions authorized to operate by the Central Bank of Brazil or by the Securities and Exchange Commission (CVM), within their respective competencies, that:

a) ensure equal conditions among participants and liquidity of negotiations;

b) allow price formation in a competitive and transparent environment; and

c) enable the registration of offers visible to the market, without prior knowledge of the counterparty, provided that the offer references the prices and rates obtained through the procedures provided for in Article 22 and that at least three institutions accredited by the RPPS in the form of Article 1º, § 1º, item VI, and meeting the requirements provided for in Article 21, § 2º, item I, are enabled;

II - in public offerings of the National Treasury through institutions regularly qualified for these offerings, provided they are accredited by the RPPS in the form of Article 1º, § 1º, item VI, and meet the requirements provided for in Article 21, § 2º, item I; or

III - in the over-the-counter market, through financial institutions regularly qualified to intermediation of operations, provided they are accredited by the RPPS in the form of Article 1º, § 1º, item VI, and meet the requirements provided for in Article 21, § 2º, item I.

§ 3º In the application of RPPS resources in the classes of investment funds referred to in this article, the rights, titles, and securities that compose their portfolios and their respective issuers must be considered, in accordance with the provisions of Article 1º, § 1º, item VII, and § 10, as low credit risk.

§ 4º The direct applications of the RPPS in FIDC are subject to:

I - proving that the investment fund manager has already carried out at least ten public offerings of senior subclasses of FIDC shares closed and fully settled; and

II - that the total applications of RPPSs represent, at most, 50% (fifty percent) of the total shares of the senior subclass of the FIDC share class.

§ 5º The financial assets of private issuers that integrate the portfolios of the classes of investment funds referred to in items V and VII of the caput, not classified as financial assets abroad, according to the regulation of the Securities and Exchange Commission (CVM), must:

I - be issued by a banking financial institution authorized to operate by the Central Bank of Brazil;

II - be issued by publicly held companies, provided they are operational and registered with the Securities and Exchange Commission (CVM);

III - be shares of senior subclasses of investment funds in credit rights classified as low credit risk by a risk rating agency registered with the Securities and Exchange Commission (CVM) or recognized by this autarchy;

IV - be shares of classes of investment funds whose invested assets observe the conditions of items I, II, V, or VI;

V - be issued by securitization companies, provided the titles are public issuance with the establishment of a fiduciary regime provided for in Law No. 14,430, of August 3, 2022; and

VI - be issued by closed companies, through a public offering whose lead coordinator is a financial institution, meeting the requirements provided for in Article 21, § 2º, item I.

§ 6º For the purposes of the investment provided for in item VIII of the caput, the following requirements must be observed cumulatively:

I - the fund regulation must provide for the prohibition of acquiring financial assets abroad;

II - the portfolio manager must have at least five years of proven experience in managing private credit assets and assets under management exceeding R$1,000,000,000.00 (one billion reais) in this segment;

III - the assets comprising the fund's portfolio must be issued by a special purpose company constituted in the form of a joint-stock company, publicly or privately held;

IV - the assets comprising the fund's portfolio must be classified as low credit risk by a risk rating agency registered with the Securities and Exchange Commission (CVM); and

V - the aggregated participation of RPPSs in the fund may not exceed 40% (forty percent) of the acquired share class.

§ 7º In the investments referred to in items VII, VIII, and IX of the caput, RPPSs are subject to a global limit of 35% (thirty-five percent) of the total of their applications.

Section II Of the variable income segment

Art. 8º In the variable income segment, the application of RPPS resources is subject to a global limit of up to 50% (fifty percent) and additionally to the following limits:

I - up to 40% (forty percent) in shares of classes of investment funds typified as "Stocks", constituted in an open regime;

II - up to 40% (forty percent) in shares of classes of stock ETFs, negotiable on stock exchanges;

III - up to 10% (ten percent) in shares of classes of investment funds whose net worth is composed of 67% (sixty-seven percent) or more of Brazilian Depositary Receipts – BDR-Stocks or BDR-ETF of stocks, constituted in an open regime; and

IV - up to 10% (ten percent) in shares of classes of international ETFs, admitted to negotiation on stock exchanges in Brazil, observing the provisions of the Securities and Exchange Commission (CVM) regulation.