CLEAN MATRIX PARADOX: REGULATORY GAPS IN THE SBCE AND CONDITIONS FOR MONETIZING DECARBONIZATION IN BRAZIL
Brazilian Emissions Trading System(SBCE); carbon credits; decarbonization; green finance; measurement, reporting and verification(MRV).
Law No. 15,042/2024 establishes the Brazilian Emissions Trading System (SBCE), but its effectiveness depends on a coherent set of implementing rules, such as bylaws, ministerial ordinances, MRV methodologies and registry rules, which are not yet fully defined. Rather than directly proposing the full content of these instruments, this research aims to assess which regulatory and operational elements are necessary for the future regulation of the SBCE to succeed in terms of environmental integrity, price predictability and monetization capacity. The diagnosis is organized in seven analytical modules of the system, but the study focuses on the interface between market design (Modules 2, 3 and 4, which cover the cap, allocation, auctions and secondary market) and integrity and data (Modules 5 and 6, which address sectoral MRV and the registry). These modules are treated as interdependent layers, in which MRV and the registry operate as prerequisites for the safe functioning of the market for allowances and credits. Methodologically, the research combines documental and legal analysis of Law No. 15,042/2024 with international experiences in emissions trading, and organizes the identified requirements into a normative chain that runs from constitutional principles and climate policy objectives to bylaws, technical standards, market standards and operational procedures. Based on this structure, the study develops a gap matrix and a sequencing plan for the adoption of rules, indicating which regulatory decisions are critical to enable the implementation of the SBCE with high integrity and alignment to green finance requirements.