When the Brazilian Emissions Trading System begins imposing concrete obligations on regulated companies, the first document required will not be the emissions report — it will be the monitoring plan, the document that describes how the company intends to measure what it will later report. Law No. 15,042/2024 establishes that operators with annual emissions exceeding 10,000 tonnes of carbon dioxide equivalent are required to submit a monitoring plan and an emissions and removals report, while those exceeding 25,000 tonnes are also subject to periodic compliance reconciliation — the stage at which the company must demonstrate that it holds allowances or certificates equivalent to its net emissions. Most of the operational details still depend on secondary regulations currently under development, but the direction is already clear, and it initially affects the sectors that Brazil’s carbon market will regulate before the others.
It is worth distinguishing two things that are often treated as synonymous. An inventory answers, “How much did your company emit last year?” A monitoring plan answers, “How will your company produce that number consistently, year after year, in a way that an independent verifier can check?” It describes the organization’s boundaries, lists each emission source, defines the calculation methodology applied to each one, specifies measurement instruments and data collection frequency, assigns responsibilities, establishes quality controls, and determines what to do when data is missing. Companies that have already structured an emissions inventory have a head start, but they are not fully prepared: the inventory is a result, while the plan is a procedure — and that is why an organized ESG management platform matters more than a well-prepared spreadsheet for a specific year.
This distinction explains the design of the preparatory phase established for the system’s implementation. The proposed sectoral coverage presented by the Extraordinary Secretariat for the Carbon Market provides for a four-year preparatory period for each sector before full obligations take effect, and the first of those years is dedicated specifically to developing the monitoring plan. The following two years involve actual monitoring, while the fourth involves participation in drafting the National Allocation Plan. This is not unnecessary bureaucracy: measuring emissions accurately requires a historical data series, and historical data cannot be produced retroactively. A company that begins monitoring in the year its obligation takes effect reaches its first verification without a baseline for comparison, without consolidated data, and without time to correct any errors.
In practice, the real obstacle is rarely technical — it is organizational. The data required by the monitoring plan almost always already exists within the company, but it is scattered: fleet fuel consumption data is held by maintenance, electricity bills are held by finance, natural gas consumption figures are held by production, waste records are held by the environmental department, and travel data is held by HR. None of these departments has been informed that these figures now form part of a document subject to external verification. Developing the plan largely involves carrying out this internal mapping and turning it into a routine: who collects the data, how often, in what format, and who verifies it.
Defining boundaries is where most mistakes occur, and those mistakes only become apparent during the audit. It is necessary to decide — and justify — whether consolidation follows the operational control or equity share approach, and that choice changes the results for companies with leased facilities, outsourced operations, co-processing activities, or ownership interests in other companies. Is a unit operated by a third party within your site included or excluded? Does an asset in which your company holds a minority stake count proportionally? These are questions that need documented answers in the plan, not improvised decisions when preparing the report.
After defining boundaries comes traceability, which is what separates an approvable plan from one that merely looks good. For each emission source, the verifier will want to know where the activity data came from, which emission factor was applied, its source and version, and how a third party can reproduce the calculation and arrive at the same number. Consumption estimated “based on historical averages” without supporting source documentation, an emission factor taken from an outdated reference version, or a meter without calibration records — these are classic findings that turn verification into rework. The monitoring plan exists precisely to anticipate this scrutiny, not to describe the company’s intention to be sustainable.
There is an additional benefit that often goes unnoticed: the monitoring plan is also a management tool. When a company knows precisely where each tonne of emissions comes from, it begins to see where reductions are inexpensive and where they are costly — information that changes investment decisions, energy contract negotiations, and input specifications. Without this, every discussion about reducing or offsetting emissions takes place in the dark, and any purchase of carbon credits becomes a matter of sizing requirements based on estimates.
Companies outside the sectors included in the first wave will not remain outside the discussion for long. Subsequent waves of the proposed sectoral coverage include mining, the electricity sector, glass, food and beverages, chemicals, ceramics, waste, and, later, road, waterway, and rail transportation. And even before any legal obligation takes effect, pressure often comes through the supply chain: corporate clients with their own targets, banks that assess climate risk when granting credit, and supplier qualification processes already request emissions data from companies that are not yet subject to any regulatory obligation. The monitoring plan addresses both scenarios through the same effort.
Finally, one point deserves caution without alarmism: the law provides for administrative sanctions for failure to comply with the system’s obligations, including fines that may reach a percentage of gross revenue, and the determination of these penalties depends on regulations still under development. As the set of secondary regulations remains under construction, deadlines, formats, and specific requirements should be confirmed on a case-by-case basis with technical and legal support before any investment decision — but this does not change the fact that data collection needs to begin before the final rules are established, because it is the only part of the process that cannot be compressed at the end.
If your company operates in one of the sectors entering the system first, or has simply received its first serious question about emissions from a client or a bank, the initial step is the same: map emission sources, define boundaries, and turn data collection into a documented routine. GETS CARBON structures this process with your team, from mapping emission sources to designing the plan that will support verification. Talk to a GETS CARBON specialist and start developing your monitoring plan while there is still time to do it properly.
