Published on the Official Gazette of the Federal Executive April 1, 2020, the Brazilian Securities and Exchange Commission Resolution No. 849 (CVM Resolution No. 849) instituted an exceptional regime for the disclosing of periodic information required by CVM due to the pandemic of COVID-19.

Such measures instituted by CVM Resolution No. 849 are in line with Provisional Measure 931/20, which allowed CVM, exceptionally for the fiscal year of 2020, to change the terms established in the Brazilian Corporate Law.

Regarding the measures instituted by CVM Resolution No. 849, we highlight:

• For publicly-held companies whose fiscal year ended between December 31, 2019 and March 31, 2020, the possibility to disclose the Annual Financial Statements within up to 5 (five) months from the end of its respective fiscal year;
• Publicly-held companies may disclose their Annual Report within 6 (six) months after the end of their fiscal year;
• The extension of 45 (forty-five) days for the deadline to prepare and disclose the Quarterly Information Form – ITR – referred to the first quarter of fiscal year of 2020 for companies whose fiscal year ended on December 31, 2019;
• The extension of 2 (two) months for the deadline to disclose the annually updated reference form, as well as to confirm the information on the registration form.
• The extension of 2 (two) months for the deadline to prepare and disclose the Standardized Financial Statements Form – DFP;
• The extension of 2 (two) months for the deadline for disclose the report on the Brazilian Corporate Governance Code; and
• Authorization for investment funds to hold virtual general meetings, either ordinary or extraordinary, regardless of provision in their respective regulations, for all eligible matters during the fiscal year of 2020.

If you have any questions or need more information and clarifications, please contact us:

Jarbas Velloso                Marcel Kim Dib

jv@zancan.com.br         mkd@zancan.com.br