The volume of cases handled by the Securities and Exchange Commission ( CVM ) has not kept pace with the growth in the number of investigations opened by the agency responsible for overseeing and developing the capital market.

In 2025, the CVM (Brazilian Securities and Exchange Commission) initiated 95 administrative sanctioning proceedings (PAS), a 25% increase compared to the previous year. However, the board only judged 49 cases, a 48% decrease compared to 2024.

Administrative sanctioning processes are the final stage of the CVM investigation, initiated when the technical area believes there is sufficient evidence to formulate a formal accusation against market participants, ranging from asset managers and funds to individuals and consultants.

Data released in the CVM's annual report on Thursday, April 9, also indicates a drop in revenue from settlement agreements – a mechanism by which defendants propose to pay a sum to end the process before trial.

In the year, revenue collected through commitment agreements totaled R$ 33.4 million, compared to R$ 64.9 million in 2024. In 2025, the board approved 42 commitment agreements, 9 fewer than the previous year.

With fewer cases judged, the number of sanctioned agents [individuals or institutions that committed irregularities in the Brazilian capital market and were punished after administrative proceedings] plummeted from 176 to 65. The largest drop occurred in fines, which fell from 153 to 45, while bans on market agents remained stable at 12.

The total number of sanctioned individuals is the lowest since 2021, when 111 were recorded. The highest number in the last six years (latest available data) occurred in 2022, with 222 sanctioned individuals.

Although the data may suggest a possible prioritization of more serious cases due to the agency's limited resources , with fewer fines issued, the amount received by the CVM (Brazilian Securities and Exchange Commission) fell by half, from approximately R$ 1 billion in 2024 to R$ 511 million last year.

Although lower than the previous year, the amounts collected by the CVM (Brazilian Securities and Exchange Commission) from fines and settlement agreements still far exceed the funds allocated to the agency's operations.

Fewer resources and directors

Although it had a projected budget of R$ 938.44 million in 2025, only R$ 268.06 million was committed and R$ 222.87 million was actually paid, according to data from the Transparency Portal.

The figures are even lower than those achieved in 2024, when expenses paid by the CVM totaled R$ 274.06 million and committed expenses totaled R$ 314.76 million.

The drop in resources allocated to the CVM (Brazilian Securities and Exchange Commission) occurs even amidst a record number of regulated participants. At the end of 2025, there were 92,818 participants under the supervision of the regulatory body, 3.4% more than the previous year.

Securities issuances, also overseen by the CVM, totaled R$ 980.9 billion. The highlight of last year was the jump from R$ 12.6 billion to R$ 48.6 billion in the volume of issuances of Real Estate Receivables Certificates (CRIs) — a category that, due to its more complex structures, different types of guarantees, and specific rules, tends to require a higher level of supervision .

In addition to budgetary constraints, the CVM also faced institutional instability throughout the period. In 2025, months before the Master case came to light, the then president of the agency, João Pedro Nascimento, left office two years before the end of his term.

Since then, the leadership of the CVM has been exercised on an interim basis, in a scenario of depleted membership. Since the beginning of the year, only two of the five seats have been occupied.

Although President Luiz Inácio Lula da Silva nominated Otto Lobo to the committee, his nomination, which requires Senate approval, remains blocked by the Senate president, Davi Alcolumbre.

Amid this scenario, market participants have criticized the CVM's actions in recent cases involving operations linked to Banco Master, as detailed in a NeoFeed report .