Investment Funds

Regulatory Developments and the EcoInvest Brasil Program

The Brazilian investment fund market, in particular the real estate fund (FII) category, is currently undergoing a period of maturation that highlights both its potential and the challenges that continue to constrain its growth. Despite a diverse range of funds and an expanding investor base, certain regulatory barriers remain obstacles to further development, even for listed, highly liquid vehicles. High quorum requirements, restrictions on reorganizations, and dissenting shareholders’ rights to seek reimbursement have all hampered consolidation efforts.

The successive rounds of the EcoInvest Brasil program – a federal blended finance initiative that channels private capital toward green transition projects in Brazil – have significantly boosted climate-focused capital flows by strengthening financing and investment mechanisms, as well as attracting new investor profiles to sustainability projects. An upcoming third round is expected to direct the incentives mainly through Private Equity Investment Funds (FIPs) established under CVM Resolution No. 175/2022, with the goal of expanding liquidity and diversifying the instruments available to finance the country’s ecological transformation.

The entry of private equity managers into the EcoInvest Brasil ecosystem marks a significant step in the program’s evolution, combining catalytic capital with investment and management discipline. These managers typically help to structure and professionalize projects, with a focus on operational efficiency, scalability, and clear exit strategies. Additionally, the program’s currency-hedging mechanism is designed to reduce international investors’ exposure to the volatility of the Brazilian real, improving financial predictability and strengthening Brazil’s competitiveness in attracting global climate capital

Ana Carolina Nomura

Partner – Asset Management Services & Investment Funds

In 2026, we expect to see reforms to the regulation of real estate and private equity funds, including updates to CVM resolution No. 175. For real estate funds, we anticipate rule changes to facilitate industry consolidation, such as lower quorum requirements at meetings. For private equity funds, greater flexibility is planned with respect to investments in limited liability companies, as is the use of leverage through debt instruments, and adjustments to influence requirements in portfolio companies, opening the door for certain private equity and venture capital transactions