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First Meeting of the National Council for Mineral Policy

The first meeting of the National Council for Mineral Policy (CNPM) took place on October 16, 2025, in Brasília, at the headquarters of the Ministry of Mines and Energy (MME), with the presence of the President of the Republic, Luiz Inácio Lula da Silva.

The CNPM is a strategic advisory body directly linked to the Presidency of the Republic, with an interministerial composition. Its role is to define long-term guidelines for Brazil’s mineral policy, focusing on governance, sustainability, and integration with the country’s economic, social, environmental, and strategic development policies. At its inaugural meeting, the CNPM approved the priorities of Brazil’s Mineral Policy, which aim, in an integrated manner, to:

(a) promote a more sustainable mining sector aligned with current legislation and define the foundations for the preparation of the National Mining Plan 2050 (PNM-2050) and a Sectoral Goals and Actions Plan; and

(b) foster the responsible use of mineral resources through improved governance, transparency, incentives for domestic value addition, advances in geological knowledge, and more efficient collection of the Financial Compensation for the Exploitation of Mineral Resources (CFEM).

Additionally, the CNPM approved its Internal Rules and the creation of four Working Groups (WGs) focused on immediate action:

WG on Critical and Strategic Minerals: tasked with developing policies for minerals essential to the energy transition and the value chains of beneficiation and industrialization in Brazil.


WG on Mining Fees, Charges, and Incentives: responsible for reviewing inspection fees, sectoral charges, and incentive mechanisms for mineral resource utilization, with the aim of creating a fairer, more predictable, and efficient regulatory environment and avoiding the retention of non-productive areas.

WG on Sustainable Development in Mining: aimed at integrating mining with environmental, territorial, and social policies, promoting socioeconomic growth, landuse planning, and responsible land management.

WG for Diagnostic Study on Mining Oversight: focused on identifying competencies, gaps, and improvement proposals for the National Mining Agency (ANM) and its coordination with states and municipalities.

This meeting marks the establishment of a long-term, interministerial governance model for Brazil’s mineral sector, emphasizing issues such as critical minerals, the energy transition, national sovereignty, environmental sustainability, and regulatory modernization—key elements of an adequate mineral policy. However, while the initiative signals renewed strategic coordination, more concrete actions will be needed before its effectiveness and short-term impact can be meaningfully assessed.

ANM Resolution No. 220/2025—New Framework for Mining Dam Safety

Published on October 17, 2025, ANM Resolution No. 220 consolidates and updates the rules on mining dam safety, repealing Resolutions No. 95/2022, 130/2023, and 175/2024. The new regulation strengthens technical requirements, enhances digital monitoring through the SIGBM system, and standardizes criteria for classification by Potential Associated Damage (DPA) and Risk Category (CRI), in alignment with CNRH Resolution No. 241/2024.

Key innovations include changes to dam classification in emergency scenarios, revised methods for calculating DPA and CRI, adjustments to the frequency of certain obligations, and new provisions regarding flood maps.

The regulation provides for a phased transition: part of its obligations will come into effect in April 2027, with full enforcement by August 2027.

However, a sensitive issue arises concerning the treatment of “structures and equipment associated with the dam” located within the self-rescue zone (ZAS). The resolution expressly excludes mining, beneficiation, and waste-disposal areas from this definition, which could imply the removal of workers from these zones—raising significant legal and operational uncertainties.

ANM Resolution No. 223/2025—Significant Changes to the Sanctions Regime

On October 24, 2025, the National Mining Agency (ANM) published Resolution No. 223/2025, which sets out new procedures, parameters, and values for the application of administrative sanctions in Brazil’s mining sector, replacing Resolution No. 122/2022.

The new regulation emerges in a context of strengthened regulatory enforcement by ANM and growing public demand for stricter oversight, particularly considering dam-related tragedies and the impacts of illegal mining. Resolution No. 223/2025 seeks to enhance the technical consistency of penalties, establishing a calculation model more aligned with the severity of infractions and the economic capacity of offenders.

Like its predecessor, the resolution maintains the division of infractions into groups and the creation of severity ranges. The calculation of monetary fines continues to consider factors such as the stage of the mining activity, production value, damage extent, and recurrence of the infraction. For infractions in Groups III to VIII, fines will now be determined using two alternative methodologies—both based on the offender’s economic capacity—though the exact formulas to be used by ANM are yet to be disclosed. The resolution also requires that administrative decisions imposing fines present the values calculated under both methodologies, applying the lesser of the two.

The most notable impact of the new framework, which will take effect on November 23, 2025, is the substantial increase in fine amounts. In serious cases—especially those involving dam safety or environmental damage—penalties may now reach unprecedented levels, with a ceiling of up to BRL 1 billion. This escalation reflects ANM’s clear intent to strengthen the deterrent nature of sanctions and bring Brazil’s regime closer to international standards of regulatory enforcement.

For mining companies, Resolution No. 223/2025 necessitates an immediate review of compliance and regulatorygovernance programs, emphasizing infraction prevention and rapid response to administrative actions. The measure marks a new era of rigor and accountability in Brazil’s mining sector.

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