New Environmental Licensing Law Redefines Rules for Projects Across Brazil

Brazil’s new General Environmental Licensing Law (No. 15,190/2025) establishes nationwide rules for licensing activities or enterprises that use natural resources, pose pollution risks, or may cause environmental degradation. The law regulates Article 225 of the Constitution and amends key frameworks, including the Environmental Crimes Law (9,605/1998), the National System of Protected Areas (9,985/2000), and the National Environmental Policy (6,938/1981). It was published in a special edition of the federal register and enters into force with 63 presidential vetoes.

The text originates from Bill 2,159/2021, approved in the Senate in May (by 54 votes to 13) and in the Chamber in July, after nearly two decades of debate.

The government framed the sanctioning of the law as a step toward “predictability” and “reduced legal uncertainty”. International organisations and civil society groups, however, issued sharp warnings about potential setbacks for human rights and climate safeguards. That tension helps explain the unusually high number of vetoes.

In parallel, the executive branch published a set of complementary measures on special licensing procedures — a sign of the administration’s attempt to fine-tune the new framework immediately after its approval.

What changes in practice

1) A national framework with room for local execution.

The law creates a unified national system for environmental licensing, applicable to federal, state and municipal levels, aligned with Complementary Law 140/2011. It sets general principles but leaves regulatory autonomy to local authorities, allowing adaptation to regional contexts and institutional capacity. In practice, the shift may reduce disparities between licensing agencies — but success will depend heavily on the technical and technological infrastructure available across the National Environmental System (SISNAMA).

2) New categories and procedures.

The legislation reorganises licensing modalities — including the LAC (Licence by Adhesion and Commitment) and the single-stage LAU — and introduces streamlined, digital mechanisms for lower-impact projects. Large or high-risk projects will still require environmental impact assessments (EIA/RIMA). Critics argue that the new regime leans too heavily on self-declaration and risks weakening safeguards. Supporters frame it as necessary bureaucracy reduction tied to stronger accountability for companies and consultants.

3) Changes to core environmental laws.

Amendments to Laws 9,605/1998, 9,985/2000 and 6,938/1981 reshape the relationship between licensing, protected areas and liability. This is a systemic overhaul with implications for public policy, environmental governance and the definition of technical criteria.

4) Vetoes as a safety valve.

The 63 vetoes eliminated provisions that, according to the Presidency, could have weakened key safeguards — such as broader exemptions in sensitive areas. Congress may override some of these vetoes, altering the law’s balance.

5) Narrative disputes and legal battles ahead.

Reports from press and multilateral bodies anticipate lawsuits and disputes over the scope of exemptions, the role of participating agencies and consultation standards. Companies should expect a transition phase marked by scrutiny and interpretative conflict.

Three numbers that reveal the scale of the change

• 63 presidential vetoes — signalling intense political negotiation and concern over controversial provisions.

• 54 to 13 — the Senate vote that revived the bill after years of stalemate.

• Two decades of debate — reflecting the difficulty of reconciling speed with robust environmental protections.

  
  

What it means for project developers and environmental service providers

For developers

• Precise classification will be decisive. 

  Correctly determining the project’s size, location and pollution potential will shape which licensing pathway applies — and how vulnerable it becomes to legal disputes.

• Regulatory risk management becomes central. 

  Greater predictability in deadlines may come alongside heightened legal and social scrutiny, especially in protected or sensitive areas.

• Tracking environmental conditions becomes more demanding. 

  New norms will require stronger compliance systems, independent audits and transparent reporting.

  
  

For the environmental services sector

• Increased demand for legal-technical assessments, due diligence and licensing support for M&A and project finance.

• More robust EIAs where simplified licences do not apply, with expanded studies on fauna, flora, climate and risk.

• More sensitive interaction with protected areas, requiring spatial planning and early institutional dialogue.

  
  

Where Green Forest operates — and how it can reduce risks and unlock projects

1) Pre-project screening and licensing strategy

Regulatory analysis, classification of licensing modality, sensitivity assessment (protected areas, Indigenous lands, riparian zones) and licensing roadmaps.

2) Impact studies and management of conditions

Strengthened EIAs, mitigation plans, socio-environmental programmes and full monitoring systems for licence conditions.

3) LAC structuring with strong governance

Where applicable, Green Forest designs LAC procedures with internal controls, audit trails and digital monitoring to reduce future vulnerabilities.

4) Due diligence for finance and M&A

Assessment of project portfolios under the prism of the new law, including exposure to judicialisation and environmental liabilities.

5) Institutional dialogue and transparency

Stakeholder engagement plans, strengthened accountability routines and ESG-aligned disclosure.

What to watch in the coming months

• Federal, state and municipal regulations defining which activities qualify for streamlined pathways, criteria for studies and consultation procedures — all of which may reshape implementation.

• Congressional voting on vetoes, which could reinstate sensitive provisions.

• Provisional measures and complementary bills targeting special licensing regimes.

  
  

In conclusion

Law No. 15,190/2025 inaugurates a new era: greater predictability for developers, and greater responsibility for those who design, execute and audit projects. Between promises of speed and risks of controversy, outcomes will depend on planning, technical rigour and governance.

For organisations needing to navigate the new landscape, Green Forest – Environmental Projects and Services offers full licensing strategy development — from initial screening to due diligence.

A free initial diagnostic is available for enterprises seeking support in adapting to Brazil’s new environmental licensing framework.

Referências

• Lei nº 15.190, de 8 de agosto de 2025 – “Dispõe sobre o licenciamento ambiental…”. Texto oficial (Planalto). (Planalto)

• Portal da Câmara dos Deputados – Página da Lei nº 15.190/2025 com ementa e alterações legais. (Portal da Câmara dos Deputados)

• Mayer Brown – “Brazil’s General Environmental Licensing Act: new provisions, presidential vetoes, provisional measure and new bill.” (análise dos 63 vetos e medidas correlatas). (Mayer Brown)

• Governo Federal – Planalto – Nota sobre sanção com vetos e justificativas de equilíbrio/segurança jurídica. (Serviços e Informações do Brasil)

• Senado Federal – Aprovação do PL 2.159/2021 (54×13). (Senado Federal)

• Agência Brasil / Reuters / The Guardian / Le Monde – Cobertura jornalística da tramitação e críticas de especialistas e ONGs. (Agência Brasil)

• OHCHR (ONU) – Alerta de especialistas sobre potenciais retrocessos e riscos a direitos humanos na proposta. (ACNUDH)