On April 15th and 16th, 2026, the 44th Ordinary Meeting of the Genetic Heritage Management Council (CGEN) took place at the Ministry of Environment and Climate Change in Brasília/DF. The Environmental and Regulatory team from Nascimento e Mourão Sociedade de Advogados was present, represented by partners João Emmanuel Cordeiro Lima and Bianca Oliveira Begossi.
The meeting, which involved representatives from various Ministries, as well as the private sector, the scientific community, and traditional peoples and communities, had as its main discussion topics: (i) updates on international discussions regarding Digital Sequence Information (DSI); (ii) deliberation on the reference lists of associated traditional knowledge (CTA) of identifiable and non-identifiable origin, within the scope of CGEN Resolution No. 47/2025; and (iii) the presentation of the new version of the National System for the Management of Genetic Heritage and Associated Traditional Knowledge (SISGEN).
In the field of DSI (Diversity, Security, and Innovation), the Ministry of Foreign Affairs provided updates on discussions within the Cali Fund Steering Committee, in the context of the Convention on Biological Diversity (CBD). The upcoming meeting of the Subsidiary Body on Implementation (SBI-7), scheduled for August 2026 in Nairobi, Kenya, was particularly highlighted. At this meeting, the draft decision to be submitted to COP-17 is expected to be consolidated. Until then, the definition of Brazil’s position on the Multilateral Benefit-Sharing Mechanism arising from the utilization of DSI, established by Decision 16/2, is expected. This position should be developed with technical support from CGEN (National Council for Genetic Resources Management), through its Sectoral Chambers.
During the meeting, the role that CGEN should play in this discussion, which has traditionally been led by the Ministry of Foreign Affairs, was debated, as well as what type of statement the body would issue, considering the limits of its competence. The representative from the Ministry of Environment and Climate Change indicated that the idea is for the body to function only as a qualified technical forum for debate.
Within the scope of CGen Resolution No. 47/2025, which deals with the reference lists of CTAs (Critical Asset Management), the collegiate body unanimously approved the List of Identified CTA Providers (CTA-IDE). Conversely, the deliberation on the List of CTAs of Unidentifiable Origin (CTA-ONI) was postponed due to a request for review, and the topic is expected to be revisited at the next CGEN meeting, scheduled for June 10th and 11th.
The CTA-IDE List, in its current version, includes 45 different providers and approximately 350 described species and CTAs, available in a tool with a Power BI interface, which will be linked to SISGEN and the official website of the Ministry of Environment. As reinforced by the Ministry of the Environment (MMA) at the meeting, the aforementioned list is not exhaustive and will be periodically updated by the National Genetic Resources Council (CGEN), through deliberation and voting by the council. Any updates will only take effect upon approval, without retroactive application.
Although the CTA-IDE List is not binding and does not alter the legal concept of access to CTA – which is conditional on the purpose of facilitating or enabling access to genetic resources, as per Article 2, item IX, of Law No. 13.123/2015 – the importance of close monitoring of its practical application is reinforced, within the scope of the analysis of specific cases and supervisory activities carried out by the DPG/MMA and the supervisory bodies (IBAMA, Navy Command and MAPA), respectively.
Another highlight of the Meeting was the presentation of SISGEN 3.0, an update to SISGEN that will bring important operational improvements, including the creation of a module for foreign institutions. In this context, the following schedule was presented, which foresees the carrying out of tests with national and foreign users, the receipt of contributions from these users, and the expectation of deliberation for approval of the system at the next CGEN meeting, scheduled for June of this year.
Active participation from the private sector in the testing phase of SISGEN 3.0 is essential for identifying inconsistencies, opportunities for improvement, and necessary adjustments to the system, ensuring its alignment with the reality of users.
Finally, it is worth highlighting that, from the publication of an official act by the Executive Secretariat of CGEN indicating the availability of SISGEN 3.0, foreign entities and other institutions covered by the extension provisions of CGEN Resolution No. 28/2021 will have a period of 1 (one) year to register activities and notify products formulated from access to Brazilian biodiversity during the validity of Law No. 13.123/2015. This deadline will also apply to the signing of Commitment Agreements for the regularization of activities and products developed during the period of validity of Provisional Measure No. 2.186-16/2001.
This material is exclusively institutional and informative in nature, limited to presenting general normative and administrative aspects of the subject.
João Emmanuel Cordeiro Lima | joaoemmanuel@nascimentomourao.adv.br
Senior Partner in the Environmental, Regulatory and Biodiversity Law area.
Bianca Oliveira Begossi | bianca.begossi@nascimentomourao.adv.br
Partner in the Environmental, Regulatory and Biodiversity Law area.
