The sanctioning of Law No. 15,506/2026, which establishes the National Policy on Critical and Strategic Minerals (PNMCE) and creates the National Council for the Industrialization of Critical and Strategic Minerals (CIMCE), marks a significant moment for Brazil’s mining sector. Originating from Bill 2,780/2024, the text followed a legislative path we have closely tracked over the past months, from approval in the Chamber of Deputies in May, to the Senate vote in September, to presidential sanction. What stands out along this path is the pace at which a matter of such magnitude advanced through its final stages. This is not about questioning the legitimacy of the process, but about noting that a regulatory framework with this potential impact, for the country, for the industry, and for the coming decades of mineral exploration, would have benefited from even more extended dialogue with the technical and economic agents directly affected by it.
Brazil is once again at a unique juncture: the opportunity to establish itself as a relevant player in the production, supply, and processing of strategic mineral products for the global energy and technological transition. This is a window that does not open often, and the country now has the geological, technical, and business conditions to seize it. But the same legislation capable of enabling this leap could, depending on how it is regulated and put into practice, also squander the opportunity. The difference between one outcome and the other will lie in the next steps, not in the law’s text alone.
The mining sector operates in long cycles, from exploration to feasibility, to licensing, to mining itself, and depends on regulatory predictability to attract and retain risk capital. Any technical weakness in the regulation tends to translate, years later, into legal uncertainty for those who have already invested.
For this reason, we believe the next regulatory measures from CIMCE and the bodies involved should listen to those directly impacted in a structured way: Brazil’s mineral exploration businesses and their research and mining projects. It is worth restating a point often overlooked in public debate: today, the vast majority of mineral exploration projects underway in the country are financed by private capital. This capital assumes the geological risk, invests without any guarantee of return, and fully reports its data and results to Brazil’s National Mining Agency (ANM) at the end of each stage.
This constant flow of information is what makes ANM today’s repository of all the geological knowledge generated by Brazilian mining, a state asset built, in large part, with private investment. Strengthening ANM institutionally is therefore not a matter of choosing between alternatives: it is a precondition for the new national policy to have a data foundation and regulatory capacity equal to its objectives. The law itself preserves the agency’s regulatory and licensing powers even with CIMCE’s creation, a design that makes sense, provided ANM has the resources and structure needed to fully exercise them.
With its broad legal authority, ranging from credentialing priority projects and approving changes of corporate control among mineral rights titleholders, to setting price guidelines and acting as the competent authority within the low-carbon mineral certification system, CIMCE now takes on a concrete and far-reaching responsibility. The speed of the sanction alone does not guarantee the new policy’s success. That will depend on the technical quality, predictability, and willingness to listen with which CIMCE regulates its instruments from here on. That is the standard this moment demands, and one Brazil’s mining sector is ready to help build.
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