On September 2, 2026, the Senate approved Brazil’s new National Policy for Critical and Strategic Minerals, and the bill (PL 2.780/2024) authored by Deputy Zé Silva now goes to President Lula for sanction who has 15 working days to sanction the bill. The direction of travel is clear: Brazil intends to use its mineral endowment to build more of the value chain domestically, rather than remain primarily an exporter of raw materials. For mining companies, this creates new financing and investment opportunities, but also greater expectations around domestic processing, innovation, traceability and government oversight.
The new framework establishes a national policy and governance structure for critical and strategic minerals and creates instruments aimed at supporting investment across the value chain. These include financial support for domestic processing and transformation, a guarantee mechanism to help de-risk projects, incentives for mineral exploration and research, support for R&D, a national registry of strategic projects and a voluntary low-carbon mineral certification scheme.
The policy is consistent with the broader approach the Lula administration has been developing over the past year: using public financing, industrial policy and international partnerships to help address investment and coordination bottlenecks, while seeking to attract private capital and technology into higher-value activities in Brazil.
The next key watchpoints are presidential sanction and subsequent regulation, particularly the eligibility criteria for minerals, projects, and incentives, as well as how the new governance arrangements will interact with existing institutions such as the National Mining Agency (ANM).
Conclusion
Brazil is moving from custodian of a mineral endowment to architect of a value chain, and the instruments it has chosen, conditional fiscal support, a state guarantee, a qualification registry, and a council with a coordinating mandate, indicate that access will be allocated rather than assumed. Companies that treat this as a fiscal question will find themselves competing for credits already shaped by others. Those that treat it as a governance question will engage during the regulatory phase, build the traceability and processing commitments the framework rewards, and secure position before the criteria harden. Speyside Group's view is that first-mover advantage in Brazil's critical minerals sector will accrue less to whoever holds the best geology than to whoever demonstrates, early and credibly, the execution capacity the state is now underwriting.
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