Anti‑Corruption and Integrity Outlook 2026: Brazil
Table of contents
The Integrity and Anti-Corruption Plan 2025-2027 represents Brazil’s main strategic and operational framework for preventing and combating corruption, within a broader set of integrity and anti-corruption policies. Adopted by the President’s Office and the Inter-Ministerial Anti-Corruption Committee, the Plan is structured around five thematic areas, each comprising strategic objectives aimed at mitigating public integrity risks.
The Office of the Comptroller General of the Union (CGU) is responsible for coordinating the implementation, monitoring, reporting, and evaluation of the strategy’s Action Plan. Oversight of conflict-of-interest prevention and compliance is entrusted to the Public Ethics Commission and the CGU, with the Commission supervising cases involving senior public officials and the CGU overseeing compliance for all other officials.
The management of the Open Data Policy of the Federal Executive Branch is coordinated by the Office of the Comptroller General of the Union, through the National Open Data Infrastructure, while the Joint Information Reassessment Commission serves as the supervisory body for public information issues. Oversight of political parties and electoral campaigns is conducted by the Superior Electoral Court.
Lobbying is partially regulated by Decree No. 10,889 of 2021 requires the disclosure of public officials’ agendas and meetings with the private sector, with monitoring carried out by the CGU and the Public Ethics Commission.
Judicial independence is guaranteed by the Constitution and Complementary Law No. 35/1979 and the National Council of Justice (CNJ) is the central administrative and oversight body for the judiciary. Procedures for the selection, appointment, and promotion of ordinary prosecutors are established in the Constitution, Law 8.625/1993, Law 75/1993, and CNMP Recommendation 108/2024. The main elements of the disciplinary process are outlined in Law 8.112/90 and the centralised disciplinary system of the federal executive branch is the Sistema de Correição do Poder Executivo Federal (SISCOR), which includes the General Inspectorate for Administrative Discipline (Corregedoria-Geral da União, CRG) as its central body and the correction units of the organs and entities that are responsible for correction activities.
Note: 2025 and 2020 data or latest year available.
Source: OECD Public Integrity Indicators Database (data extracted on 7 March 2026).
Data on where Brazil’s integrity system is strongest and could be most improved can be found at the link below:
Note: 2025 data or latest year available.
Source: OECD Public Integrity Indicators Database (data extracted on 7 March 2026).
Brazil fulfils 47% of criteria on the strength of strategic framework, and 53% on practice, compared to the OECD average of 38% and 32%, respectively.
The Integrity and Anti-Corruption Plan 2025-2027, adopted in 2024 by the President’s Office and the Inter-Ministerial Anti-Corruption Committee, sets out strategic actions to promote integrity and combat corruption in the federal public administration.
The Plan was developed through extensive inter-institutional and public consultation processes, involving 53 federal bodies, 30 civil society representatives, 50 academic experts, and around 100 companies, including roundtables and public debates. It is organised around five thematic axes: Quality Control of Public Resource Use, Integrity in State-Private Sector Relations, Transparency and Open Government, Anti-Corruption Efforts, and Institutional Strengthening for Integrity.
The strategy includes an Action Plan that translates its objectives into 260 concrete actions, with a lead organisation identified for each activity. Despite this comprehensive set of actions, the Plan lacks outcome-level indicators and baseline targets to assess impact over time, as well as a thorough situational analysis of existing public integrity risks. Moreover, no recent inter-institutional report provides a comprehensive assessment of public integrity risks or establishes system-wide priorities. The plan is not based on a complete risk assessment and does not draw on relevant data sources, including employee, household, or business surveys. Monitoring, reporting, and evaluation follow a four-stage process involving the CGU, the Council for Transparency, Integrity, and Anti-Corruption (CTICC), and the Interministerial Committee for Combating Corruption (CICC). The CTICC has conducted consultations with relevant state administration bodies, the general public, and civil society organisations to discuss the monitoring results.
Note: 2025 data or latest year available.
Source: OECD Public Integrity Indicators Database (data extracted on 7 March 2026).
Brazil fulfils 40% of criteria on lobbying regulations, and 33% on practice, compared to the OECD average of 43% and 38%, respectively.
Lobbying in Brazil is partially regulated in the executive branch through Decree No. 10,889 of 2021 (regulating item VI of art. 5 and art. 11 of the Law 12.813/2013 on conflict of interest), which defines interest representatives and what constitutes a representation of private interests. It mandates the disclosure of meetings between certain categories of public officials in the executive branch and private sector representatives. The Decree also created the Electronic System of Agendas of the Federal Executive Branch (“E-Agendas Portal”), which provides information on meetings between public officials and interest representatives, including the type of meeting, participants, date, location, and topic of discussion. The Portal also contains information on public officials' participation in political-electoral events, as well as the receipt of gifts, hospitalities and other benefits from persons outside government.
However, the portal does not allow users to sort entries by interest representative, company, organisation, domain of intervention, or targeted legislation. It also lacks details on the specific interests pursued and the legislative or regulatory initiatives concerned. As disclosures are made by public officials rather than lobbyists, the system also does not capture information on lobbying expenditures or other influence activities conducted beyond formal meetings.
While the E-Agendas system is publicly accessible, no code of conduct regulates interactions between public officials and interest representatives. The current framework also lacks cooling-off periods for former officials acting as lobbyists. A comprehensive beneficial ownership register is not in place.
Note: 2025 data or latest year available.
Source: OECD Public Integrity Indicators Database (data extracted on 7 March 2026).
Brazil fulfils 100% of criteria on conflict-of-interest regulations, and 0% on practice, compared to the OECD average of 80% and 45%, respectively.
Regulations define incompatibilities between public office and other activities, specify situations and relationships that may create conflicts of interest, and establish an obligation for officials to manage them. Public officials are responsible for preventing and managing conflicts of interest.
Law No. 12,813/2013 establishes that the Public Ethics Committee (for senior public officials) and the Office of the Comptroller General of the Union (for all other public officials), provide support by issuing norms, procedures, and mechanisms, offering guidance to public officials on questions and concerns, and analysing potential conflict-of-interest situations. Senior officials can request guidance through the Public Ethics Committee’s Sistema Eletrônico de Informações da Presidência da República (SEI-PR), while all other officials use the CGU’s Electronic System for Conflict-of-Interest Prevention (SeCI). Under Decree No. 10,571/2020, the CGU manages the Electronic System of Asset and Conflict of Interest Information, verifies interest declarations, and can initiate investigations, while the Public Ethics Committee uses the analyses to support proceedings in the case of senior public officials.
Members of government, parliament, senior judiciary bodies, high-risk officials, and newly appointed or reappointed top-tier civil servants must submit an interest declaration upon taking office, whenever their position changes or is renewed, on an annual basis, and upon leaving public office. The regulatory framework also specifies sanctions for violations, which range from fines to dismissal.
However, in practice, submission compliance is weakly monitored – though confidentially; there is no data available confirming that authorities have issued recommendations or applied sanctions.
Note: 2025 data or latest year available.
Source: OECD Public Integrity Indicators Database (data extracted on 7 March 2026).
Brazil fulfils 100% of criteria on political finance regulations, and 29% on practice, compared to the OECD average of 76% and 58%, respectively.
Law No. 9,504 bans contributions from foreign states, enterprises, and publicly owned companies, sets spending ceilings for parties, candidates, and third parties, and establishes reporting obligations for campaign funding and expenses. The law also prohibits the use of public resources to favour or oppose any party, limits personal contributions to candidates’ campaigns, and requires parties to make financial reports public, including all contributions above a fixed ceiling.
A comprehensive framework regulates political finance and election campaigns, holding candidates personally liable for violations and defining sanctions proportionate to the severity of offences. Oversight of political parties and campaigns is entrusted to the Electoral Court.
In practice, only 47% of political parties have submitted annual accounts over the past five years, and 67.8% have submitted election-related accounts within the deadlines set by national legislation for the past two election cycles. Moreover, not all parties have made their financial reports publicly available.
Note: 2025 data or latest year available.
Source: OECD Public Integrity Indicators Database (data extracted on 7 March 2026).
Brazil fulfils 78% of criteria on public information regulations, and 62% on practice, compared to the OECD average of 72% and 62%, respectively.
The Joint Information Reassessment Commission serves as the supervisory body for public information, while the Office of the Comptroller General supports the Ministry of Economy in implementing the Open Data Policy through the National Open Data Infrastructure (INDA). However, as the Commission is composed of executive members (Ministers), its decisions could potentially be overturned by other executive bodies.
Law No. 12,527 establishes that all public institutions and private persons performing public functions are holders of public information, and that everyone, including non-citizens and legal entities, has the right to access information in all available forms. The law sets statutory deadlines for processing requests, requires information to be provided in the requested format, and defines valid grounds for withholding information. However, information is not always provided free of charge.
In practice, Brazil proactively discloses a wide range of information online, including consolidated primary legislation, the state budget, public tenders and awarded contracts, and Ministers’ agendas. By contrast, sensitive categories- such as salaries of senior civil servants, asset and interest declarations of top-tier public officials, members of the judiciary, elected officials, and company or land registries- are not made publicly available.
Note: 2025 data or latest year available.
Source: OECD Public Integrity Indicators Database (data extracted on 7 March 2026).
Brazil fulfils 59% of the criteria on judicial integrity regulations, and 28% on practice, compared to the OECD average of 66% and 45%, respectively.
Judicial independence is guaranteed by the Constitution and Complementary Law No. 35/1979, which provide judges with life tenure and protection against arbitrary removal. Judges may be dismissed only as a disciplinary sanction for serious misconduct, negligence, or conduct incompatible with judicial office, while Federal Supreme Court (STF) judges can be removed exclusively through impeachment before the Senate under Law No. 1.079/1950. Judges are recruited through competitive examinations organised by the National Council of Justice (CNJ), an independent body, which also sets criteria for merit-based promotions. Ordinary judges follow these procedures, including performance evaluations, as established by the Constitution, Law No. 35/1979, and CNJ Resolution No. 106/2010. However, these procedures do not apply to all appointments: STF and Superior Court of Justice (STJ) judges are appointed by the President and approved by the Senate based on legal knowledge and reputation. Appeals are available under CNJ Resolutions No. 75/2009 and 106/2010 for competitive entry and promotions, but no appeal mechanism exists for presidential appointments under Articles 101 and 104 of the Constitution.
Standards of conduct for all judges are set out in the Code of Ethics of the National Magistracy and Law No. 35/1979, which enshrine independence, impartiality, and integrity. Members of the highest judicial bodies, as well as all judges, must submit asset declarations under Laws No. 35/1979 and 8.730/1993, but data on submission rates, verification, or follow-up for conflict-of-interest cases is not available.
Complaint channels exist under CNJ Resolution No. 432/2021, Resolution No. 67/2009 and the rules of the National Justice Inspectorate, allowing in-person, electronic, and postal submissions. However, these mechanisms do not provide dedicated whistleblower protection, legal safeguards against retaliation are absent, and staff confidentiality training is not mandatory.
Note: 2025 data or latest year available.
Source: OECD Public Integrity Indicators Database (data extracted on 7 March 2026).
Brazil fulfils 38% of criteria on prosecutorial integrity regulations, and 32% on practice, compared to the OECD average of 66% and 52%, respectively.
Procedures for the selection, appointment, and promotion of ordinary prosecutors are established in the Constitution, Law 8.625/1993, Law 75/1993, and CNMP Recommendation 108/2024. These procedures include competitive examinations, evaluation of performance, seniority, training, and public, reasoned decisions on promotions. However, objective, merit-based procedures are not required for the selection and appointment of the Attorney General of the Republic, who is appointed by the President with the Senate’s approval. There is no legal provision allowing candidates to appeal selection, appointment, or promotion decisions, and clear dismissal grounds are lacking for both prosecutors and the Attorney General.
CNMP Resolution 261/2023, alongside the Constitution, define circumstances and relationships that may create conflicts of interest. The Code of Criminal Procedure and the Code of Civil Procedure outline recusal provisions and mechanisms to resolve conflicts of interest. Allegations of recusal or impediment are resolved through a formal petition process.. Sanctions for breaches of conflict-of-interest rules are clearly defined in Complementary Law 75/1993 and Law 8.370/1993, ranging from a formal warning to removal from office.
There are no internal reporting channels or comprehensive protection for whistleblowers against retaliation in the law for reporting prosecutorial misconduct. There is no mandatory training or publicly available guidance for relevant officials on ensuring confidentiality in handling reports.
Note: 2025 data or latest year available.
Source: OECD Public Integrity Indicators Database (data extracted on 7 March 2026).
Brazil fulfils 92% of criteria on disciplinary system regulations, and 100% on practice, compared to the OECD average of 66% and 22%, respectively.
Law 8,112/1990 establishes the disciplinary framework for civil servants in Brazil, regulating procedures, rights, and sanctions within the federal administration. It defines disciplinary offences and prescribes how investigations and proceedings are conducted, ensuring that the accused have the right to be heard and to challenge evidence. Statutes of limitation set clear timeframes for initiating proceedings.
Civil servants may challenge disciplinary decisions in court after exhausting administrative remedies. Law 8,112/1990 sets the procedures, infractions, sanctions, and rights of the accused, and the Constitution guarantees judicial review of all administrative decisions, ensuring disciplinary sanctions can be contested in court. Administrative review of disciplinary cases is also possible under Law 8,112/1990 (Art. 174–182), either upon request or ex officio, if new facts or circumstances justify reconsideration. Decisions violating binding precedents may additionally be appealed to the Supreme Federal Court under Art. 64-B of Law 9,784/1999, which governs administrative procedures.
Staff handling disciplinary investigations are trained annually by the Comptroller General’s Office (CGU), which also provides guidance on the mandatory ePAD system for managing disciplinary cases. This electronic system, used across all central government bodies, ensures standardised, secure, and efficient handling of proceedings. Data on cases initiated, concluded, appealed, and sanctions applied are systematically recorded. While some datasets require CGU access, aggregated information is publicly available through transparency portals, promoting accountability and oversight of disciplinary actions within the federal administration.
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The full book is available in English: OECD (2026), Anti-Corruption and Integrity Outlook 2026: Harnessing the Integrity Advantage, OECD Publishing, Paris, https://doi.org/10.1787/16708b78-en.
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