OECD Integrity Review of Brazil 2025

Executive summary

Brazil has introduced several reforms that reflect the country's commitment to enhancing public integrity. This Integrity Review provides recommendations to support Brazil in identifying and addressing remaining challenges and ensuring successful implementation of current policies.

Consolidating a strategic approach to integrity

At the federal level, Brazil established a System of Integrity, Transparency and Access to Information and an Ethics Management System. Also, several co-ordination mechanisms promote exchanges among key integrity actors. However, while significant progress has been made, challenges remain in fostering more strategic co-ordination. The ethics commissions within federal public institutions are neither dedicated nor professionalised units and their role in sanctioning breaches of the Code of Professional Ethics of the Public Servant of the Federal Executive Branch weakens their potential to safeguard integrity. Also, public integrity in states and municipalities requires increased attention.

Recommendations

• Enhance the role of Brazil’s National Strategy against Corruption and Money Laundering (ENCCLA) in providing a strategic, multi-year vision for the country’s public integrity efforts.

• Transform the current ethics commissions into dedicated ethics units that can build expertise and become visible and trusted safe havens within public institutions. This includes transferring the authority to sanction violations of the Code of Professional Ethics to the disciplinary regime.

• Integrate a legal obligation for states, the Federal District and municipalities to develop their own integrity regulations, while continue providing incentives and technical assistance for implementing integrity policies at these levels.

Promoting an open culture of integrity in the public sector

Brazil has established integrity standards for public officials across the executive, legislative and judiciary branches. However, integrity standards are dispersed across various pieces of legislation, some dating back to 1990. Moreover, codes of ethics are often written in legalistic language rather than offering practical and clear guidance. In the legislative and judiciary in particular, public officials need more clarity and support to identify and effectively manage conflict of interest.

Recommendations

• Unify and simplify relevant integrity legislation and standards into a single, cohesive and overarching legal framework within each branch of government.

• Update the Code of Professional Ethics for Civilian Public Servants of the Federal Executive Branch and the Code of Conduct for the High Federal Administration taking a values-based approach and provide guidance on developing organisational codes to respond to specific risks.

• Enact legislation to identify and manage conflict of interest within the legislative and judiciary, including conflict of interest related to family relations or gifts, as well as movements between the private and public sectors (the "revolving door").

• Raise awareness among public officials about the role of ethics commissions (or future ethics units) as the primary channel for ethical guidance and advice.

Strengthening a whole-of-society approach to public integrity

Despite initiatives to foster a culture of integrity across society, trust in public institutions and in the government's anti-corruption and integrity efforts could be strengthened. Private sector integrity programmes seem focused on ensuring compliance rather than creating genuine cultures of integrity.

Recommendations

• Provide further guidance to private companies in establishing their integrity programmes, while encouraging high-risk sectors to develop sector-oriented integrity initiatives.

• Partner with universities and private sector federations to better understand practices and challenges in business integrity.

• Develop awareness-raising campaigns, being aware of potential unintended consequences.

Strengthening the integrity risk management and audit framework

Brazil has improved its risk management and internal control regulatory framework, aligning it with international standards. However, governance weaknesses, unclear responsibilities and a lack of accountability at senior levels compromise the internal control system’s effectiveness. Ensuring effective co-ordination among the various audit bodies remains challenging. While the Federal Court of Accounts (TCU) and the Office of the Comptroller General of the Union (CGU) collaborate in certain areas, this partnership and impact could be strengthened.

Recommendations

• To foster a greater sense of ownership, develop guidance and raise awareness among public officials and senior managers on internal control concepts, roles and responsibilities.

• Enhance co-ordination between the TCU and the CGU by establishing standards and guidelines to prevent duplication and foster synergy in integrity risk management.

• Further embed the Integrar Network across all audit courts to strengthen co-ordinated audits, harmonise methodologies and ensure consistent participation, creating a more unified approach to overseeing decentralised policies.

Implementing enforcement mechanisms

Brazil has introduced significant reforms to protect whistleblowers, but further efforts are needed to ensure effective implementation and address concerns regarding reprisals and retaliation. While the disciplinary system within the federal executive branch is comprehensive and effective, disciplinary enforcement at the sub-national level needs to be strengthened. The judiciary is generally considered independent, with judges holding substantial authority to assess the constitutionality of government actions. However, its efficiency is hindered by limited capacity and concerns over perceived corruption.

Recommendations

• Strengthen protection against retaliation for all who report on reasonable grounds and improve the co-ordination between existing reporting channels.

• Align subnational disciplinary legislation with federal regulations, develop manuals and automated tools for disciplinary processes and designate dedicated municipal units or staff to handle disciplinary matters.

• Improve the selection and appointment processes for higher positions in the judiciary and the prosecution service by involving independent bodies, establishing objective criteria and engaging non-political experts.

Strengthening transparency and integrity in decision-making

Brazil has established regulations to ensure transparency in policy influence and promote open government. However, given the evolving landscape of lobbying and influence, which increasingly involves diverse actors, heightened political polarisation and the spread of false or misleading information on social media targeting elections and policymaking processes, further efforts are needed.

Recommendations

• Adopt and enforce a framework to ensure transparency in lobbying activities, including definitions of “lobbying” and “lobbyist” and disclosure requirements identifying who is lobbying, on whose behalf, for which specific policies and through what means.

• Strengthen the integrity and transparency of ad hoc advisory or expert groups to inform legislative or policy decisions by detailing how inputs are handled, what outcomes are achieved and how those inputs influence the final decisions.

• Reduce opportunities for informal campaign financing by prohibiting cash contributions, introducing a nominal ceiling for individual donations and regulating third-party campaigning.

• Establish appropriate integrity standards for both public officials and lobbyists, including guidelines and training for public officials on engaging with lobbying and influence actors.