With the approach of the Ordinary General Meetings of publicly traded companies, held in accordance with Article 132 of Law No. 6,404/1976, the amendment introduced by Law No. 15,177/2025, which added paragraph 6 to Article 133 of the Corporations Law, gains special relevance. The new provision mandates the inclusion, in the management report, of structured information regarding the gender equality policy adopted by the company.
The report should include, in comparison to the previous year, the number and proportion of women by hierarchical level, female participation in management positions, and remuneration—fixed, variable, and occasional—segregated by sex in equivalent positions or functions. This is a duty of transparency directly embedded in the corporate regime of annual accountability, forming part of the informational content submitted for shareholders' meeting approval.
Law No. 15.177/2025 applies to all publicly traded and privately held companies, regardless of the number of employees, giving it broad scope within the framework of corporate law. In this respect, the rule complements the discipline established by Law No. 14.611/2023, whose Article 5 requires salary transparency reports from employers constituted as private legal entities with 100 (one hundred) or more employees. While the latter has an objective focus linked to the size of the employer, the new wording of Article 133 of the Corporations Law establishes an autonomous corporate obligation, based on the logic of governance and accountability to shareholders.
In light of the upcoming shareholder meeting season, corporate administrations are required to consolidate the required data technically and coordinate between the legal, human resources, and governance areas to ensure formal and substantive compliance with the new legal disclosure obligation.
From a contemporary governance perspective, this requirement is unequivocally part of the ESG agenda, especially in the Social (diversity and equity) and Governance (transparency and accountability) vectors. By shifting gender equity metrics to the management report—a central document in the shareholders' meeting cycle—legislators are transforming indicators traditionally treated as voluntary best practices into a legal obligation for disclosure, reinforcing the integration between corporate law and corporate sustainability standards.