The value of data management

CNV RG 1115/2026: A new chapter for reporting in Argentina

The recent General Resolution 1115/2026 from the National Securities Commission (CNV) has ushered in a new era for companies operating under the public offering regime in Argentina. By explicitly incorporating sustainability information into issuers' Annual Reports for the first time, the country is joining a trend that is becoming increasingly prevalent across Latin America. While the region is moving at different speeds—with cases like Mexico demanding rigorous frameworks based on global standards, and others, like Brazil, shifting mandatory requirements toward voluntary schemes—the underlying direction is shared and consistent. In the Argentine case, the initial requirement is flexible: it establishes a "comply or explain" narrative model, does not set specific metrics to be reported (such as Scope 3 emissions or physical risks), and does not require formal verification of the information. However, regardless of the current level of stringency in each country, it is clear that the greatest resilience for any organization lies in the control and management of its own data.

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At Kolibri, based on our experience supporting organizations in their transition toward business models that place environmental variables at the heart of their value proposition, we have seen that regulatory compliance can be an ideal opportunity to transform data management into a strategic asset. We are certain that integrating environmental variables strengthens business understanding, helps identify resource efficiency, and boosts long-term competitiveness.

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Reporting as an opportunity 

This local regulatory flexibility hides a strategic challenge and, at the same time, a key differentiator. The regulation asks companies to report their performance indicators on the subject "if they have them." If a company chooses not to do so, it must publicly explain why its directors consider these issues irrelevant to their business. Facing this scenario opens up several opportunities:

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• Market positioning: The justification for not reporting is captured in a public document signed by the board of directors. Having the ability to be transparent and demonstrate management represents a great opportunity to show maturity to investors, banks, business partners, and various stakeholders in the value chain, rather than justifying the absence of indicators.
• Driving the internal agenda: The regulatory requirement serves as a vehicle to accelerate the systematization of environmental and social issues, shifting the focus of the discussion: it is no longer about asking whether there is a strict obligation, but about seizing the opportunity to consolidate this data and translate it into concrete business opportunities, enabling improvements in competitiveness and dialogue with the value chain. 

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From obligation to business efficiency 

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To capitalize on these opportunities, information governance and data management are the key differentiators. The financial review itself contemplates the collection of physical statistical data, such as electricity or gas consumption, which form the basis for calculating operational environmental impact. Systematizing this data and consolidating its management will not only allow for accountability alongside financial statements but will also add real value to the business on multiple fronts:

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• Access to capital: Environmental, social, and governance information is key data analyzed by investors and multilateral organizations. Measuring this methodically and aligning with global standards enables better financing conditions and opens the door to schemes such as sustainability-linked thematic bonds.
• Cost efficiency: The process of inventorying energy, fuel, and resource usage for reporting purposes also makes it possible to detect where inefficiencies exist and where opportunities for savings and optimization can be found.
• Comprehensive risk management: Although current Argentine regulations do not explicitly require this to be reported, climate exposure is already an evaluation criterion for multiple stakeholders. Building this information allows you to get ahead of the conversation regarding physical and transition risks, which is already formalized in other countries in the region.

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