Brazil — CMN regulates BRL 4 billion in subsidised FNAC loans to airlines

Mechanism

The CMN (Brazil's National Monetary Council, chaired by the Ministry of Finance) approved a resolution on 30 October 2025 regulating how the National Civil Aviation Fund (FNAC) — financed by airport-concession contributions — can be lent out to airlines. The program makes up to BRL 4 billion available across six credit lines, all prioritising national suppliers: (1) SAF purchases, (2) aircraft maintenance, (3) engine maintenance, (4) aircraft acquisition, (5) advance payment for aircraft, and (6) logistics infrastructure. Interest rates range from 6.5% to 7.5% per year — materially below unsecured commercial credit for Brazilian carriers, several of which (Azul, Gol) have faced financial distress. The Ministério de Portos e Aeroportos and BNDES formalised the operating contract in December 2025, with a February 2026 government announcement confirming the lines were open for disbursement.

The counterpart package is the notable industrial-policy lever: airlines must commit to raising SAF use by 1 percentage point per year toward a 10% blend target (exceeding Brazil's existing legal Fuel of the Future mandate), increase Legal Amazon/Northeast regional flight frequency by 30% versus 2024 baselines, and cannot expand dividend payouts to shareholders during the loan's grace period. Global Trade Alert logs the SAF/national-supplier prioritisation strand separately as a "local content incentive" alongside the underlying credit-line intervention.

Downstream implications

• A second Brazilian state-credit intervention for the airline sector inside a month (following

the 27 Nov 2025 Gecex/FGE aviation-kerosene guarantee, 2025-11-27-brazil-camex-fge-aviation-kerosene-credit-guarantee), underscoring how the federal government is using multiple fund/agency channels (CMN/FNAC, Camex/FGE) to shore up carrier liquidity and cheap financing simultaneously.

• The SAF-blending and domestic-supplier counterparts function as demand-pull industrial policy

for Brazil's nascent SAF production industry, financed through interest-rate relief rather than direct subsidy.

• Regional-connectivity requirement (Legal Amazon/Northeast) ties the credit program to a separate

domestic policy goal (regional air-service coverage), broadening the program's political rationale beyond pure carrier bailout.

Open questions

• No confirmed per-airline drawdown cap disclosed; unclear how the BRL 4 billion is allocated

across the six lines or across competing carriers (Azul, Gol, LATAM Brasil, Voepass).

• Whether the dividend-freeze counterpart has already bound any carrier, or is likely to given

current profitability across Brazil's airline sector, is not yet publicly reported.