REGULATORY APPROVAL · 05/05/2026

From the Sandbox to S3: SUSEP approves Split Risk's migration

On April 30, 2026, SUSEP approved the capital increase and the migration of Split Risk Seguradora from the regulatory Sandbox of SUSEP - Superintendência de Seguros Privados to the S3 segment, formalizing its entry into…

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From the Sandbox to S3: SUSEP approves Split Risk's migration

On April 30, 2026, SUSEP approved the capital increase and the migration of Split Risk Seguradora from the regulatory Sandbox of SUSEP - Superintendência de Seguros Privados to the S3 segment, formalizing its entry into the full prudential regime to operate property and casualty insurance throughout Brazil.

The approval confirms Split Risk's effective exit from the Sandbox and marks another significant step in the program's maturity, just days after the prior authorization granted to LTI Seguros for the same regulatory destination.

𝗣𝗿𝗶𝗼𝗿 𝗮𝘂𝘁𝗵𝗼𝗿𝗶𝘇𝗮𝘁𝗶𝗼𝗻 𝗮𝗻𝗱 𝗳𝗶𝗻𝗮𝗹 𝗮𝗽𝗽𝗿𝗼𝘃𝗮𝗹: 𝘁𝘄𝗼 𝘀𝘁𝗮𝗴𝗲𝘀, 𝗼𝗻𝗲 𝗽𝗮𝘁𝗵.

The distinction between the two acts often causes confusion in the market.

• Prior authorization is SUSEP's initial decision on the application. The agency reviews the corporate structure, the controlling shareholder, the business plan and the regulatory requirements, and authorizes the operation in advance. From that approval, the company has a deadline, generally 90 days, to implement the operation and file the corresponding administrative proceeding.

• Final approval (homologation) is the last stage. SUSEP reviews the acts actually performed, such as paid-in capital increases, registered amendments to the bylaws and evidence of the required conditions, and formalizes the company's entry into the new regime.

Split Risk has now completed the final stage of this path.

𝗧𝗵𝗲 𝗦𝗮𝗻𝗱𝗯𝗼𝘅 𝗿𝗲𝘀𝘂𝗹𝘁

Split Risk's approval reinforces SUSEP's Sandbox as one of the quiet success stories of recent Brazilian regulation. It is not a regime for accommodating small projects indefinitely. It is a space to test business models, validate the prudential structure and migrate to the full regulated environment.

Panucci, Severo e Nebias Advogados advised Split Risk in the process before SUSEP, with the involvement of partner Roberto Panucci and associate Marcelo De Callis.

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