Abstract Transnational networks of non-state actors are using ILO Convention No. 169 as a powerful instrument of environmental governance. The treaty promotes the norm of Free, Prior and Informed Consultation (FPIC), empowering local communities to influence infrastructure projects that impact their livelihoods and natural resources. However, there is a disconnect between the Brazilian government’s discourse and the effective implementation of this norm. Using document analysis and process tracing, this article investigates this rhetoric-practice gap. It argues that these transnational networks are diffusing the FPIC norm through Consultation Protocols, slowly bridging the gap.