The Office of the Attorney General of the National Treasury (PGFN) has published Notice No. 6/2026, opening a crucial window of opportunity for companies and individuals with debts enrolled in the Federal Union’s outstanding debt registry (dívida ativa da União). The program allows taxpayers to regularize tax liabilities with substantial reductions in interest, fines, and legal surcharges, in addition to significantly extended payment terms.
The window for joining the program is already open and will remain available until 7:00 p.m. (Brasília time) on September 30, 2026.
Below, we summarize the key aspects of the Notice in clear and straightforward language to help you assess the impact of this measure on your business.
Who is eligible and what are the limits?
Amount of outstanding debt: Tax and non-tax debts may be included, provided that the consolidated amount does not exceed BRL 45,000,000.00 (forty-five million reais) per taxpayer.
Enrollment cut-off dates: For the Small-Value modality, the debt must have been enrolled in the Union’s outstanding debt registry by June 1, 2025. For the other modalities, the latest enrollment date is March 3, 2026.
Overview of the 4 Settlement Modalities
The Notice allocates the available benefits according to the taxpayer’s economic situation and the nature of the outstanding debt:
1. Settlement Based on Payment Capacity
Designed for taxpayers whose presumed financial situation indicates insufficient resources to fully settle their debts within the next five years.
General rule: Discounts of up to 100% on interest, fines, and legal surcharges, capped at 65% of the total amount of each enrolled debt. The outstanding balance may be paid in installments, with an initial payment of 6% (in up to 6 installments) and the remaining amount in up to 114 monthly installments.
Benefit for micro and small businesses, sole proprietors, and individuals: For this group (which also includes charitable hospitals, cooperatives, and educational institutions), the maximum discount increases to 70% of the total amount. The remaining balance may be paid in up to 133 installments after payment of the initial contribution, which itself may be split into up to 12 installments.
2. Settlement of Unrecoverable Debts
Focused on debts for which the tax authorities have a very low likelihood of recovery, including debts enrolled for more than 15 years without collateral, companies in bankruptcy or in-court/out-of-court reorganization, and companies whose taxpayer identification number (CNPJ) has been cancelled or classified as inactive.
General rule: Initial payment of 5% (in up to 12 installments), with the remaining balance payable over up to 108 months and discounts of up to 65% of the total amount.
For companies under court-supervised reorganization, micro and small businesses, and sole proprietors: the maximum discount is increased to 70% of the consolidated amount, and the remaining balance may be paid in up to 133 monthly installments.
Small-Value Settlement
Intended for individuals, sole proprietors (MEIs), microenterprises (MEs), and small businesses (EPPs).
Debts of up to 60 minimum wages: This modality offers a flat 50% discount on the total amount for payment either in a lump sum or in installments (with an initial payment of 5% in up to 5 installments and the remaining balance in up to 7 months). Longer installment plans are also available (up to 55 months), with progressively reduced discounts ranging from 45% to 30%.
MEI (Tax Code 1537): Where the enrolled amount is up to five minimum wages, a 50% discount is granted on the total debt, with direct installment payment in up to 60 months.
4. Enrollments Secured by Surety Bond or Bank Guarantee
For companies with final and unappealable adverse court decisions whose guarantees have not yet been enforced. No discounts are granted, but installment payment is allowed, with initial payments ranging from 30% to 50% of the total amount and the remaining balance payable over periods of 6 to 12 months.
Key Rules and Practical Considerations
Full adherence requirement: The settlement must necessarily cover all eligible enrollments (inscrições) of the taxpayer, and it is not permitted to select only certain debts, except in specific cases such as amounts already under installment plans or with enforceability suspended.
Debts under judicial dispute: If the taxpayer decides to include debts currently being litigated in court, they must file for withdrawal of the relevant lawsuits and submit proof of such withdrawal in the REGULARIZE system within 60 days from the date of adherence.
Minimum installment amounts: The minimum installment is BRL 100.00 in most cases and BRL 25.00 for sole proprietors (MEIs) under the specific tax code 1537. All installments are subject to monthly indexation by the SELIC rate plus an additional 1% in the month of payment.
Compliance considerations: The Notice bars participation by taxpayers whose prior settlement agreements were terminated within the last two years. In addition, providing false information or concealing assets to obtain improper discounts leads to termination of the agreement and referral for criminal prosecution to the Federal Prosecution Service (Ministério Público Federal).
Why is legal support essential?
Your Payment Capacity is assessed confidentially by PGFN’s systems. In many cases, the tax authority’s initial classification does not accurately reflect the company’s actual financial condition, which may reduce the level of discounts made available.
Specialized legal analysis makes it possible to verify and challenge this calculation, structure the most advantageous combination of settlement modalities, and ensure the safe termination of court proceedings associated with the debts, thereby protecting the business owner’s assets and mitigating the risk of termination of the agreement.