New PGFN Public Notice: Opportunity for regularization of enrolled active debt up to BRL 45 Million

On June 1, 2026, the Office of the General Attorney for the National Treasury (PGFN) published Public Notice PGDAU No. 6/2026, opening a new window for the regularization of debts enrolled in the Union’s active debt, with a consolidated value of up to BRL 45 million.

The enrollment deadline runs until September 30, 2026, at 7:00 PM, through the REGULARIZE portal. More than just an operational opportunity for an installment plan, this public notice demands a strategic analysis: adhering to the tax transaction can lead to a significant reduction in liabilities, extended payment schedules, tax regularization, and an improved corporate standing before banks, suppliers, investors, and public agencies.

What the New Public Notice Allows

The new public notice includes four main transaction modalities:

• Transaction based on payment capacity;

• Transaction for debts that are difficult to recover or irrecoverable;

• Small-value transaction;

• Transaction regarding debts secured by insurance bonds or bank guarantees.

In the modalities applicable to most companies, debts enrolled in the Union’s active debt up to March 3, 2026, may be negotiated, provided that the total consolidated value does not exceed BRL 45 million.

Depending on the taxpayer’s classification and the applicable modality, the public notice provides benefits such as:

• Waiver of down payment for lump-sum payments;

• Facilitated down payments;

• Installment plans with extended terms for the remaining balance;

• Discounts of up to 100% on interest, fines, and legal charges, subject to the limits of the public notice;

• Possibility of utilizing federal court-ordered debts (precatórios) under specific circumstances.

For micro-entrepreneurs, micro-businesses, small business entities, and individuals, there are also specific rules for small-value debts, with discounts that may vary based on the term and form of payment.

Why Prior Analysis is Essential

A tax transaction is not merely a simulation of installments. Before enrolling, it is highly recommended to evaluate at least five key points:

1. Eligibility of Debts: Not every enrolled debt can be included in the same modality. The enrollment date, the nature of the debt, the existence of collateral, previous installment plans, ongoing lawsuits, or the suspension of enforceability can alter the strategy.

2. Classification of Payment Capacity: In the transaction by payment capacity, the PGFN classifies the taxpayer automatically. This classification can impact discounts, terms, and conditions. In some cases, it may be necessary to evaluate a request for a review of the payment capacity.

3. Impacts on Lawsuits: When the debt is being disputed in court, enrollment may require waiving the lawsuit, appeal, or challenge, with the presentation of proper documentation within a specific deadline. This decision must be made cautiously, especially when significant legal arguments or deposits/guarantees are involved.

4. Cash Flow and Risk of Rescission: Defaulting can lead to the forfeiture of benefits and the resumption of collection efforts. Furthermore, the rescission of the transaction may prevent a new enrollment for two years. Therefore, the payment plan must be financially defensible.

5. Corporate, Accounting, and Reputational Effects: Regularizing active debt can impact the issuance of tax clearance certificates, contracts, corporate transactions, credit acquisition, participation in public biddings, corporate reorganizations, and negotiations with third parties.

When is the Transaction Especially Relevant?

The public notice deserves close attention from companies that:

• Have ongoing tax foreclosures (execuções fiscais);

• Have federal debts enrolled in active debt;

• Intend to participate in public biddings or contract with the public administration;

• Are in the process of fundraising, sale, reorganization, or corporate succession;

• Face credit restrictions or cash flow pressure;

• Wish to reduce tax contingencies prior to strategic operations.

In many cases, the opportunity lies not only in the discount but in the reorganization of tax liabilities within a broader legal, financial, and corporate strategy.

The Core Point: A Comprehensive Review of Tax Liabilities

Experience shows that many companies enroll in regularization programs without a complete review of their liabilities. This can lead to inefficient choices, lost discount opportunities, the improper inclusion of debts, or the premature waiver of relevant judicial discussions.

The safest decision requires a preliminary diagnosis, involving:

• Mapping out the active debt enrollments;

• Identifying available modalities;

• Comparative scenario simulations;

• Analysis of guarantees, lawsuits, and previous installment plans;

• Evaluation of payment capacity;

• Definition of the most advantageous modality;

• Monitoring the enrollment and subsequent obligations.

Although the final deadline for enrollment is September 30, 2026, document preparation, the review of payment capacity, and decision-making regarding potential lawsuits can take time. Therefore, if there is an interest in adhering to the new public notice, we suggest that the analysis be initiated as soon as possible.

For companies wishing to turn tax liabilities into predictability, this may be the right moment for a technical and objective analysis of the available alternatives.

At Cammarota & Abreu Advogados, the analysis of tax transactions is conducted in an integrated manner, considering not only the immediate fiscal aspect but also the legal, corporate, financial, and strategic impacts on the business. We remain at your disposal to assist you in making the best decision according to the specificities of your business.