06/09/2026
The Office of the Attorney General of the National Treasury (PGFN) has published Notice No. 6/2026, establishing new conditions for the regularization of debts registered as federal overdue liabilities, whether tax or non-tax in nature, with a consolidated amount of up to BRL 45,000,000.00 per taxpayer.
Taxpayers may enroll until September 30, 2026, at 7:00 p.m., exclusively through the REGULARIZE portal. The notice provides for different transaction modalities, including transactions based on the taxpayer’s payment capacity, transactions involving debts deemed difficult to recover or irrecoverable, small-value transactions, and transactions related to registrations secured by surety bond insurance or bank guarantee letters.
As regards transactions based on payment capacity, debts registered as federal overdue liabilities by March 3, 2026 may be included. Under this modality, payment terms and any applicable discounts are determined according to the classification assigned by the PGFN to the taxpayer, taking into account the taxpayer’s payment capacity. Depending on the circumstances, the transaction may involve a reduced down payment, installment payment of the remaining balance, and discounts on interest, fines, and legal charges, subject to the limits set forth in the notice.
The notice also establishes specific conditions for debts classified as difficult to recover or irrecoverable. This modality may be particularly relevant for taxpayers with older liabilities or liabilities with lower prospects of recovery, as it allows regularization under more favorable payment terms. The notice also includes specific modalities for small-value debts and for registrations secured by surety bond insurance or bank guarantee letters.
This new transaction opportunity may represent an important alternative for taxpayers seeking to reorganize their tax liabilities and improve their fiscal position.
However, despite the potential benefits, enrollment should be preceded by an individualized assessment to determine which debts are eligible, which modality offers the most favorable conditions, whether there are lawsuits or guarantees linked to the relevant registrations, and the financial impacts arising from the down payment and installment plan.
Our tax team remains available to provide further clarification and guidance on the matter.
Authored by: Phillipe da Cruz Silva
