The Attorney General's Office for the National Treasury (PGFN) published, on June 1, 2026, the Public Notice No. 6/2026, opening a new window for joining the tax transaction proposal to regularize debts registered as outstanding federal tax liabilities. The enrollment period runs from 8:00 AM on June 1, 2026 to 7:00 PM on September 30, 2026.
Debts registered as outstanding tax or non-tax liabilities with a consolidated value of up to R$ 45,000,000.00 per taxpayer are eligible. For eligibility purposes, the registration as outstanding debt must have occurred by June 1, 2025 for Small Value Transactions and March 3, 2026 for general modalities.
Transaction modalities of the new PGFN public notice
The PGFN (Attorney General's Office for the National Treasury) notice provides for four types of transactions:
(i) Transaction by Ability to Pay.
Intended for taxpayers whose presumed ability to pay is insufficient to fully settle their tax liabilities within 5 years. The general rule allows a discount of up to 65% on the total value of each registration. Payment can be made in full or in installments, with an initial payment of 6% of the consolidated amount in up to 6 monthly installments and the balance in up to 114 subsequent installments.
If the taxpayer is an individual, MEI (Individual Microentrepreneur), ME (Microenterprise), EPP (Small Business), Santa Casa de Misericórdia (charitable institution), cooperative, civil society organization, or educational institution, the discount will be a maximum of 70% on the total value of each registration, or in the case of payment in installments, by paying an initial installment of 6% of the total consolidated debt, in up to 12 monthly installments, and the remaining balance may be paid in up to 133 successive monthly installments, with a possible discount of up to 100% on interest, fines, and legal charges, respecting the maximum limit of 70% discount on the total value of each registration.
(ii) Transaction of Debts that are Difficult to Recover or Unrecoverable.
Credits registered for more than 15 years without collateral or suspension of enforceability; with enforceability suspended by court order for more than 10 years; or held by debtors who are bankrupt, in judicial or extrajudicial reorganization, in liquidation, or with an irregular registration status in the CNPJ or CPF are considered unrecoverable.
For this category, the discount can reach up to 65% of the total value (70% for business entities in judicial reorganization and for the taxpayers mentioned in the previous modality), with a down payment of 5% of the consolidated value in up to 12 monthly installments and the balance in up to 108 (or 133 if the debtor is a natural person, individual microentrepreneur, microenterprise, small business, Santa Casas de Misericórdia, cooperative societies, other civil society organizations referred to in Law No. 13,019, of July 31, 2014, or educational institutions) subsequent installments.
(iii) Small Value Transaction.
Aimed at low-value registrations for individuals, MEI (Individual Microentrepreneur), ME (Microenterprise), and EPP (Small Business). For MEI under revenue code 1537, with registrations up to 5 minimum wages, a fixed discount of 50% applies, payable in up to 60 installments. For other categories, whose individual registrations do not exceed 60 minimum wages, the discount varies from 30% to 50%, depending on the chosen payment term (cash payment with a 50% discount; or installment payment with a down payment of 5% of the consolidated amount in up to 5 months and the balance in up to 55 subsequent installments, with a regressive discount from 50% to 30%).
(iv) Registration Transactions Guaranteed by Surety Bond or Letter of Guarantee.
Applicable to registrations with a final and unfavorable judgment against the taxpayer and without a claim or execution of the guarantee. No discounts are granted. Payment is made by means of an initial payment of 30%, 40% or 50% of the consolidated amount, with the remaining balance in up to 6, 8 or 12 monthly installments, respectively. Maintaining the validity and effectiveness of the insurance or letter of credit is a condition for the approval of the application.
According to the PGFN (Brazilian Federal Attorney General's Office), partial adherence to the transaction is prohibited; only combinations of available modalities are permitted. Taxpayers who are judicially disputing the debts under the transaction must withdraw their respective lawsuits and request the termination of the proceedings with a decision on the merits within 60 days of the negotiation. Furthermore, they are obligated to maintain good standing with the FGTS (Brazilian Severance Indemnity Fund) for 90 days after the formalization of the agreement, as well as to authorize the offsetting of any federal refunds and court-ordered payments against the installments of the agreement.
Our team of Tax Law It is highly specialized and continues to monitor the impacts of the recent PGFN (Attorney General's Office for the National Treasury) announcement.
