New Settlement Opportunities before the PGFN
The Office of the Attorney General of the National Treasury (Procuradoria-Geral da Fazenda Nacional – “PGFN”) has published two new acts on settlement by adhesion (transação por adesão) of debts enrolled as federal overdue liabilities (dívida ativa).
PGDAU Public Notice No. 10/2026 extended Public Notices No. 6 and No. 9 until January 29, 2027, and Public Notice No. 8 – Desenrola Rural until December 20, 2026, in addition to extending the cut-off dates for eligible enrolled debts.
PGDAU/PGFN/MF Public Notice No. 12/2026 created a settlement for debts relating to the FGTS and to the Social Contributions under Complementary Law No. 110/2001, of up to BRL 45 million per obligor (sujeito passivo).
Discounts reach 100% of the late-payment charges, capped at 65% or 70% of the amount of each enrolled debt, with installment plans of up to 133 installments. They do not apply to amounts owed to workers.
Adhesion to Public Notice No. 12/2026 is made through REGULARIZE (PGFN’s online platform), from 8 a.m. on October 15, 2026, to 7 p.m. on January 29, 2027.
PGDAU Public Notice No. 10/2026: Extension of the Public Notices in Force
PGDAU Public Notice No. 10/2026 extended the adhesion deadlines and the cut-off dates for enrolled debts that may be negotiated under Public Notices No. 6, 8 and 9/2026.
Public Notice No. 12/2026: New Settlement for FGTS Debts
- Debts enrolled as overdue liabilities (dívida ativa) of the Government Severance Indemnity Fund for Employees (Fundo de Garantia do Tempo de Serviço – FGTS); and
- Debts relating to the Social Contributions created by articles 1 and 2 of Complementary Law No. 110/2001.
Social Contributions under Complementary Law No. 110/2001: the 10% termination contribution levied on dismissals without cause and the 0.5% monthly contribution on workers’ remuneration, both currently extinct, although debts previously constituted may remain enrolled as overdue liabilities (dívida ativa).
- by October 15, 2025, for the Small Amount Settlement modality; or
- by July 17, 2026, for the other modalities provided for in the Public Notice.
Public Notice No. 12/2026: Modalities and Conditions
Requirements for Adhesion to Public Notice No. 12/2026
Discounts
- Up to 100% of interest, fines and charges, capped at 65% or 70% of each enrolled debt. Amounts owed to workers are not subject to discount.
- The use of tax loss carryforwards (prejuízo fiscal) or negative CSLL tax base (base negativa de CSLL) is not allowed.
Unrecoverable debts
- Debts enrolled for more than 15 years without a guarantee, judicially suspended for more than 10 years, owed by bankrupt debtors or debtors under reorganization (recuperação), by companies that have been deregistered or declared unfit (inaptas), and by deceased individuals.
Scope of adhesion
- Adhesion must include all eligible enrolled debts; partial adhesion is prohibited, except for debts that are guaranteed, under installment plans, subject to a settlement, or judicially suspended.
- Ongoing installment plans and settlements require withdrawal. Negotiations with Caixa Econômica Federal (CEF) may be migrated through REGULARIZE.
Lawsuits and economic groups
- Withdrawal from lawsuits and appeals within up to 60 days; judicial deposits are applied to amortize the enrolled debts.
- Members of an economic group must acknowledge it immediately after adhesion.
- Co-obligors and enrolled debts backed by guarantee insurance or bank guarantee depend on a prior request.
Payment, Obligations and Termination
Payment
- First installment due by the last business day of the month of adhesion, failing which the application will be rejected.
- Installments adjusted by the Selic rate, with a minimum of BRL 100 (BRL 25 for MEI), payable only through a payment slip issued by REGULARIZE.
Obligations during the agreement
- Maintain good standing with the FGTS, the PGFN and the Federal Revenue Service (Receita Federal); new debts must be regularized within 90 days.
- Individualize the amounts in the workers’ accounts within 30 days of the first payment.
- Guarantees and encumbrances remain in place; federal tax refunds and court-ordered payments (precatórios) may be offset against the installments.
Impediments
- Parties whose settlement was terminated in the last 2 years, or who are listed in the registry of employers that have subjected workers to conditions analogous to slavery, may not adhere.
Cancellation and termination
- The agreement is terminated, among other cases, upon 3 overdue installments, whether consecutive or not, asset stripping or bankruptcy.
- • Termination cancels the discounts, resumes collection and the guarantees, and bars a new settlement for 2 years. A challenge may be filed within 30 days.
This content is provided for informational purposes only and does not constitute legal advice. The application of this information depends on the analysis of each specific case.