RADAR Siscomex — the license to import and export

The three modalities

The RADAR is not a single registry: the company is classified into one of three modalities, defined in art. 16 of RFB Normative Instruction 1.984/2020, and it is the classification that sets how much it may import per six-month period (the limit does not reach exports, which have no ceiling).

• Express: reserved for publicly traded corporations and their wholly owned subsidiaries, public enterprises and mixed-capital companies. It has no import limit.
• Limited: for those with an estimated financial capacity of up to USD 150 thousand per semester, with two import sublimits — USD 50 thousand and USD 150 thousand, measured by the customs value. It is the gateway for most companies.
• Unlimited: for those with an estimated capacity above USD 150 thousand per semester; it does not subject the company to any ceiling.

The AEO certification does not appear in art. 16 as a modality — the old rule that the AEO would grant Express RADAR belonged to the repealed RFB Normative Instruction 1.603/2015. When the automatic estimate does not reflect the real size, an estimate review lies to raise the modality.

How the licensing works

The request is filed through the Habilita system, within the Siscomex Single Portal, and in most cases approval is automatic (arts. 20-24 of RFB Normative Instruction 1.984/2020). Before applying, the company must meet the admissibility requirements (art. 21): DTE enabled in the e-CAC and a regular registration status of the CNPJ and of the CPF of the representatives. When the request falls into analysis, a digital case is opened before the unit of the tax domicile, with a verification notice and a non-extendable 10-day period for cure (art. 24, §2).

The legal basis for requiring the license lies in art. 16 of Law 9.779/1999 and in art. 809, §2, of Decree 6.759/2009 (the Customs Regulation) — and not in art. 80 of Provisional Measure 2.158-35/2001, which deals only with importation on behalf and to the order of a third party. The financial capacity that defines the modality is estimated by the Revenue Service from taxes paid (art. 18 and Coana Ordinance 72/2020) and may be reviewed on request, with no risk of a downgrade (art. 29, §2).

Maintenance, delicensing and cost

Being licensed requires continuous maintenance. A company that goes 12 months without operating is automatically delicensed for inactivity (art. 47), and since 15/01/2026 (Siscomex Systems Notice 013/2025) the license came to require permanent registration regularity of the CNPJ and of the CPF of the representatives — irregularity delicenses and prevents operating until regularization. RFB Normative Instruction 2.292/2025 (of 18/11/2025) broadly reformed the regime and tightened fraud control.

On cost: there is no RADAR licensing fee — the request in Habilita is free. The Siscomex Utilization Fee (BRL 115.67 per declaration, plus a regressive value per addition from BRL 38.56) is a distinct thing: it is charged on the registration of each import declaration, not on the license. Although the STF declared unconstitutional the 2011 increase in that fee (Theme 1085), the refund window has already lapsed.

How TaxUp helps with the RADAR Siscomex

The TaxUp team diagnoses the correct modality for the company’s import volume, conducts the request in Habilita and, when the automatic limit does not reflect the real size, structures the estimate review to raise the modality — through the administrative channel or, if necessary, through a writ of mandamus. It also acts in relicensing after a delicensing and in the appeal against a denial. The complete step by step, with the modalities, the limits and the financial-capacity formula, is in the guide RADAR Siscomex: modalities, limits and how to raise them.