Authorized Economic Operator (AEO): the express lane of the Brazilian customs.
What RFB IN 2.318/2026 changed — and how to certify your company.

What the AEO Program is — from the WCO SAFE Framework to RFB IN 2.318/2026

The concept of the Authorized Economic Operator was born outside Brazil. In June 2005, the Council of the World Customs Organization (WCO) adopted the SAFE Framework of Standards, the global standard for security and facilitation of international trade, structured in three pillars — Customs-to-Customs, Customs-to-Business and Customs-to-Other Government Agencies. It is in the second pillar that the figure of the AEO (Authorized Economic Operator) lives: customs certifies trustworthy companies and, in exchange, concentrates enforcement on those who represent real risk. SAFE remains alive — the most recent edition is from 2025 — and the Brazilian AEO Program declares full alignment with it.

The Brazilian normative line — and the 2026 turn

In Brazil, the program was created by RFB IN 1.598/2015, succeeded by IN 1.985/2020 and by IN 2.154/2023 — which expanded the criteria from 18 to 22, included the shipping agencies and stretched the revalidation from 3 to 4 years. In 2026 came the complete restructuring: RFB IN 2.318, of 03/26/2026 (Official Gazette of 03/27/2026), expressly revoked IN 2.154/2023 and IN 2.200/2024 (art. 57) and came into force on the date of publication (art. 58). Every reference to IN 2.154/2023 as the governing rule is therefore outdated — and the warning is not theoretical: even pages of gov.br itself still display rules from the revoked instruction.

The infralegal layer is also new: Coana Ordinance 187/2026 regulates the procedures and sets the validation deadline, Joint Coana/Comac Ordinance 186/2026 created a team dedicated to candidates coming from Confia and RFB Ordinance 673/2026 approved the program’s Visual Identity Manual 2.0. Above all of this, Complementary Law 225, of 01/08/2026, gave the AEO — alongside the Confia and Sintonia programs — the status of complementary law, with concrete effects that this page details further on.

Voluntary membership, living certification

Three features define the nature of the program. First: membership is voluntary and there is no registration fee — the company’s real investment lies in the internal adjustment of compliance, risk management and documentation. Second: the certification is granted on a precarious basis, for an indefinite term (art. 27), which means it is not a static seal — there is permanent monitoring, annual self-assessment and revalidation every 4 years. Third: the AEO is a program of partnership, not of amnesty — whoever joins takes on continuous security and compliance obligations before customs.

The size of the program in official figures

As of 12/31/2025, the AEO System recorded 1,034 active certificates, from 827 distinct root CNPJs — 587 in AEO-Security and 436 in AEO-Compliance —, plus 187 applications under analysis. In two years (Jan/2024 to Dec/2025), the certified functions grew from 755 to 1,034. The economic weight is disproportionate to the number of companies: in 2025, AEOs accounted for 26.46% of the quantity and 28.55% of the value of Brazilian foreign-trade declarations — 29.68% of import declarations and 22.45% of export declarations. It is this group that the Revenue formally treats as a low-risk partner.

The real modalities of IN 2.318/2026 — AEO-Security and the three tiers of AEO-Compliance

Art. 7 of RFB IN 2.318/2026 structures the program in two modalities. AEO-Security (AEO-S) is open to all nine eligible parties in the logistics chain and looks to physical security — of the cargo, the transport, the facilities, the business partners. AEO-Compliance (AEO-C) is exclusive to importers and exporters (art. 7, §2) and looks to the tax and customs compliance of the operations. The 2026 novelty is inside AEO-C, which came to have three tiers:

What each tier means

The AEO-C Essential was tailor-made for trading export companies: it has simplified entry — it waives the self-assessment and the attachment of documents in the application (art. 20, §1), waives the validation visit and is not subject to the rule of 60% of operations on its own account (art. 7, §4) —, but requires the supporting documents to be uploaded to the system within 180 days of the certification. Its reason for existing is tax-related, as will be seen further on. The AEO-C Qualified corresponds to the former AEO-C tier 2 and concentrates the classic operational benefits of compliance. The AEO-C Reference is the new top of the program: only those who have already demonstrated elevated compliance reach it — certification in the Confia Program or an A+ rating in the Sintonia Program — and it is there that the green channel as the rule and the tax deferral reside. Applications for Essential and Reference have been open since 04/15/2026 (art. 53).

What ceased to exist — and what was never a modality

Two points of precision separate this page from much of what is read out there. First: the names “AEO-C tier 1” and “tier 2” were abolished — in the December 2025 statistics a single residual tier-1 certificate remained —, and the term “AEO-Full” does not exist in IN 2.318/2026: it is vocabulary of the regime of INs 1.985/2020 and 2.154/2023, today merely historical. Second: the AEO-Integrated is not a certification modality — it is the participation of other public agencies in the program, through complementary modules (art. 44, VIII, with guidelines in RFB Ordinance 435/2024). The official RFB page lists as operational the Secex, Anvisa and Anac modules — the Anvisa module, regulated by RDC 845/2024, was the pioneer — and as under implementation the modules of the Army, of Agro (currently suspended) and of Inmetro.

Real benefits — in the rule and in official figures

An honest clarification before the list: IN 2.318/2026 does not publish green-channel percentages as a rule — anyone promising “X% of green channel guaranteed by law” is making it up. What the rule guarantees are qualitative benefits by modality; what the official RFB statistics show is the practical result of them. The two planes, added together, form the business case for certification.

Clearance on the water — the importers’ favorite benefit

Clearance on the water is in art. 11, VI, of IN 2.318/2026: the AEO-C importer may register the import declaration before the arrival of the cargo at the customs territory, in the waterway and air modes — so that, with the green channel, clearance takes place practically upon berthing. It is no showcase benefit: 255 of the 436 eligible importers (58.5%) already use it, and it accounted for 17.9% of the declarations in the sea mode over the twelve months of the official statistics. A technical detail that is often poorly explained: the sole paragraph of art. 11 is not a condition of clearance on the water — it deals with another scenario, that of the AEO-C Qualified acting as a predetermined acquirer or orderer in imports by order and on behalf of a third party or by order: in those cases, the enjoyment of the benefits requires the operation to be registered by DUIMP, under the terms of a Coana act.

The result in figures — the statistic that settles the account

In the official average for 2025, AEO-Compliance importers had 0.32% selection for inspection — 99.68% of green channel —, against 23.15% for non-certified importers. On exports, the selection was 0.19% for AEO-Security against 1.31% for the rest. And the average clearance time on imports tells the same story in hours:

Translated into the operation, this means less storage and demurrage, less working capital idle in the gray channel and — perhaps the most valuable — lead-time predictability for inventory and production planning.

International recognition — the Mutual Recognition Agreements

The AEO-Security certification travels with the cargo. Through the Mutual Recognition Agreements (MRA), the partner customs treats the Brazilian AEO exporter as a low-risk operator — fewer inspections at destination and priority in disruption scenarios. Brazil counts ten signed MRAs, all in the AEO-Security modality, including the country’s two largest trading partners — and, in May 2025, came the unprecedented one: the Mercosur–Pacific Alliance MRA, formally signed according to the official RFB MRA sub-page, the first agreement of its kind signed between two economic blocs. For multinationals with operations in Brazil and for agribusiness exporters, it is a direct asset of international competitiveness.

Who may be an AEO — the nine parties, the 60% rule and the criteria

The nine eligible parties

Art. 6 of IN 2.318/2026 lists exhaustively who may apply for certification: importer, exporter, carrier, freight forwarder, shipping agency, warehouse keeper of goods under customs control in a bonded facility, warehouse keeper in Redex, port operator and airport operator. The customs broker is not on the list — it is not certifiable, although Coana may extend the program to other parties (§6). For importer, exporter, carrier, freight forwarder and shipping agency, the certification is granted to the head establishment, with automatic extension to all branches in the country; for warehouse keepers and port and airport operators, it is by establishment (§1). The shipping agency further needs registration in the Mercante system (§5). And there is an absolute entry bar: the habitual debtor may neither join nor remain in the program (§7).

The 60% rule — the loosening almost no one reported

For the importer, the rule of art. 6, §2 applies: the certification requires predominant activity on its own account — at least 60% of the operations directly, without indicating a third party as acquirer or orderer, a percentage measured by quantity or by value in the operations of the last 24 months (§3). The figure matters twice over. First, because the previous rule required 85%: IN 2.318/2026 opened the door to importers that keep up to 40% of indirect operations in their portfolio — a common profile in consumer-goods manufacturers that combine own imports and imports by order. Second, because the gov.br “Who may be an AEO” page itself still displayed, in a recent check, the old 85% percentage citing the revoked rule — the one in force is 60%, and using the wrong reference may wrongly discard (or approve) a candidate in the eligibility diagnosis.

Admissibility and certification criteria

Before any merits analysis, the candidate must pass the admissibility test: regular CNPJ registration, habitual activity as a party in the activity to be certified, tax regularity, adherence to the Electronic Tax Domicile (DTE) and Digital Accounting Bookkeeping (ECD) — items detailed in art. 15 of Coana Ordinance 187/2026, which waived the attachment of supporting documents already available in the RFB databases (the obligation to comply, of course, remains). Once admissibility is cleared, the certification criteria come in: the general ones of art. 14 (record of compliance with the legislation, financial viability, management of commercial records, information security, human-resources security and cooperation with the administration); the security ones of art. 15 of the IN, for AEO-S (security of the cargo, of the transport, of the physical facilities, of the business partners, training and crisis management); and the compliance ones of art. 16, for AEO-C — description and tax classification of the goods, rules of origin, foreign-exchange aspects, calculation base and customs valuation, immunities and tax benefits, indirect operations, professional qualification and customs risk management. The AEO-C Essential, consistent with its simplified design, waives items I to VII of art. 16 and concentrates the requirement on risk management and on the general criteria.

The certification process step by step — official deadlines, denial and maintenance

The certification runs entirely in the AEO System, within the Single Portal Siscomex (Pucomex), in a cycle that IN 2.318/2026 and Coana Ordinance 187/2026 organize into stages with defined deadlines:

The stages in detail

Everything begins outside the system: the mandatory self-assessment (art. 19) requires the company to compare its internal policies and procedures with the program’s criteria — and it is here that a well-done gap analysis decides the outcome. The application (art. 20) is formalized in the AEO System with acceptance of the Commitment Term, the appointment of the point of contact, the recording of the self-assessment result and the attachment of the documentary evidence; until the formal submission, the RFB does not access the data — but, once submitted, the information binds the party and the signatories (art. 21). Then comes the validation (art. 23): documentary analysis, searches in systems and a validation visit — physical, virtual or hybrid —, notified 30 days in advance. If the Tax Auditor points out required actions, the deadline to implement them is 30 days from the notice (art. 24, §1). The decision comes by decisory dispatch (art. 25) and, if granted, the certification is formalized by an Executive Declaratory Act in the Official Gazette (art. 27).

Why applications are denied

The most common cause of early denial is objective: the failure to meet an admissibility requirement authorizes the denial without analysis of the other criteria (art. 23, §4) — the application dies before the merits. Next come required actions not implemented within the 30-day deadline and a self-assessment inconsistent with the documentary reality, which undermines the credibility of the dossier. There is also the most severe bar: serious infractions, listed in Annex II of Coana Ordinance 187/2026, may prevent the certification — or the permanence — for up to 5 years. An appeal against the denial lies within 10 days, assigned to another team (EqOEA) and judged in 30 days, with a second and final instance at the AEO Center — also in 30 days.

Certified — now what? Maintenance is the second project

Certification on a precarious basis means continuous vigilance: permanent monitoring by a Tax Auditor (arts. 30 and 31), mandatory annual self-assessment (art. 19) and revalidation every 4 years, which may be brought forward depending on the monitoring result. Corporate reorganizations with a change of CNPJ (merger, spin-off, incorporation) require notice 90 days in advance and a new application, which proceeds with priority — failing to follow the rite may interrupt the enjoyment of the benefits (art. 29). Whoever becomes a habitual debtor must be excluded from the program (CL 225/2026, art. 36, §9). And the level of compliance demand is illustrated by a little-known obligation of Coana Ordinance 187/2026 (item 13.3 of the annex): upon identifying, in the operation, persons listed in restrictive government public lists, the exporter must report the fact to the RFB point of contact within 24 hours before the departure of the cargo. In parallel, any customs assessments that threaten the certificate’s compliance record deserve technical defense — including at the administrative level, up to the CARF.

AEO in the Tax Reform and in CL 225/2026 — from customs facilitation to a cash-flow benefit

Until 2025, the AEO business case was operational: time, predictability, reputation. CL 225/2026 changed the nature of the program by institutionalizing it as complementary law, alongside Confia and Sintonia, and by creating the first direct financial benefit in the history of the AEO: the deferred payment of the taxes due on import for the AEO-C Reference tier (art. 38 combined with IN 2.318/2026, art. 12). The law itself sets the payment by the 20th of the following month after the operation — the terms and conditions, however, still depend on an RFB normative act, so the benefit should be treated as provided for in law and pending operational regulation.

The AEO-C Essential and indirect export in the new system

The second link between the AEO and the Reform is in art. 82 of CL 214/2025: the suspension of IBS and CBS in the supply of goods to a trading export company, for the specific purpose of export, requires the trading export company to be, cumulatively, certified in the AEO Program, to have net equity of at least BRL 1 million (or equivalent to one time the suspended taxes, whichever is greater), to adopt the DTE, to keep digital accounting bookkeeping and to be in good standing. The suspension converts into a zero rate with the effective export; without exporting within 180 days of the invoice, the trading export company is liable for the taxes. The AEO-C Essential tier was created precisely to make this framing viable — it is worth recording, however, that there is already judicial controversy under way: 2026 decisions have been setting aside requirements of art. 82 on the ground that the export immunity is objective. Meanwhile, the rest of the redesign of consumption taxation — IBS, CBS and the Selective Tax, which also applies on the import of the goods it reaches — and the preservation of territorial regimes such as the Manaus Free Trade Zone only increase the value of a trusted customs position: whoever is treated as low risk crosses the transition with less friction.

The path to the Reference runs through tax. Access to the AEO-C Reference requires certification in the Confia Program or an A+ rating in the Sintonia Program (IN 2.318/2026, art. 17) — tax-compliance programs, not customs ones. In practice, the maximum customs benefit depends on the tax house being in order: governance of obligations, litigation under control and a record of compliance. It is the definitive welding between the company’s customs agenda and its tax agenda.

Illustrative case — an industrial importer heading toward the AEO-C Qualified

Illustrative case. The figures are examples and do not correspond to a specific client — they serve to show the TaxUp team’s working method.

The context

A consumer-goods manufacturer imports inputs by the sea and air modes, with about 35% of the operations by order — a predetermined orderer — and the rest on its own account. The erratic clearance lead time forced the company to keep a high safety stock, and episodes of the yellow channel added up relevant storage and demurrage over the year. Under the old rule of 85% direct operations, the AEO-C certification was out of reach; the company had not even reassessed the matter after the normative change.

The team’s reading

The TaxUp team’s diagnosis started from the point most people miss: with the 60% rule of art. 6, §2, of IN 2.318/2026, the 65% of operations on its own account made the company eligible. The gap analysis mapped the criteria of arts. 14 and 16 — admissibility in order (CNPJ, good standing, DTE, ECD), but weaknesses in records management, formalization of customs risk management and the tax-classification routine. Two technical points earned special attention: the documentation of the measurement of the own-account percentage over the last 24 months and the treatment of operations by order, which — by force of the sole paragraph of art. 11 — would have to be registered by DUIMP for the full enjoyment of the benefits in the condition of predetermined orderer.

The execution

Rather than filing and hoping, the work followed the reverse order: first the remediation of the gaps and the formalization of the policies, then the self-assessment consistent with the documentary reality, and only then the application in the AEO System with the complete dossier of evidence. In the validation, the required actions pointed out by the Tax Auditor were addressed within the 30 days. Certified as AEO-C Qualified by EDA in the Official Gazette, the company began to operate clearance on the water in the sea mode — registering the declaration before berthing — and structured the maintenance routine: annual self-assessment, monitoring of the indicators and the calendar of the four-year revalidation. The next step on the roadmap: to pursue the A+ rating in Sintonia in order to claim the AEO-C Reference and capture the tax deferral as a working-capital gain.

How the firm acts — from eligibility to revalidation

An honest diagnosis before filing

The most expensive mistake in AEO is filing too early. Because failing to meet admissibility allows denial without merits analysis — and serious infractions may lock the certification for up to 5 years —, the TaxUp team always begins with the eligibility and viability diagnosis: framing among the nine parties, measurement of the 60% rule for importers, checking of admissibility (good standing, DTE, ECD) and a frank reading of when the application should not yet be filed — low volume, a compliance record to remediate, a relevant open liability. For those who pass the filter, the modality and target tier are defined according to the profile: AEO-S for the logistics chain and exporters that value the MRAs; AEO-C Qualified for importers; Essential for trading export companies; Reference for those who can weld the customs agenda to the tax one.

Technical conduct of the full cycle

In the preparation phase, the firm carries out the gap analysis of the criteria of arts. 14 to 16, supports the formalization of policies and procedures and assembles the dossier of evidence — knowing that the information provided binds the company. In the certification phase, it conducts the application in the AEO System, follows the validation and the visit, responds to the required actions within the 30-day deadline and, if necessary, files the appeal in both instances. After the EDA, the recurring service that most people neglect remains: annual self-assessment, preparation of the four-year revalidation, timely communication of corporate reorganizations (90 days) and normative vigilance — the program has just changed its entire rulebook, and it will keep changing with the regulation of the deferral and the arrival of IBS/CBS on imports.

The bridge with the tax strategy

What sets the TaxUp approach apart is the integrated reading: the AEO is not a project isolated from the broker, it is a piece of the tax strategy. Access to the Reference tier runs through Confia or Sintonia A+; the trading export company’s IBS/CBS suspension runs through art. 82 of CL 214/2025; the deferral of art. 38 of CL 225/2026 is, in essence, an instrument of working capital — and it speaks directly to the work of recovery of tax credits and to the review of the burden levied on foreign trade. Within the Customs Law practice, the firm delivers both ends: the certification that reduces friction at the border and the tax intelligence that turns that position into a financial result.