RADAR Siscomex: the license to import and export.
Modalities, limits, financial capacity — and how to move up from Limited to Unlimited.

What the RADAR Siscomex is — the license to operate in foreign trade

In foreign-trade jargon, “obtaining the RADAR” has become synonymous with being cleared to import. Technically, the RADAR (Registry and Tracking of the Activity of Customs Intervenors) is the license of the individual or legal entity to act in foreign trade before the Federal Revenue Service. It is the precondition for everything: without an active license, Siscomex simply will not allow an import or export declaration to be registered. Whoever handles the day-to-day of the operation — the representative — must also be accredited, which is an act distinct from the company’s license.

The rule that governs the matter is RFB Normative Instruction 1.984/2020, of 27/10/2020, effective since 01/12/2020 (art. 65). It repealed RFB Normative Instruction 1.603/2015 and other old rules of the regime (art. 64) and, in November 2025, was broadly reformed by RFB Normative Instruction 2.292/2025 — the most relevant change to the RADAR in a decade, which we address in detail below.

Legal basis: what authorizes the Revenue Service to require the license

The legal basis of the license does not lie in a specific “RADAR” law, but in the competence assigned to the customs administration. The preamble of RFB Normative Instruction 1.984/2020 rests on art. 16 of Law 9.779/1999 — which authorizes the Federal Revenue Service to set requirements, conditions and registration for those acting in foreign trade — and on art. 809, §2, of Decree 6.759/2009 (the Customs Regulation), in addition to art. 46, §7, II, of Law 12.715/2012. It is a point the TaxUp team insists on fixing, because a lot of material circulates — including some manuals and articles — attributing the basis of the RADAR to art. 80 of Provisional Measure 2.158-35/2001. That provision deals with a distinct matter: art. 80, I, of Provisional Measure 2.158-35/2001 is restricted to importation on behalf and to the order of a third party, not to the general licensing regime. Citing the correct legal basis matters when the discussion turns judicial.

Terminological note. The system that today operationalizes the request is called Habilita, within the Siscomex Single Portal. “RADAR” is the established name of the registry; “Habilita” is the system through which one applies. In this text, we use both in their current market sense.

The three modalities: Express, Limited and Unlimited

The heart of the RADAR are the licensing modalities, defined in art. 16 of RFB Normative Instruction 1.984/2020. They determine how much a company may import per semester. There are three — and the initial classification is, as a rule, automatic:

• Express — reserved for publicly traded corporations and their wholly owned subsidiaries, public enterprises and mixed-capital companies. It is the modality of the large listed companies and of state-owned entities; it has no value limit (art. 17, §4).
• Limited — for those with an estimated financial capacity of up to USD 150 thousand per consecutive six-month period. It is split into two import sublimits: up to USD 50 thousand (estimated capacity up to USD 50 thousand) and up to USD 150 thousand (estimated capacity between USD 50 thousand and USD 150 thousand). It is the gateway for most companies.
• Unlimited — for those with an estimated financial capacity above USD 150 thousand per semester. As the name says, it does not subject the company to any import ceiling.

One clarification that avoids error: the AEO certification does not appear in art. 16 as a RADAR modality. The rule “AEO grants Express RADAR” belonged to the repealed RFB Normative Instruction 1.603/2015 and did not survive RFB Normative Instruction 1.984/2020. Today, AEO and RADAR are distinct programs — the AEO is governed by RFB Normative Instruction 2.154/2023 and does not, in itself, change the company’s licensing modality. We address the AEO on its own page: Authorized Economic Operator.

Bringing it all together into a view of who fits where:

Which RADAR modality does your company need?

The practical question is not “I want to import”, but “how much do I intend to import per semester, and in what way”. The decision path of RFB Normative Instruction 1.984/2020 can be read as a simple tree, always remembering that the limit is measured by the customs value — the value of the goods plus insurance and freight up to the port or airport of unloading (CIF basis), not the value on the supplier’s invoice.

The individual’s case

The individual is exempt from licensing in their own name (art. 19, I), provided the operations are limited to professional activity, own use and consumption or personal collections, without resale (art. 4, §3). They may even act as their own representative (art. 15, §1, V). Watch out for a common trap: the rural producer who is an individual but holds a CNPJ is not exempt — they become subject to the licensing regime like any legal entity.

Those who export and those who operate on behalf and to the order

Because exports have no ceiling, whoever only exports need not worry about the modality value. Some operations, however, fall outside the limit even in Limited (art. 17, §2): export, internalization in the Manaus Free Trade Zone, importation on behalf and to the order with respect to the importing legal entity, and importation without exchange coverage. Others count within the limit (art. 17, §3), such as on-behalf-and-to-the-order with respect to the acquirer and to-order with respect to the ordering party. Structuring the operation knowing what does and does not enter the ceiling is part of the planning for those operating near the sublimit.

How to request the RADAR for imports — the step by step

The licensing request follows a flow defined in arts. 20 to 24 of RFB Normative Instruction 1.984/2020. In most cases it is resolved by the system itself, with automatic approval; it only falls into human analysis when there is something to verify. The path, in practice, is this:

A few points that change the experience of those applying:

• Admissibility requirements (art. 21, as amended by RFB Normative Instruction 2.292): DTE enabled, CNPJ in “active” status (or “suspended” only in the case of art. 37, V, of RFB Normative Instruction 2.119/2022) and CPF “regular” or “pending regularization” of the individuals entitled to represent the company. If any of these items fails, the system bars the request before any analysis.
• Verification and cure notice (art. 24, §2): when the request falls into analysis, the Revenue Service may issue a documentary verification notice with a non-extendable 10-day period for cure. Each partial cure generates a new notice, with a fresh 10 days. Without full cure, the request is dismissed (art. 25) — which does not prevent a new request.
• Accreditation of the representative: the license belongs to the company; whoever operates in the system (partner, employee with an exclusive tie, customs broker with an active registration) must be accredited separately, within the roster of art. 15, §1.

The extractive block of the step by step — for those who just want the summary — is in the frequently asked questions section, at the end of this page.

How the Revenue Service calculates your financial capacity

The Limited and Unlimited modalities depend on a number that the Revenue Service estimates automatically: the company’s financial capacity, in dollars, per six-month period. It is this value that defines the sublimit (USD 50 thousand or USD 150 thousand) and says whether the company already enters as Unlimited. The formula is in art. 18 of RFB Normative Instruction 1.984/2020, detailed by Coana Ordinance 72/2020.

In plain terms, the calculation takes the greater of two sums of taxes and contributions paid:

• the sum of IRPJ + CSLL + PIS/Pasep + COFINS; or
• the Social Security Contribution (on employees and individual contributors).

The amount paid in the current year plus the four previous calendar years is considered, and the total is divided by the average dollar exchange rate of the five previous calendar years. Left out are the taxes declared and not paid, those under installment plans and those assessed ex officio — only what the company actually paid enters.

The logic is to use the company’s fiscal footprint as a proxy for size: whoever pays more tax moves more and, presumably, has the backing to import more. The side effect is well known — a new company, or one with a small payroll and little taxable profit, tends to land in the USD 50 thousand Limited modality, even if the business already has far greater import demand. It is precisely this mismatch that the estimate review resolves, as we will see.

The good news: this is an estimated figure, not a rigid limit on the company’s real size. When the automatic estimate does not reflect the effective capacity, the law provides the path to review it — without having to wait five years of fiscal history.

Limited x Unlimited RADAR: how to raise the limit (estimate review)

The question that reaches the firm most often is straightforward: how to move from Limited to Unlimited — or to climb from the USD 50 thousand sublimit to the USD 150 thousand one? The instrument is the review of the financial-capacity estimate, provided for in arts. 29 and 30 of RFB Normative Instruction 1.984/2020. There are two paths:

• Review through Habilita (art. 29): the system itself recalculates the estimate based on the Revenue Service’s internal data, when they already exist. It is the automatic path, without attaching any document.
• Review by digital case (art. 30): the company presents the value in reais that it understands to be its capacity, with grounds, supporting documentation and proof of operational capacity. It is the route for those who want to demonstrate a size that the standard calculation does not capture.

Which justifications does the Revenue Service accept in that demonstration? The official manual and Coana Ordinance 72/2020 admit, among others: capital available in current assets, tax exemptions enjoyed and payments via DAS (Simples Nacional) exceeding the automatic estimate. In other words: a Simples company, with little IRPJ/CSLL recorded, may use what it actually paid under the DAS to pull the estimate upward.

There is an important protective safeguard in the company’s favor: under art. 29, §2, reclassification is not carried out if it would result in a more restrictive modality or a lower limit than the one the company already has. Requesting a review, therefore, does not expose the company to the risk of being downgraded through this path — a review on request can only maintain or improve the situation.

The analysis process follows the same timing rite as the request (art. 56, as amended by RFB Normative Instruction 2.292): the Revenue Service reviews within 10 days from the filing into the digital case, with automatic grant by lapse of the period if the analysis does not come out (art. 56, §1); each cure restarts the count (§3). The cure rules of the review mirror those of the request (art. 31, §§3-4), with the same non-extendable 10-day period.

Strategy note. Specialized firms argue the thesis that the quantitative limit of the Limited modality is questionable in light of free enterprise and legality, warranting a writ of mandamus for reclassification in concrete cases. It is a litigation route, alternative to the administrative channel, which the TaxUp team assesses case by case — without promising a result, which depends on the Judiciary.

How much a RADAR Siscomex costs — and why the Siscomex Fee is another thing

The answer that surprises whoever asks: RADAR licensing is free. There is no government fee to obtain the RADAR — the request in the Habilita system has no emolument cost. What the company may pay are private fees of a customs broker or of legal advisory that conducts the request, the classification and the documentation. That is a price for a service, not a fee of the State.

The most common confusion is mixing up the license with the Siscomex Utilization Fee — the “Siscomex Fee”. They are distinct things: the Siscomex Fee does not belong to the RADAR; it is charged on the registration of each declaration of import (DI or Duimp), operation by operation, after the company is already licensed. The values in force in 2026 (ME Ordinance 4.131/2021 and RFB Normative Instruction 2.024/2021, effective since 01/06/2021) are:

In other words: the Siscomex Fee value depends on how many additions the declaration has, and the per-addition share is regressive — it is not a fixed BRL 38.56 per addition. The more items grouped, the lower the marginal cost of each addition.

Theme 1085 of the STF — and why there is nothing left to recover

There is a relevant judicial chapter in this story. In Theme 1085 (RE 1.258.934/SC, judged in 2020, with general repercussion), the STF declared unconstitutional the roughly 500% increase in the Siscomex Fee made by MF Ordinance 257/2011 (which had taken the values to BRL 185.00 per declaration and BRL 29.50 per addition), for defective legislative delegation — the Executive may only update the fee by official correction indexes, not raise it freely. It was this thesis that anchored the current basis of BRL 115.67 / BRL 38.56, calculated by monetary correction over the original values of Law 9.716/1998.

A point the TaxUp team insists on making clear: the window to refund amounts overpaid in the past, arising from Theme 1085, has already lapsed by the passage of the period. It is neither honest nor technical to offer today “recovery of the Siscomex Fee” as if there were a credit to reclaim — that episode is closed. What remains useful from Theme 1085 is the parameter: the fee cannot be raised by an infralegal act beyond the correction indexes, which frames any future adjustment.

The 2025 reform and the automatic delicensing of 2026

The RADAR went through the biggest update of the decade in November 2025. RFB Normative Instruction 2.292/2025, of 18/11/2025 (DOU 19/11/2025), came into force on the date of publication (art. 3), amended dozens of provisions of RFB Normative Instruction 1.984/2020 and fully repealed RFB Normative Instruction 2.098/2022 (art. 2, II). Among the articles amended or added are arts. 4, 5, 14, 15, 19, 21, 23, 24, 25, 29, 30, 31, 32, 39 (new §7), 43, 44, 46, 49, 54, 56 and 59 — a fine-tooth comb that tightened fraud control and reorganized deadlines and requirements.

Two novelties deserve highlighting for the company’s compliance:

• Power to summon on the origin of the funds (art. 39, §7): the Revenue Service may summon the company to prove the origin, the availability and the effective transfer of the funds employed in the operations — a clear reinforcement of the anti-fraud axis.
• Tightened ex officio review (arts. 43-44): opening of a Procedure for the Inspection of Customs Fraud Combat (RFB Normative Instruction 1.986/2020), communication to Coaf and Bacen, tax representation for criminal purposes and the possibility of nullity, inaptitude or cancellation of the CNPJ.

The automatic delicensing that began on 15/01/2026

The operational milestone that most impacts the day-to-day was announced in Siscomex Systems Notice No. 013/2025 (published on 02/12/2025) and took effect on 15/01/2026: the license came to require, on a continuous basis, the maintenance of the DTE and the regularity of the registration status of the company’s CNPJ and of the CPF of the representatives and of the ownership structure. Whoever becomes irregular is delicensed and rendered unable to operate until they regularize (operationalization of art. 46, I). It is no longer a one-off control at the moment of the request: it has become permanent verification.

Add to this the delicensing for inactivity of art. 47: a company that goes 12 months without performing acts in the systems is automatically delicensed. Each operation renews the count; relicensing is done by a new request in Habilita. The effect of delicensing (art. 48) is broad — it delicenses the responsible parties, deaccredits the users and cancels links in the Pucomex. For those who import sporadically or seasonally, it is a concrete risk of finding the RADAR “switched off” right on the eve of the next import.

Lost the RADAR? Relicensing, ex officio review and appeal

Being licensed is not a permanent state — it must be maintained. Beyond delicensing for inactivity (art. 47) and the automatic one for registration status (from 15/01/2026), RFB Normative Instruction 1.984/2020 provides for other scenarios of loss of the license that the importer needs to know.

Under art. 46, the Revenue Service may delicense the company at any time for failing to meet the admissibility requirements, with a notice to the DTE or an electronic edict on the RFB website (§1), and also in the course of an ex officio review. A new §5 (added by RFB Normative Instruction 2.292) provides for direct delicensing when the CNPJ is inapt, cancelled or void. The capacity estimate, in turn, is reviewable ex officio at any time (art. 18, sole paragraph) — but this ex officio review is a path distinct from the review on request, and does not carry the protective safeguard of art. 29, §2.

Relicensing after being delicensed

Relicensing is done, depending on the case, by a new request in Habilita or by a regularization analysis (art. 49), which the Revenue Service examines within 30 days (art. 57). Once the pending issue that led to the delicensing is regularized — updating the CNPJ, curing the registration of the representatives, resuming operations — the company recovers its fitness to operate.

Appeal against the denial

If the request or the review is denied, an appeal lies (art. 58): 10 days from notice, addressed to the Tax Auditor, with a reconsideration judgment within 5 days; if not reconsidered, the head of the unit decides within 30 days. Once that channel is exhausted, the decision is final (art. 59). It is at this point that technical work makes a difference — a denial for insufficient documentation or for a restrictive reading of financial capacity often reverses with proper grounds, or, in cases of a limit manifestly incompatible with the real size, through the judicial route of the writ of mandamus.

To check the status of any company, the Revenue Service itself maintains a public search of licensed parties by CPF/CNPJ, useful both to verify one’s own status and to check the license of a commercial partner before closing an operation.

Update note (July 2026). The Federal Revenue Service submitted to public consultation, between 18/06/2026 and 17/07/2026 (Brasil Participativo platform), the proposal for a new Normative Instruction that will consolidate the rules of the import customs clearance. In parallel, the migration schedule from the DI to the Duimp advances in 2026 (switch-on completed on 08/06/2026; DI switch-offs on 31/08 and 01/12/2026, per the official schedule subject to revisions). None of these changes alters, for now, the licensing regime of RFB Normative Instruction 1.984/2020 — but the TaxUp team monitors it to revise this page when there is a new rule.