There is a short window — open since June 1 and closing at 7 p.m. on September 30, 2026 — in which the Office of the Attorney General of the National Treasury (PGFN) accepts settling federal active debt with a discount of up to 100% on interest and penalties. For a company carrying old liabilities, it is the chance to reach the Tax Reform turning point with its house in order, before the tax authority’s digitalization makes every registered debt far more visible.
PGDAU Public Notice No. 6/2026, based on Lei 13.988/2020, allows settlement by adhesion of debts entered as federal active debt of up to R$ 45 milhões. Adhesion is done on the Regularize portal until 30/09/2026 (7 p.m.). There are three main paths: payment capacity (discount of up to 100% on interest, penalties and legal charges, capped at 65% of the total, with a 6% down payment), hard-to-recover or unrecoverable debts and favored profiles such as individuals, MEI, ME, EPP and non-profit entities (cap of 70%, 5% down payment), and small value (50% paid in a lump sum, without the 65-70% cap). Whoever adheres must include all eligible registrations and withdraw the lawsuits, challenges and appeals concerning the settled debts. The TaxUp team treats the public notice as a pre-Reform cleanup instrument: settle the liability now, while the discount exists and before split payment exposes the default.
What PGDAU Public Notice No. 6/2026 is
Tax settlement is the agreement by which the taxpayer and the National Treasury end a dispute or pay off a debt through mutual concessions. It was governed in general terms by Lei nº 13.988/2020 and, since then, the PGFN has published periodic settlement-by-adhesion public notices — a modality in which the conditions come pre-defined and the taxpayer simply adheres to those that fit their profile, with no case-by-case negotiation.
PGDAU Public Notice No. 6/2026 is the 2026 vehicle of this policy. It applies to debts entered as federal active debt — that is, debts already collected by the PGFN, not those still at the Federal Revenue Service — whose total consolidated value is up to R$ 45 milhões. Adhesion is done exclusively through the Regularize portal.
The legal basis and the logic of the discount
The discount in a settlement is not a courtesy: it is calibrated by the recoverability of the credit. The Treasury starts from the premise that a hard-to-recover credit — with no guarantee, no debtor assets, with a low chance of success in enforcement — is worth more negotiated with a discount now than pursued for years in court. That is why the largest reductions fall on debts classified as unrecoverable or hard to recover, and on taxpayer profiles that the law treats as favored.
The modalities of the public notice
The public notice brings together distinct paths, and the right choice depends on the size of the debt, its recoverability classification and the taxpayer’s profile. The three that account for most corporate cases are in the table below.
| Modality | Who it is for | Discount and cap | Down payment and installments |
|---|---|---|---|
| Payment capacity | General rule — any taxpayer with a registered debt and payment capacity assessed by the PGFN | Up to 100% on interest, penalties and the legal charge, capped at 65% of the total debt value | Down payment of 6% of the total without discount, in up to 6 installments (12 in some cases); balance paid over a long term |
| Hard to recover or unrecoverable + favored profiles | Debts classified as hard to recover or unrecoverable; individuals, MEI, ME, EPP, non-profit entities and companies under judicial reorganization | Cap raised to 70% of the total debt value | Down payment of 5% of the total in up to 12 installments; balance over an extended term |
| Small value | Individuals, MEI, ME and EPP, for small-value registrations (in minimum wages), entered until 01/06/2025 | 50% on a lump-sum payment — its own structure, without the 65-70% cap | Lump sum (largest discount) or in installments, with percentages tiered by term |
Source: PGDAU Public Notice No. 6/2026 (gov.br/pgfn). Conditions simplified; the exact discount is assessed in the Regularize simulation.
Cutoff dates that change what is eligible
There are two distinct cutoff dates. For the general modalities, debts entered as active debt until March 3, 2026 qualify. The small-value modality, in turn, reaches registrations made until June 1, 2025. Confusing the two is a common mistake: a recent registration may fit one modality and not the other.
Step by step of adhesion on Regularize
The operation is entirely digital. The Regularize portal is available Monday to Friday, except national holidays, from 7 a.m. to 9 p.m. (Brasília time). The flow, from diagnosis to formalization, follows a clear sequence.
1. Diagnose before simulating
Before opening Regularize, it is worth listing all the company’s registrations in active debt and its related CNPJs, identifying each one’s recoverability classification and mapping which are under judicial or administrative dispute. This snapshot avoids the surprise of discovering, at the moment of adhesion, a forgotten registration that drags the whole operation along.
2. Simulate each modality
The portal itself allows simulating the conditions with no commitment. The simulation shows the consolidated value, the applicable discount, the down payment required and the number of installments. Since the same set of debts can fit more than one modality, simulating all the eligible ones is what reveals which delivers the lowest total cash outflow.
3. Formalize and pay the down payment
Once the modality is chosen, adhesion is formalized with the electronic acceptance of the terms. The deal, however, only consolidates with payment of the first installment of the down payment on its due date. Adhering and not paying the down payment freezes nothing — the adhesion simply does not take effect.
Who benefits most
The settlement is not equally advantageous for everyone. It pays off more for specific liability profiles.
Liability with a lot of accumulated interest and penalties
Since the discount applies to interest, penalties and the legal charge, the company that gains most is the one whose debt has aged — old registrations, in which the additions already exceed the principal. In those, writing off up to 100% of the additions represents a significant saving on the consolidated value.
Unrecoverable or hard-to-recover debts
Debts classified by the PGFN as unrecoverable or hard to recover access the raised cap of 70% and the reduced down payment of 5%. It is the scenario in which the Treasury concedes most, because the alternative — years of uncertain enforcement — interests it less than receiving part now.
Favored profiles
Individuals, MEI, microenterprises, small businesses, non-profit entities and companies under judicial reorganization receive more favorable treatment. For small-value registrations, the dedicated modality delivers 50% in a lump sum without the 65-70% cap.
The right question is not “how much do I owe,” but “how much of this liability is interest and penalties that the public notice can zero out.” It is in that fraction that the settlement gives cash back — and it is usually larger than the business owner imagines.
TaxUp Team · Tax Practice
The effect of withdrawing the lawsuits
This is the counterpart that demands the most analysis. By adhering, the taxpayer commits to withdrawing the lawsuits, challenges and administrative appeals that dispute the included debts, and to waiving the legal claims on which those measures are founded. In exchange for the discount, the company gives up fighting that credit.
Attorney fees and the risk of settling a good argument
Withdrawing a lawsuit can entail loss-of-suit attorney fees in favor of the opposing party or of the Treasury itself, depending on the case. And there is a subtler strategic risk: if the company has a robust legal argument, with favorable case law, settling means giving up an asset that might be worth more than the discount. The decision to include or not a disputed debt is, therefore, a calculation of the probability of success against the reduction offered — the realm of legal analysis, not of a spreadsheet.
The rule of the totality of registrations
The public notice bars partial adhesion: whoever chooses a modality must include all the eligible registrations in that profile. There are specific exceptions — registrations already guaranteed, in installments or with suspended enforceability may be left out. But the general rule is that you do not pick “the best registration” and leave the rest: either the eligible set goes in, or you do not adhere through that path.
In practice, this forces the company to look at the liability as a whole before deciding. Including a registration it did not intend to settle, or discovering late that the totality pulls in a debt under a good argument, are mistakes prevented at the diagnosis stage — not on the adhesion screen.
An illustrative savings example
Without pinning down an exact number — the real discount depends on the modality, the recoverability classification and the composition of the debt — it is worth illustrating the mechanics. Consider an old registration of R$ 1 milhão consolidated, of which about 60% is interest, penalties and the legal charge accumulated over the years, and 40% is principal.
| Component | Without settlement | Illustrative scenario in the settlement |
|---|---|---|
| Principal | R$ 400 mil (owed) | R$ 400 mil (kept) |
| Interest, penalties and charge | R$ 600 mil (owed) | High portion written off — the discount applies here |
| Discount cap | — | Cap of 65% or 70% on the total, per the modality |
| Down payment | — | 5% to 6% of the total, in installments |
| Cash effect | Full collection + enforcement | Reduced total outflow + long installment plan |
Merely illustrative example of the discount mechanics. The real values are assessed in the Regularize simulation.
The point of the example is not the number, but the logic: the larger the share of additions in the liability, the more the settlement gives back. A new debt, almost only principal, gains little; an old debt, soaked in interest and penalties, gains a lot.
The connection with the Tax Reform
Cleaning up the liability now is not just about taking advantage of a discount — it is about preparing the company for a more transparent tax authority. The Tax Reform planning window opens precisely because the transition changes how the State sees each operation.
Digitalization and split payment make the liability visible
The Reform brings the e-invoice adapted to the new model and split payment — a mechanism in which the tax is separated and collected at the very moment the operation is financially settled. With assisted assessment and collection at source, tax default becomes far more exposed: what today dilutes into ancillary obligations starts to appear in near real time. A company with active-debt pending items crosses the transition with its tax compliance under constant scrutiny.
Arriving clean at the turning point
The firm’s logic is straightforward: use the public notice window to zero out what can be zeroed out before the Reform comes into force. A clean compliance certificate, an equated liability and a predictable cash flow are preconditions for operating calmly in the new system — and for accessing credit, public tenders and the Reform’s regimes without the weight of an ongoing tax enforcement. It is the same reasoning that guides the firm’s tax litigation work: resolve the past to free up the future.
The timeline: what to decide by September 30
The window is short and does not renew automatically. Whoever leaves it to the last week runs two risks: the simulation not closing in time and the down payment not being paid on the due date — which invalidates the adhesion.
The recommended internal calendar
Reserving July and August for the diagnosis and simulation, leaving September only for formalization and payment of the down payment, keeps a safety margin. The last week of September tends to concentrate access to Regularize — relying on it is betting against the clock.
Pre-Reform cleanup playbook
An objective roadmap to guide the decision within the window.
| Stage | What to do | Expected result |
|---|---|---|
| 1. Map | List all registrations in active debt and the recoverability classification of each one | Complete picture of the eligible liability |
| 2. Separate | Identify which debts are under judicial or administrative dispute and the strength of each argument | List of what is worth settling or not |
| 3. Simulate | Run each eligible modality on Regularize and compare the total cash outflow | Optimal modality identified |
| 4. Decide | Weigh discount vs. waiver of arguments vs. loss-of-suit attorney fees | Reasoned decision to adhere or not |
| 5. Formalize | Adhere and pay the down payment with room to spare before the due date | Deal consolidated and liability regularized |
TaxUp roadmap for analyzing adhesion to PGDAU Public Notice No. 6/2026.
Risks and pitfalls
The settlement is a powerful tool, but it has pitfalls that cost dearly when ignored.
Missing the deadline
The window closes at 7 p.m. on 09/30/2026 and there is no guarantee of an extension. Earlier public notices have been extended, but counting on that is imprudent. Treating the date as firm is the safe stance.
Including the wrong registration
Adhering and dragging into the deal a debt backed by a winning argument means giving up an asset. On the other hand, forgetting an eligible registration may breach the totality rule and compromise the adhesion itself. Both mistakes stem from a lack of diagnosis.
Failing to keep up with the installments
The deal assumes the ability to meet the installments. Default leads to rescission of the settlement, with the debt returning to its original value — less what was paid — and collection resuming, now without the discount. Sizing the installment within the real cash flow is part of the decision, not a detail.
Frequently asked questions
What is PGDAU Public Notice No. 6/2026?
It is the PGFN public notice, based on Lei 13.988/2020, that offers settlement by adhesion of debts entered as federal active debt of up to R$ 45 milhões. Adhesion is done on the Regularize portal until September 30, 2026, at 7 p.m., with a discount of up to 100% on interest, penalties and the legal charge, according to the modality and the debt’s classification.
Who can adhere to the settlement under Public Notice No. 6/2026?
Taxpayers — individuals and legal entities — with debts entered as federal active debt, whose total consolidated value is up to R$ 45 milhões. The general modalities reach registrations made until March 3, 2026; the small-value modality reaches registrations until June 1, 2025. Favored profiles (individuals, MEI, ME, EPP, non-profit entities) have expanded conditions.
What is the discount under the payment-capacity settlement?
Up to 100% on the value of interest, penalties and the legal charge, with the total discount capped at 65% of the consolidated debt value under the general rule. For hard-to-recover or unrecoverable debts and favored profiles, the cap rises to 70%. The effective discount depends on the composition of the debt and is only assessed in the Regularize simulation.
What is the adhesion deadline and how does it work?
The window opened on June 1, 2026 and closes at 7 p.m. (Brasília time) on September 30, 2026. The Regularize portal operates Monday to Friday, except national holidays, from 7 a.m. to 9 p.m. The adhesion only consolidates with payment of the first installment of the down payment on its due date — adhering without paying does not make the deal effective.
Do I need to withdraw the lawsuits to adhere?
Yes. Adhesion requires withdrawing the lawsuits, challenges and administrative appeals that dispute the included debts, and waiving the arguments on which those measures are founded. There may be loss-of-suit attorney fees on withdrawal. For that reason, debts backed by favorable case law should be assessed carefully before entering the deal.
Can I settle only some of my debts?
As a rule, no. The public notice requires including all the eligible registrations in the chosen modality, with partial adhesion barred. There are specific exceptions for registrations already guaranteed, in installments or with suspended enforceability. That is why the diagnosis of the complete liability must precede the decision to adhere.
What is the small-value modality?
It is a dedicated path for individuals, MEI, ME and EPP, aimed at small-value registrations (measured in minimum wages) made until June 1, 2025. It offers a 50% discount on a lump-sum payment, with a tiered structure for installments, and is not subject to the 65-70% cap of the other modalities.
What happens if I do not pay the installments of the deal?
Default leads to rescission of the settlement. The debt returns to its original value (less what was paid), the discount is lost and collection resumes, including tax enforcement. That is why it is essential to size the installment within the real cash flow before adhering.
Why clean up the liability now, before the Tax Reform?
Because the Reform brings the digitalization of invoices and split payment, which collects the tax at the very financial settlement of the operation. This makes tax default far more visible in near real time. Arriving at the transition with the active debt equated and the compliance certificate clean avoids constant friction with the tax authority and frees up access to credit, public tenders and the Reform’s regimes.
Does the settlement apply to debts still at the Federal Revenue Service?
Not directly. PGDAU Public Notice No. 6/2026 reaches only debts already entered as federal active debt, collected by the PGFN. Debts still at the Federal Revenue Service, under audit or in another phase, may require a different instrument. The statement of pending items on Regularize is the starting point to know what is eligible.
Clean up the liability before the Reform comes into force
The TaxUp team diagnoses the active-debt liability, simulates the modalities of PGDAU Public Notice No. 6/2026 and calculates the cash outflow of each scenario — to decide, on a legal basis, what is worth settling before the window closes on September 30.
Whoever is structuring the complete transition will find the overview in the firm’s Tax Reform solution, and the detail of the instrument on the settlement with the PGFN page. Cleaning up the liability is part of the same Tax Reform planning window that guides the turning point.
Sources: PGDAU Public Notice No. 6/2026 (gov.br/pgfn — public notice page + Regularize portal); Lei 13.988/2020. Informational content; not legal advice.
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