The agency established the requirements, deadlines, and procedure to access the special penalty reduction regime
As of that date, the fine must not be final or, if it is, it must not have been paid.
Fines whose amount has been consolidated through adherence to a payment facilitation plan are also considered paid.
Taxpayers must comply with the omitted formal duties that led to the penalty by December 18, 2026, inclusive.
Taxpayers with fines under administrative, contentious-administrative, or judicial discussion must make a digital submission to access the benefit.
The procedure must be completed by December 18, 2026, inclusive, through the ARCA Digital Submissions web service. There, they must select the option “Special benefit for reduction of fines - Law 27.826”.
In the submission, they will need to identify the applicable penalty and provide the necessary information to individualize it. Among them, they must include:
Case number.
Resolution number.
Instrument through which the fine was determined or applied.
Other data that allows for the correct identification of the penalty.
The Revenue and Customs Control Agency (ARCA) regulated the Special Regime for Reduction of Fines, which establishes a 50% reduction in penalties for formal non-compliance. The measure applies to violations covered in articles 38, 39, and the unnumbered articles added following Law 11.683.
The benefit is aimed at certain groups of taxpayers and, in most cases, is applied automatically. However, those with fines under administrative or judicial discussion must complete a specific procedure before December 18, 2026.
The regime includes three groups of taxpayers who will be able to access the reduction of formal fines:
Micro, small, and medium enterprises: companies in tiers 1 and 2 that hold a valid MiPyME Certificate.
Individuals and undivided estates.
Non-profit entities.
The reduction operates by law, without the beneficiaries needing to make an additional submission. The exception applies to penalties that are under administrative, contentious-administrative, or judicial discussion.
The 50% reduction includes fines for non-compliance with formal duties related to obligations that have expired since January 2, 2026.
Additionally, certain conditions related to the date of the violation and the status of the penalty must be met:
The violation must have occurred before October 9, 2026.
