Confia Program: how to prepare your company?

The Confia Program marks an important change in the relationship between the Federal Revenue Service and large taxpayers. The logic is no longer just reactive, based on inspection, assessment and litigation, but instead values a cooperative relationship model, with more transparency, tax governance and anticipated treatment of risks.

For large companies, economic groups, industries, importers and expanding businesses, the issue should not be seen just as a tax rule. Confia is a clear sign of how the IRS intends to assess the maturity of controls and the quality of the information declared, accounting consistency and tax management capacity.

Even if your company is not yet among the taxpayers eligible for the first edition, understanding the Confia Program helps you anticipate a trend: increasingly, tax compliance will be treated as a strategic asset, with a direct impact on cash, risk, reputation, access to certificates and predictability for growth.

Quick summary: what your company needs to know about the Confia Program

• Confia is the Federal Revenue Service's Tax Cooperative Compliance Program.
• The first edition was regulated by RFB Ordinance No. 621/2025, with rules on vacancies, deadlines and conditions for applying for certification.
• The original application deadline was from January 26, 2026 to February 20, 2026, then extended to March 20, 2026 by the RFB Ordinance No. 650/2026.
• The 2026 edition offered 40 places and received 51 applications for certification, according to the IRS.
• The selection involves quantitative criteria, such as economic size, and qualitative criteria, such as governance, tax compliance, internal controls and management capacity.
• For the company, the topic relates to tax compliance, CND/CPEND, ancillary obligations, risk matrix, decision documentation and tax governance.

What is the Confia Program?

The Confia Program is an initiative by the Federal Revenue Service to create a new relationship model with large taxpayers, based on cooperative tax compliance. In practice, this means that companies with a high tax impact and complex operations can go through a structured process of certification, dialog and monitoring with the tax authorities.

The proposal is to reduce dependence on a purely litigious relationship. Instead of the company only discovering tax problems when it receives an assessment, the model seeks to encourage transparency, the exchange of qualified information and the prior treatment of relevant inconsistencies.

This does not turn the Revenue Service into a consultant for the company, nor does it eliminate the need for its own controls. On the contrary: Confia increases the importance of a robust structure of Accounting and tax BPO, The program also includes tax compliance, review of obligations, document management and tax governance. Anyone entering a program of this kind needs to demonstrate maturity, not just intention.

What does RFB Ordinance No. 621/2025 define?

RFB Ordinance No. 621/2025 opened the first edition of the Confia Program and established the operational rules for applying for certification. Among the main points, the rule defined the number of vacancies, the application period and the conditions applicable to the selection process.

The first edition was structured to select taxpayers with great economic relevance and the ability to demonstrate fiscal governance. According to the IRS, applications are analyzed based on RFB Normative Instruction No. 2,295/2025 and RFB Ordinance No. 621/2025, considering quantitative and qualitative criteria.

Among the requirements published by the Revenue Office to apply for a vacancy are: classification as the largest special taxpayer, gross revenue declared in the Real Profit of at least R$ 2 billion, declared tax debts of at least R$ 100 million, degree of indebtedness less than or equal to 30%, valid CND or CPEND and response to the Self-Assessment Questionnaire.

Translation into business routine: Confia doesn't just look at invoicing. It requires the company to prove organization, traceability, consistency and the ability to explain its tax decisions.

Rodrigo Ribeiro 

What were the deadlines for the Confia Program?

The first edition of Confia became operational in 2026. The original deadline for applying for certification opened at 8 a.m. on January 26, 2026 and ran until 11:59:59 p.m. on February 20, 2026, Brasília time.

The IRS then extended the deadline until March 20, 2026 by means of RFB Ordinance No. 650 of February 12, 2026, published on February 19, 2026. The justification was practical: large companies usually depend on internal approval cycles, with the participation of tax, legal, financial, executive and compliance areas.

This detail is important because it reveals a management message. The decision to join a cooperative compliance program is not just a fiscal one. It involves corporate governance, risk assessment, executive authorization, alignment between areas and the ability to sustain commitments to the tax authorities.

Who is impacted by the Confia Program?

The direct impact falls on large taxpayers, especially Real Profit companies, economic groups with significant revenue and tax debts, industries, multinationals, importers, companies with complex operations and organizations classified by the Revenue Department as special legal entities.

But the indirect impact is broader. Growing companies, even if they don't yet fit the criteria of the first edition, should follow the movement. Programs like Confia tend to raise market standards on tax controls, reconciliation of statements, documentation of decisions and risk prevention.

In practice, a company that wants to grow, attract investment, expand international operations, take part in tenders, reduce litigation or keep negative certificates available needs to treat tax governance as a routine. You can't leave everything to the eve of an inspection, an audit or a corporate transaction.

Why does Confia matter for cash, risk and growth?

Tax is not just a legal obligation. For larger companies, taxes affect cash flow, margins, investment capacity, predictability of results and institutional reputation. A recurring error in accessory obligations, an inconsistency between SPED and calculations, or the loss of a CND can put the brakes on important decisions.

Companies that don't have mature tax controls are more exposed to assessments, fines, withholding of certificates, administrative disputes, lawsuits and audit noise. In addition to the direct cost, there is the invisible cost: management time, financial insecurity, loss of predictability and wear and tear with stakeholders.

On the other hand, a well-organized tax structure improves the reading of the business. The company can identify risks before they become liabilities, correct inconsistencies in advance, review tax credits, support decisions with adequate documentation and integrate the tax area into strategic planning.

This is where Confia should be read with a CFO's eye: tax compliance is not an isolated cost center. When done well, it protects cash, reduces surprises, improves governance and creates conditions for more predictable growth.

What risks does the company run by ignoring this trend?

The first risk is missing out on opportunities for cooperative relations with the IRS. For companies that meet the requirements, not being prepared could mean missing out on a significant window for certification and qualified dialog with the tax authorities.

The second risk is continuing to operate with poor visibility of tax obligations. This happens when the company submits returns, calculates taxes and responds to inspections without an integrated view of its own data. In complex businesses, this model increases the chance of divergences between accounting, tax, finance, legal and operations.

The third risk is reputational. Companies with recurring tax liabilities, unstable certificates or poorly managed litigation may face more difficulty in commercial negotiations, credit operations, audits, sales processes, corporate reorganizations and expansion into new markets.

In short: ignoring Confia is not just ignoring a rule. It's ignoring a sign that the tax compliance ruler is rising.

What opportunities does the Confia Program create?

The main opportunity is to turn the tax area into a source of predictability. Companies that structure tax governance are able to map risks, document positions, anticipate inconsistencies and have a better dialogue with internal audits, external audits, councils and supervisory bodies.

Another opportunity is to reduce litigation. The clearer the company's tax position, the less room there tends to be for surprises. This doesn't mean eliminating all tax discussions, because complex companies naturally face interpretative issues. 

It means having method, evidence and governance to back up every decision.

There are also efficiency gains. A good Tax BPO, This, combined with technology, periodic reconciliations and a review of ancillary obligations, reduces rework and improves the quality of the information used by the leadership.

For the entrepreneur and the CFO, this maturity facilitates growth decisions. The company now knows better where the risks lie, what adjustments need to be made and what figures can be used with confidence in planning, budgeting, fundraising, expansion and reorganization.

How to prepare your company for the Confia Program?

Even if the company isn't going to apply immediately, the preparation process is similar to what any mature organization should do to reduce tax exposure. The difference is that Confia makes this need more evident.

1. Make a complete tax diagnosis

The first step is to understand the company's real situation. This includes reviewing the tax regime, assessments, ancillary obligations, credits, debits, installment payments, administrative proceedings, legal proceedings, certificates, tax classification of operations and consistency between accounting and tax.

Real Profit companies need special attention because the calculation depends on more detailed accounting and tax controls. At this point, it is also worth reviewing whether the information used for IRPJ, CSLL, PIS, COFINS and other taxes is reconciled with financial statements, SPEDs and internal reports.

2. Reconcile tax returns and bases

A common mistake is to look at each obligation in isolation. The IRS cross-references information from different bases, and inconsistencies between declarations can lead to exposure even when the company believes it is paying correctly.

For this reason, preparation must include reconciliation between ECD, ECF, EFD-Contribuições, EFD ICMS/IPI, DCTFWeb, invoices, payroll, PER/DCOMP, credit controls and internal systems. The central question is simple: does the data tell the same story?

3. Regularize CND and CPEND

The negative or positive certificate with negative effects cannot be treated as an emergency document. It needs to be monitored continuously. Companies that depend on credit, relevant contracts, tenders, corporate operations or imports know how an unstable certificate can affect cash and operations.

In Confia's logic, fiscal regularity is an indication of maturity. If the company only discovers pending issues when it needs the certificate, there is a process failure.

4. Set up a tax risk matrix

The risk matrix helps to organize issues by financial impact, probability, area responsible, supporting documentation, action plan and status. It should include assessment risks, accessory obligation risks, interpretation risks, operational risks and risks related to infraction notices or ongoing discussions.

This matrix should not be left to the tax department alone. For it to work, it needs to interact with legal, finance, accounting, purchasing, sales, foreign trade, technology and executive leadership.

5. Document relevant tax decisions

Complex companies make tax decisions all the time: use of credits, classification of income, treatment of incentives, withholdings, operations between group companies, imports, exports, transfer pricing, tax benefits and reorganizations.

The problem is that many decisions are scattered in emails, spreadsheets or individual memories. To reduce risk, the company needs to keep clear documentation: what the decision was, what technical basis was used, who approved it, which areas participated and when the understanding should be revised.

6. Integrate tax governance and automation

Automation doesn't solve bad governance, but it does speed up well-designed governance. The ideal is to combine integrated systems, reconciliation routines, audit trails, defined responsible parties and compliance indicators.

Companies that still operate with excessive manual controls tend to have more rework, a higher risk of error and less responsiveness. In a cross-data environment, speed and quality of information make a difference.

Executive checklist to prepare the company

What changes for companies that are not yet Confia members?

For growing medium-sized companies, Confia works as a benchmark of maturity. Perhaps the company doesn't yet have the turnover, volume of debts or framework to participate, but it can now start to build a tax structure compatible with a larger business.

This point is especially relevant for companies that intend to grow by acquisition, internationalize operations, increase imports, open new units, attract investors or professionalize management. The later fiscal governance enters the agenda, the more expensive it tends to be to correct the past.

Expanding companies should treat the issue as preparation for the next phase of the business. This includes reviewing processes, organizing documents, improving indicators, reducing dependence on improvised controls and seeking specialist support in accounting, tax and tax planning.

How can CLM Controller help?

Preparing for a higher standard of tax compliance requires method. It's not enough to know that a new standard exists; you have to turn this requirement into a business routine.

CLM Controller can support your company with tax compliance diagnostics, reviewing ancillary obligations, tax and accounting reconciliation, assessing tax compliance, structuring a risk matrix and improving governance processes.

The aim is to provide clarity for the leadership: where the risks lie, which adjustments are a priority, which controls need to be strengthened and how to reduce fiscal exposure without holding back growth.