Has your company lost its authorization to operate on Siscomex? The first step is to determine whether the authorization was revoked due to inactivity, an ex officio review, a suspension, or a cancellation. Each situation requires a different procedure.
Discovering that the company is barred from operating in Siscomex can disrupt imports, exports, and other foreign trade-related processes. Despite the urgency, submitting a new application without knowing the cause of the problem may further delay the resolution of the issue.
In this article, you'll learn why a company might be deactivated, how to check its status, and what steps to take to resume operations.
What is Siscomex authorization?
Registration in the Integrated Foreign Trade System (Siscomex), commonly known as Radar Siscomex, allows individuals and legal entities to conduct transactions within Brazil’s foreign trade systems.
Except in cases where an exemption is provided for by law, the company must be authorized to conduct import or export operations.
The Federal Revenue Service classifies legal entities as Express, Limited, or Unlimited, based on the characteristics of the taxpayer and, when applicable, its estimated financial capacity.
It is important to understand that the license is granted on a provisional basis. This means that the Federal Revenue Service may review the company’s status at any time.
Siscomex Radar Disabled: What Does This Mean?
The suspension prevents the company from continuing to conduct transactions in the foreign trade systems.
In addition, it can cause:
removal of officials affiliated with the company;
revocation of authorized users' access;
cancellation of certain links on the Single Foreign Trade Portal;
interruption of import or export operations;
logistical, contractual, and financial delays.
Before taking any action, you must confirm the type of incident. Deactivation, suspension, and cancellation are not the same thing and may require different procedures.
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What are the causes of deactivation in Siscomex?
A company may be deactivated for various reasons. Among the most significant reasons are inactivity in foreign trade systems and irregularities identified during an ex officio review.
Inactivity for more than 12 months
A goods declarant may be automatically deactivated if they have not performed any transactions in the foreign trade systems for 12 months.
The count includes:
the date the license was issued, when no transactions have been recorded; or
the date of the most recent foreign trade transaction recorded in the systems.
Therefore, it is incorrect to state that a license is automatically suspended after six months without imports or exports. According to current regulations, the inactivity period required for automatic suspension is 12 months.
In that case, the company may submit a new application for certification.
Ex officio review
The Federal Revenue Service may also review the company's registration and request documents, information, or clarifications.
Disqualification may occur, for example, when registration issues are identified, when the requirements for qualification are not met, or when circumstances prevent the Internal Revenue Service from confirming the company’s existence and operational capacity.
Depending on the case, the rectification should take place within the administrative review process itself.
Irregular CNPJ Status
The company’s registration status must also be verified. CNPJ registrations classified as “ineligible,” “canceled,” or “null” may result in disqualification, depending on the context and the corresponding administrative procedure.
Problems with guardians and users
In some situations, the company remains authorized, but the legal representative, authorized representative, or user is unable to access or operate the systems.
Therefore, it is important to determine whether the problem lies with the company's license or simply with a specific individual's accreditation.
How can I find out why Radar was disabled?
A correct diagnosis prevents the creation of unnecessary work orders and reduces the risk of new requirements.
Follow these steps:
1. Check the status of your license
Check the company's status in the Habilita System and on the Federal Revenue Service's official channels.
Please confirm:
whether the company is authorized or not;
the registered category;
the operating limit, if applicable;
the existence of messages, requirements, or restrictions;
the date of the last transaction performed.
2. Check e-CAC
Visit the Federal Revenue Service’s Virtual Service Center and search for cases, summonses, orders, and notices related to Siscomex registration.
It is also important to check the company's email inbox. Failure to respond to a message could jeopardize the progress of the process.
3. Verify your registration and tax status
Check out the following points, among others:
CNPJ registration status;
information on the company's ownership and management structure;
registration status of the responsible parties;
tax returns and ancillary obligations;
address and contact information;
corporate documents;
financial transactions consistent with the intended operations.
The existence of an outstanding tax matter does not, in and of itself, mean that the registration will be automatically canceled. It is necessary to verify whether this outstanding matter is related to the Federal Revenue Service’s decision.
4. Identify the type of incident
Find out if there was:
automatic deactivation due to inactivity;
disqualification resulting from an ex officio review;
suspension;
cancellation;
user authentication issue;
reduction or change in the operational limit.
This identification will determine the next step.
How do I restore my license status in Radar Siscomex?
The procedure depends on the cause of the disability.
Disabling Due to Inactivity
If a company is automatically de-registered for failing to take any action for 12 months, a new application for registration may be filed.
The request is typically submitted through the Habilita System. The request may be processed automatically or selected for review.
Even if the company has been approved in the past, the new application will be evaluated based on its current situation.
Disqualification resulting from an ex officio review
If the revocation is related to an audit conducted by the Federal Revenue Service, it is not sufficient to simply submit an application as if it were an initial authorization.
The documents and statements proving that the matters have been resolved must be included in the corresponding administrative file.
The analysis may result in:
continuation of the disability; or
granting of a new authorization, with the type and limit determined by the Federal Revenue Service.
The decision will be formalized by an order, which may be subject to an administrative appeal.
Suspension or Cancellation
If the matter involves a suspension or cancellation, it will be necessary to analyze the basis for the decision, the applicable deadlines, and the options for appeal or rectification.
In this situation, the company should avoid placing parallel orders without first analyzing the process. This can lead to rework without resolving the original cause.
What documents may be requested?
The documentation required varies depending on the type of transaction, the company's situation, and the reason for the review.
The Federal Revenue Service may request, among other things:
updated articles of incorporation or bylaws;
corporate changes;
documents from legal guardians;
proof of address;
accounting and financial documents;
trial balances and balance sheets;
bank statements;
information on the source of funds;
contracts related to operations;
documents demonstrating the company's structure and operational status;
clarifications regarding financial or commercial transactions.
The documents must be up-to-date, legible, and consistent with one another. Inconsistent information may result in additional requirements and extend the review period.
Is there a deadline for recovering the Siscomex Radar?
There is no single deadline that applies to all cases.
Requests processed automatically by the Habilita System may receive a faster response. When a request is selected for review, the processing time depends on the complexity of the case, the documentation submitted, and whether additional information is required.
Cases involving ex officio review, rectification, or appeal may also require a more detailed analysis.
Therefore, it is best to submit the application correctly from the start, with all required documents and a justification that is consistent with the cause of the disability.
How can I prevent another disability?
A company engaged in foreign trade must maintain a routine for monitoring its registration, tax, and operational matters.
Some important measures include:
monitor the status of the license;
check e-CAC and your email inbox;
keep the CNPJ, corporate structure, and list of responsible parties up to date;
fulfill ancillary obligations by the deadlines;
keep accounting and financial documents organized;
track the date of the last transaction in Siscomex;
periodically review accredited users;
assess whether the operational limit is adequate for the planned imports;
respond promptly to summonses from the Federal Revenue Service.
This monitoring is especially important for companies that conduct operations on an occasional basis.
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Frequently Asked Questions About Disabling the Siscomex Radar
Is Radar canceled after six months of inactivity?
No. The regulations provide for automatic deactivation when the declarant has not conducted any transactions in the foreign trade systems for 12 months.
After 12 months without importing or exporting, do I have to start all over again?
A company whose registration has been suspended due to inactivity must submit a new application for registration. The application will be reviewed based on the company’s current status and may be processed automatically or forwarded for review.
Does a tax debt automatically cause the company to be removed from Radar?
Not necessarily. The existence of a debt, in and of itself, should not be treated as an automatic grounds for disqualification. It is necessary to review the status of the qualification and verify the basis for any decision by the Federal Revenue Service.
Can I continue operating while I get my license in order?
If the company is effectively deactivated, it will not be able to perform new transactions in the foreign trade systems on its own behalf. The impact on ongoing operations must be analyzed on a case-by-case basis.
Do I need to hire an accountant or a lawyer?
There is no general requirement to hire a professional to file the application. However, an expert review can help prevent errors in cases of ex officio review, discrepancies in registration information, questions regarding financial capacity, or the need to file an appeal.
Has your company been deactivated in Siscomex?
Before submitting a new application, it is essential to identify the cause of the disability and gather the appropriate documentation.
CLM Controller assists import and export companies with the registration, accounting, tax, and financial analyses required for foreign trade operations.
If your company has been shut down, has received a notice of noncompliance, or needs to review its operational capacity, contact the experts at CLM Controller. Our team can assess the situation and advise you on the most appropriate steps to safely resume operations.
Count on CLM Controller to keep your company ready to do business internationally.
Good afternoon!
My understanding is that after 6 months without importing/exporting, the company's registration with siscomex is suspended and it has to go through the whole process again, is this correct?