A concept note based on the author’s working paper has been published on SSRN:
The Tax and Customs Compliance System in Brazil: Normative Structure and Integration of the Sintonia, Confia, and AEO Programs
https://papers.ssrn.com/sol3/papers.cfm?abstract_id=6570738

In several countries, the evolution of cooperative compliance models has been accompanied by a greater focus on taxpayer segmentation mechanisms, tax governance, risk management, and trust-based relationships. In this context, the new regulatory framework adopted in Brazil may offer insights relevant to the regional debate on tax administration and the promotion of compliance.

Supplementary Law No. 225/2026 and its implementing regulations introduced a framework comprising three instruments: the Sintonia Program, the Confia Program, and the Authorized Economic Operator (AEO) Program. Rather than being isolated initiatives, these programs can be understood as components of an integrated compliance management system. This may be the most distinctive feature of the Brazilian model: the attempt to structure classification, cooperative monitoring, and customs facilitation not as parallel initiatives, but as interconnected dimensions of the same regulatory framework.

Sintonia represents the system’s segmentation and classification component. It is a continuous mechanism for assessing the compliance performance of legal entities, based on objective criteria related to, among other factors, the regularity of registration, compliance with ancillary obligations, the consistency of the information provided, and payment behavior. The program’s logic is not merely classificatory in an informational sense, but rather structuring: the classification produces legal and administrative effects, determining benefits, forms of interaction with the administration, and the intensity of monitoring.

One particularly interesting aspect is that the regulatory framework is not limited to rewarding results but rather seeks to influence behavior. It includes mechanisms for the early reporting of inconsistencies, opportunities for self-regulation, and differentiated treatment based on the level of compliance demonstrated. In this sense, the classification ceases to be a mere overview and begins to function as a regulatory management tool.

Confia adds a second layer to the system: shifting the focus from segmentation to a structured cooperative relationship. Its approach moves away from general behavioral oversight toward a relationship based on transparency, tax governance, and ongoing interaction between taxpayers and the tax administration. It is not simply a benefits-based program, but rather a relational framework supported by eligibility criteria, internal controls, risk management, and institutional channels for dialogue.

Particularly noteworthy is the idea that compliance, in this context, is not viewed solely as the result of ex post oversight, but rather as something that is built through continuous monitoring, prevention, and self-regulatory mechanisms. From this perspective, the program adopts models internationally associated with the concept of “enhanced relationship taxation,” but within its own regulatory framework.

The third component, the AEO Program, applies this logic to the customs sphere. In this case, the certification of trusted operators is structured not only as a tool to facilitate trade, but also as part of a broader compliance framework. Criteria related to reliability, governance, risk management, and compliance history become prerequisites for accessing streamlined procedures and reduced controls. The underlying logic is similar: calibrating administrative performance based on information about behavior and risk.

It is precisely the connection between these three instruments that appears to offer a particularly fruitful starting point for comparative analysis.

Rather than treating segmentation, cooperative compliance, and customs certification as separate entities, the model seeks to link them through a shared information base, converging criteria, and complementary effects. The article that inspired this note argues that this integration manifests itself at multiple levels: in the criteria used by the programs, in information flows, in the feedback between mechanisms, and in the possibility of functional progression between instruments.

From this perspective, Brazilian architecture seems to suggest something conceptually interesting: perhaps cooperative compliance can be viewed not only as a specific program, but as a compliance management system composed of distinct yet coordinated tools.

This could represent a potential contribution to the international debate.

In many debates on cooperative compliance, the discussion tends to focus on specific cooperative relationship programs. The Brazilian case seems to invite us to broaden this perspective and consider whether segmentation, cooperative monitoring, and certification can function as components of an integrated regulatory architecture.

Another relevant point is that the model appears to partially shift the focus from the classic idea of control toward a more informative and relational approach. Information ceases to be merely an input for monitoring and becomes integrated into the architecture itself to promote compliance.

This aspect may be of particular interest in Latin American debates, where many                     tax administration agencies have sought to combine oversight, dispute prevention, and incentives for voluntary compliance.

Naturally, this paper does not aim to provide an institutional assessment of the Brazilian model, nor to judge its practical effectiveness—a topic that will require future empirical analysis. Nor does it express the official position of any tax administration. It is a personal academic initiative by the author, conceived with a more modest and perhaps more useful objective at this time: to facilitate international understanding of the regulatory framework adopted in Brazil and to contribute to technical exchange on regulatory approaches based on cooperative compliance.

In this regard, the value of the model lies perhaps less in providing definitive answers and more in offering information for comparative analysis.

Some aspects may prove particularly thought-provoking for this debate:

First, the idea of integrating instruments that have traditionally been treated separately.

Second, the use of segmentation is not only for classification, but also as the basis for calibrating incentives, monitoring, and relationships.

Third, the importance attributed to governance, information, and self-regulation as elements of the regulatory architecture itself.

And finally, the possibility of conceiving facilitation and control not as opposites, but as potentially complementary dimensions within the same risk management model.

From this perspective, the Brazilian experience could be interpreted less as a closed experiment and more as a regulatory hypothesis in the making, and, precisely for that reason, as an interesting topic for international dialogue.

At a time when various tax administrations are debating new ways to promote compliance, reduce litigation, and strengthen cooperative relationships with taxpayers and economic operators, the Brazilian case can offer a useful, albeit preliminary, point of reference for this debate.

At the very least as a conceptual proposal, it seems to suggest that the future of cooperative compliance may not lie solely in isolated relationship programs, but rather in integrated compliance management architectures.

This, in essence, is the idea that the working paper seeks to advance.

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