The State of Rio de Janeiro has introduced a new opportunity for the regularization of outstanding liabilities, offering discounts of up to 95% and a 60-day enrollment window.

On December 10, 2025, Decreto nº 50.040/2025 was published in the Official Gazette of the State of Rio de Janeiro, regulating the new Special Installment Program for Tax and Non-Tax Credits (Refis RJ), authorized by Convênio ICMS 69/25 and instituted by Lei Complementar nº 225/2025.

The program establishes relevant conditions for the settlement of state-level liabilities, providing significant reductions in penalties and interest, as well as differentiated mechanisms according to the taxpayer’s profile, with a 60-day enrollment period counted from December 10, 2025.

Scope of the program

Liabilities with taxable events occurring up to February 28, 2025 may be included, whether or not enrolled in active debt, including:

1. ICMS and IPVA;
2. Liabilities related to the FECP, FEEF, and FOT funds;
3. Penalties arising from tax infractions and ancillary obligations;
4. Non-tax credits enrolled in active debt, including:
   • Administrative fines imposed by public agencies;
   • Penalties imposed by the State Court of Accounts (TCE/RJ);
5. Outstanding balances from previous installment plans, except those benefiting from total or partial amnesty or remission.

Payment conditions and discounts

The consolidated credit may be settled in a lump sum or paid in up to 90 monthly installments, subject to the following conditions:

1. Single installment (lump sum): 95% reduction in penalties and interest;
2. Up to 10 installments: 90% reduction;
3. Up to 24 installments: 60% reduction;
4. Up to 60 installments: 30% reduction;
5. Up to 90 installments: no reduction.

Where the liabilities consist exclusively of penalties, the penalty amount will be reduced by 50%, and the applicable late-payment charges will be reduced in accordance with the percentages corresponding to the selected payment modality.

The minimum amount of each installment is 450 UFIR-RJ, and installments will be due on the 5th day of each month.

Offset with court-ordered payments

The decree authorizes the offset of liabilities enrolled in active debt against state, whether owned by the taxpayer or acquired from third parties, subject to the following parameters:

1. Additional reduction of 70% on penalties and interest related to the offset portion;
2. ICMS: offset limited to 75% of the liability amount;
3. IPVA: offset limited to 50%.

Note: Any remaining balance must be settled in cash within five business days following approval.

Relevant prohibitions

Refis RJ does not allow:

1. Partial payment of liabilities included in the same tax assessment or debit notice;
2. Use of judicial deposits;
3. Inclusion of credits covered by a final, non-appealable court decision favorable to the State, when fully secured by a deposit, cash attachment, bank guarantee, insurance guarantee, surety bond, or equivalent instrument.

Special conditions for judicial reorganization and bankruptcy

Companies undergoing judicial reorganization or with bankruptcy declared are subject to a specific regime applicable to tax and non-tax liabilities with taxable events occurring up to October 27, 2025, including:

1. Installment plans of up to 180 monthly installments under a more favorable structure;
2. Progressive reductions in penalties and interest;
3. Alternatively, an installment plan linked to gross revenue may be elected, with installments ranging from 2% to 5.5% of monthly revenue, depending on the selected term.

Final considerations and additional care

Under the terms of the decree, enrollment becomes effective only upon payment of the lump sum or the first installment of the selected plan; the mere filing of the request does not suspend the enforceability of the liabilities.

Additionally, participation in the program implies an irrevocable and irreversible acknowledgment of the included liabilities, waiver of related judicial actions and administrative defenses, and the total loss of the granted benefits in the event of material default.

Our team remains available to provide further clarification, assess specific scenarios, and assist in structuring the most appropriate tax regularization strategy.