In compliance with Supplementary Law no. 214/2025, which set the Tax Reform milestone, on December 1, 2025, the Federal Revenue Office implemented the new MAT (Tax Administration Module) system. This change modifies the process of starting a company, requiring entrepreneurs to define their tax regime prior to issuance of the CNPJ.

Until then, the procedure allowed issuance of the CNPJ in sync with the registration of the organizational documents at the Commercial Registry, notary public offices, or the Brazilian Bar Association (OAB). With the new system, however, the corporate registration and issuance of the CNPJ no longer occur simultaneously but now depend on the choice of tax regime in the Tax Administration Module. This change directly relates to the requirement previously announced by the Federal Revenue Office, which now calls for the indication of the tax regime at the time of registration, as addressed in a previous article.

When will the CNPJ be generated?

Although the essential steps for opening a business remain similar, the new process changes the timing to obtain the CNPJ. Under the new process:

• Registration of the organizational documents;
• Issuance of the State Registration Identification Number (NIRE) and provision of the Certificate of Full Content;
• Indication of the tax regime in the Tax Administration Module; and
• Generation of the CNPJ takes between 5 and 60 minutes.

Only after accessing the Federal Revenue Office’s Tax Administration Module and formalizing the choice of tax regime will the CNPJ be effectively generated. For this purpose, the company has up to 90 days to make the indication.

Most significant impact: expectation of immediate CNPJ issuance

The main practical effect of this change lays on the absence of a CNPJ at the time of registration, and this impacts the start of the following activities:

• Open a bank accounts;
• Registration of the company on financial platforms;
• Execution of preliminary agreements; and
• Maintain registrations with suppliers and business partners.

This change requires new planning, especially for companies that operate on tight schedules or depend on having a CNPJ to start operational activities.

Tax planning in advance

Another significant effect is the mandatory advance tax study. While many previously postponed analyzing their tax regime, the system now requires this decision to be made right at the beginning, which tends to force a more informed and technically sound decision. Although this change represents an initial increase in formalities, the trend is that, in the medium and long term, this requirement will reduce problems arising from incorrect classifications that generate damaging tax impacts for the company.

In practical terms, the model contributes to greater consistency between corporate planning and tax structure from the outset.

Scope and reach of the change

It is important to note that this new procedure applies exclusively to the organization of new companies. Subsequent changes, such as contractual amendments, corporate reorganizations, or registration adjustments, do not follow the new logic. Furthermore, this is a nationwide change resulting from regulations issued by the Federal Revenue Office, even though its implementation is carried out by the state Commercial Registries.

Starting companies in a more technical setting

Given this new context, starting a company now requires greater integration between corporate planning, tax analysis, and technical support of the procedural process.

PLBrasil Group works to advise its clients on starting companies, guiding them through critical stages, ensuring correct compliance with requirements, and adaptation to the new operational model, both in the paralegal and tax areas, especially in more complex scenarios.

With a preventative approach and strategic analysis from the outset, it’s possible to structure the start of a company with greater security, predictability, and alignment with new regulatory requirements.