The National Congress has approved Provisional Measure No. 1,343/2026 in the form of Conversion Bill (PLV) No. 6/2026, which now proceeds to the President for sanction or veto. Although the approved text has mitigated some of the severity of the originally proposed regime (particularly regarding fine amounts and the criteria defining repeated offenses and recidivism), operational obligations and preventive control mechanisms linked to the CIOT remain, as do penalties with potentially significant impact. The new scenario, therefore, reduces regulatory exposure to some extent but does not eliminate the need to align operational and contractual freight-related processes.
Among the key changes, the increased fine—originally set between R$ 1 million and R$ 10 million per repeated operation—is now capped at R$ 1 million and applies only in cases of recidivism following a final administrative decision. The text also establishes stricter criteria for the suspension and cancellation of the RNTRC (National Registry of Road Freight Transporters), requiring due process, a full right of defense, proportionality, and the individualization of sanctions.
Infractions committed prior to the publication of the future law must be converted into warnings, including in ongoing administrative proceedings and regarding fines not yet paid. This rule does not apply to aggravated cases, such as fraud, willful misconduct, sham transactions, document falsification, or attempts to evade regulatory oversight. Furthermore, these prior infractions may not be used to establish a pattern of repeated offenses, recidivism, or habitual non-compliance under the new regime.
Despite the reduction in sanctions, the logic of preventive control via the CIOT remains in place. Operations must be registered in advance, specifying the freight value and adhering to the minimum rate floor; the ANTT (National Land Transportation Agency) may suspend code generation in the event of non-compliance or missing mandatory information. The requirement linking the CIOT to the MDF-e (Electronic Freight Manifest) is also maintained. The bill provides for a period of up to 180 days for the issuance of the acts necessary to regulate and operationalize the new regime. Obligations requiring technological integration, system adaptation, or the definition of procedures must allow for an adaptation period of at least 60 days whenever there is a significant operational impact. Existing substantive obligations—specifically the payment of the minimum rate floor and the settlement of freight charges—remain enforceable.
It will still be necessary to await the sanctioning and publication of the final text. Once that occurs, an assessment will be required to determine whether the regulations already issued by the ANTT will remain in force, require adaptation, or present incompatibilities with the new regime, as well as to understand the Agency’s position regarding the transition and implementation of the new rules.
Leonardo Mattoso Sacilotto | leonardo.sacilotto@nascimentomourao.adv.br
Partner, Environmental, Regulatory, and Biodiversity Law practice.
João Emmanuel Cordeiro Lima | joaoemmanuel@nascimentomourao.adv.br
Senior Partner, Environmental and Regulatory Law practice at Nascimento e Mourão Advogados.
