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REFAZ RECONSTRUCTION II: RIO GRANDE DO SUL LAUNCHES NEW ICMS SETTLEMENT AND INSTALLMENT PROGRAM WITH REDUCTIONS IN FINES AND INTEREST

27/11/2025

The Government of the State of Rio Grande do Sul has established a new ICMS regularization program, called “REFAZ RECONSTRUCTION II”, under Decree No. 58.468/2025 and Normative Instruction RE No. 102/25, both effective and published on 11/19/2025. This is an extension (“second chance”) for taxpayers who did not join the first phase of REFAZ RECONSTRUCTION. The program allows payment of ICMS debts overdue until February 28, 2025, with reductions of up to 95% in interest and fines. Enrollment must occur by December 17, 2025, allowing only a single lump-sum payment with irrevocable and irreversible confession of debt.



1. Which debts may be settled under REFAZ RECONSTRUCTION II?





  • Only ICMS debts, enrolled or not in active debt registry, overdue until 02/28/2025.




  • Excluded credits: debts already offset and approved (except remaining balances); fully guaranteed debts (deposit, surety or insurance) with final judgment in favor of the State; and debts of taxpayers under Special Inspection Regime.





2. Payment options, deadlines and reductions:



Only a single lump-sum payment is allowed, by 12/17/2025, with the following reductions:


























Modality Reductions Deadline Applies to
01 95% 12/17/2025 General ICMS debts, such as late payment or omission of payment.
02 90% 12/17/2025 Specific cases, such as minor infractions or accessory obligations (e.g., not submitting declarations).


Reductions include all related legal additions.



3. Who can join?





  • All taxpayers with ICMS debts overdue until 02/28/2025.




  • Includes debts under dispute, provided the taxpayer withdraws actions or appeals within 10 days of payment.




  • Pending offset requests must be withdrawn by 11/21/2025.




  • Mixed debts must have pre-02/28/2025 installments separated via request by 11/21/2025.





4. How to join?





  • Via login on the e-CAC Portal (businesses) or Citizen Portal (individuals).




  • Without login: through SEFAZ public payment page.





5. Important deadlines:





  • 12/12/2025: deadline for spontaneous reporting.




  • 12/17/2025: last day for enrollment and full payment.





6. Debts under judicial collection:





  • Attorney fees remain applicable;




  • Court costs are not included;




  • Taxpayer must withdraw legal actions within 10 days after payment.





7. Key considerations:





  • Payment confirms enrollment;




  • Enrollment implies irrevocable and irreversible confession of debt;




  • Attorney fees and court costs are not waived;




  • Deposited guarantees require a judicial request for release;




  • Existing installment plans are automatically canceled once payment is made via the program;




  • If not all debts in the same enforcement action are included, the action continues for the remainder.





The Dupont Spiller Fadanelli law firm remains available to assist with any questions.

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