An illegal market that moves R$ 179.2 billion per year in Brazilian retail, according to CNC data, is not sustained solely by informal merchants. Industry entities and specialists point out that the chain of illegality begins with companies that systematically fail to collect taxes, turning the practice into a business model.
It was to target these agents that Complementary Law 225/2026 came into effect in January, creating the figure of the contumacious debtor. This norm is the main new instrument of a broader set that also includes asset recovery, criminal hardening, and product tracking.
However, the numbers from this application are considered modest. The Federal Revenue identified 3,132 companies that could be classified under the new legislation, but from this universe, only 49 businesses were effectively fined or enrolled in active debt, revealing a significant gap between the potential for action and the practical application of the law.




