RDAP and RADI reports submitted: find out what happens next

By Alexsandro Evangelista and Cristiane Rodrigues, from the Economic Consulting & Projects team.

Companies benefiting from incentives managed by SUFRAMA were required to submit, by June 30, 2025, the Project Monitoring Report (RDAP) and the Annual Import Demonstration Report (RADI), in compliance with the monitoring procedures established by the agency. With this stage completed, one question arises: what happens next?

Issuance of the Project Monitoring Opinion (PAP)

Based on SUFRAMA Resolution No. 205/2021 and Ordinance No. 1,398/2024 (amended by Ordinance No. 1,924/2025), SUFRAMA has up to one year from the submission of the reports to issue the PAP, a document that consolidates the analysis of the information provided.

During this period:

• Technical inspections may be carried out by SUFRAMA’s team to verify, on site, the accuracy of the information submitted; and

  
  

• The company may be formally notified to provide additional documents or clarifications within a defined deadline.

  
  

What if a notification is issued?

If the PAP indicates signs of partial or total disapproval, the company will be formally notified and will have 30 days to present its defense. After this period:

• A new technical opinion will be issued within 60 days, extendable for an equal period; and

  
  

• The final decision will rest with the Deputy Superintendent of Projects, who will have 30 days to issue it, also extendable for an equal period.

  
  

What if my RDAP/RADI is disapproved?

If the PAP concludes that the Basic Production Process (PPB) requirements have not been met, the company must provide proof of regularization within 15 days. Otherwise:

• The SUFRAMA registration will be blocked;

  
  

• Import Licensing Requests (PLI) will be suspended; and

  
  

• In more serious cases, tax incentives may be suspended or canceled.

  
  

And if it is approved?

Companies whose RDAP/RADI are approved will be formally notified by SUFRAMA following the decision of the Deputy Superintendent of Projects.