Next Wednesday, October 7, marks another quarterly payment deadline for the Environmental Control and Inspection Fee (TCFA). With this deadline coming up, it’s a good moment to check not just whether your company has paid, but whether it paid the correct amount, especially if it has subsidiaries. To clarify this scenario, we spoke with our forestry engineer, Gabriel Inácio, who leads environmental matters at Ígnea.
“It’s a federal fee charged by IBAMA for the control and inspection of potentially polluting activities or activities that use natural resources. It’s important to note that it isn’t a fine. Even without any violation, the TCFA is owed simply for carrying out the activity. Anyone with an active registration in the CTF/APP who carries out activities listed in Annex VIII of Law No. 6,938/1981, from extraction through ore dressing, must pay this fee. The amount depends on the establishment’s size classification and the activity’s pollution potential level, as set out in Annex IX. Payment is quarterly, due by the fifth business day of the month following the end of each quarter, and late payment triggers interest and a late-payment penalty.”
What the amounts are
The quarterly amounts, per establishment, cross the company’s size classification with the activity’s pollution potential level:
| Pollution Potential | Small Size | Medium Size | Large Size |
|---|---|---|---|
| Low | R$ 289.84 | R$ 579.67 | R$ 1,159.35 |
| Medium | R$ 463.74 | R$ 927.48 | R$ 2,318.69 |
| High | R$ 579.67 | R$ 1,159.35 | R$ 5,796.73 |
(Microenterprises pay R$ 128.80, and only at the high pollution potential level; individuals are exempt.)
Since 2024, under an understanding issued by IBAMA’s Federal Specialized Attorney’s Office, the size classification declared for a subsidiary no longer considers that subsidiary’s revenue in isolation. It now follows the parent company’s classification, calculated on the consolidated gross revenue of the entire economic group. This doesn’t change how payment works: each subsidiary still keeps its own registration in the CTF/APP and issues its own payment slip; IBAMA doesn’t consolidate billing into a single invoice for the parent company. Only the basis for the calculation changes. In practice, this means a company can be paying its subsidiaries’ TCFA punctually every quarter and still be in debt, because the declared size classification no longer reflects the group’s real revenue.
“One possible risk is updating the size classification at the parent company but forgetting to reflect that change in each subsidiary’s registration in the CTF/APP, leaving the old, standalone revenue figure on file.”
Another point worth raising: the relationship between the TCFA and IBAMA’s Certificate of Regularity runs in one direction only. Being current on the TCFA, with no outstanding debt with the collections office, is one of the requirements for issuing the Certificate of Regularity, but that certificate isn’t the document that specifically proves the fee is paid up; it attests to compliance with several requirements at once (registration, submission of the Annual Report of Potentially Polluting Activities, inspection data, among others). The document that specifically proves good standing on the fee is the Certificate of No Outstanding Debt.
In practice, this means a company can keep both certificates clean today, because the system only flags a debt once the size-classification error is actually detected, which can happen well after the debt already exists.
Outstanding quarters
Overdue, unpaid TCFA debts accrue interest at the SELIC rate and a late-payment penalty of 0.33% per day, capped at 20%, starting from the month the payment was actually due, not from the current quarter. Anyone who has owed since April or July has already been accruing these charges for months, and the longer it goes unresolved, the closer the debt gets to being registered in the active debt registry, at which point a further 10% charge applies to the total, rising to 20% once tax foreclosure proceedings have been filed. Before that registration happens, though, it’s still possible to arrange an administrative installment plan with IBAMA, in up to 60 monthly installments.
“It’s worth reviewing your registration and payment status now, before any pending issue accrues interest and becomes active debt,” Gabriel adds.
For the complete guide to the TCFA, who is required to pay, registering with the CTF/APP, and calculating your size classification, see our article: TCFA and Environmental Compliance.
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