Professional Council Annual Fees: Pay Close Attention To Charges

At the beginning of every year, companies from various sectors start receiving payment slips for annual fees issued by Professional Councils — such as CREA, CRQ, CRMV, COREN, CFM, CRO, CRF, among many others. In 2026, this movement is expected to be even more intense: throughout last year, some Councils sent official notices requesting information about service providers and professionals subject to their oversight, expanding the mapping of companies and helping to explain the increase in charges at the start of this year.

But before simply paying, it is always worth asking: is this annual fee actually mandatory?

The taxable event is not the CNAE — it is the activity

Brazilian legislation and case law establish that a legal entity's registration with Professional Councils depends on the predominant activity effectively carried out, not on ancillary activities or the internal use of regulated professionals. In practice, however, there is no uniform interpretation among the Councils themselves, which leads many companies to receive charges without a solid legal basis.

This lack of regulatory uniformity makes it even more important to carefully review whether the company truly falls within the activities supervised by the Council issuing the charge.

Double registration? As a rule, it is prohibited

It is common for companies with multidisciplinary operations to receive charges from more than one Council. The consolidated understanding of the Superior Court of Justice (STJ) and several Federal Regional Courts (TRFs), however, is clear: double registration cannot be required when the company carries out a single predominant activity or when its involvement in another area is merely ancillary. Therefore, charging two annual fees for the same purpose is improper and may be challenged administratively and/or judicially, avoiding unnecessary burdens for the legal entity.

What if registration is required and the company does not pay?

Failure to pay Professional Council fees may result in the debt being recorded as public debt, protested, and judicially collected through tax enforcement proceedings, with the risk of asset freezes, as well as registration in CADIN, which prevents the company from contracting with the government and accessing financing and incentives. In addition, noncompliance may create difficulties in maintaining registrations and licenses and may lead to administrative fines. Although the amounts involved are generally not high, this type of pending issue often causes disproportionate legal and operational strain, with repercussions for audits, corporate transactions, and the company's regulatory standing until the matter is resolved.

So… how do you know whether your annual fee is due?

Answering this question requires more than looking at the payment slip or the CNAE code. It is necessary to analyze the activity actually carried out by the company, review its corporate purpose and corresponding CNAE classifications, always in light of the applicable legislation and the company's operational context, as well as consider existing administrative and judicial precedents on the matter. This type of legal assessment makes it possible to distinguish legitimate obligations from improper charges — and, above all, prevents companies from assuming costs, risks, and liabilities that need not exist.

It is undeniable that many technical activities must — and should — be supervised by Professional Councils. However, such oversight, as well as the obligations arising from it, must always observe the limits and criteria established by law and consolidated case law.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.