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As of 2025, all municipalities in the country will have to register IPTU debts in notary offices before fiscal execution, which may prevent the sale and financing of properties in just three business days.
As of 2025, municipalities across the country will need to prioritize the extrajudicial protest of the Active Debt Certificate (CDA) before resorting to fiscal execution.
This measure arises from the ruling of Topic 1184 by the Federal Supreme Court (STF) and from Resolution 547/2024 of the National Justice Council (CNJ), which incorporated the requirement as procedural rule.
The procedure may lead to the blocking of property registration in a few days, preventing the sale or financing of the property until the debt is settled.
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New Rules from the STF and CNJ
The STF determined that public entities must use extrajudicial collection methods, such as the notary protest, before engaging the judiciary.
The CNJ regulated the guideline, creating electronic mechanisms that block the distribution of legal actions when there is no proof of the extrajudicial attempt.
Thus, the initial collection of taxes will occur in notary offices, and fiscal execution will only be accepted after demonstrating these measures.
How The Protest Works
The protest follows a standardized procedure.
The municipality presents the CDA to the notary office, the debtor is notified, and if the debt is not settled, the protest is formally registered within three business days, as provided in Article 12 of Law 9.492/1997.
The registration generates restrictions in credit records and is noted on the property registration, preventing transactions like buying, selling, financing, or mortgaging while there is an outstanding debt.
Amounts in Collection
Although the CNJ resolution establishes limits for filing executions below a certain amount, there is no legal minimum for protests.
In some cities, any debt can be registered as an active debt and brought to the notary office.
Thus, small amounts can also result in protests and property blocking, along with interest, fines, and notary fees.
Justification for the Change
The goal of the measure is to reduce the number of low-value fiscal executions that are processed in the courts.
Data from the Sao Paulo State Court (TJSP) shows that 79% of ongoing municipal executions involve IPTU collections of less than R$ 500.
According to the STF, these cases consume public resources and often do not result in effective recovery.
Debt Recovery by Notary Offices
After the STF decision and CNJ regulation, notary offices registered an increase in the recovery of public debts.
According to the Institute of Studies on Title Protest in Brazil – Ceará Section, between January 2023 and May 2025, R$ 18 billion was recovered nationwide, of which R$ 4.9 billion was recovered in just the first five months of 2025.
The entity points out that the annotation of the protest in credit records helps to accelerate the regularization by debtors.
Consequences for the Taxpayer
The protest has an immediate effect on the CPF or CNPJ, with registration in credit databases and an impact on financial operations.
In some municipalities, notification is sent via email or SMS, but if the data is outdated, notification may occur by public notice.
In this case, the taxpayer may discover the restriction only when attempting to sell or finance the property.
Local Procedures and Cancellation
In cities that already use the protest as a regular collection tool, registration as an active debt can occur shortly after the IPTU due date.
Once this step is completed, the CDA is sent to the notary office.
If payment is made within the deadline, the protest is avoided.
Otherwise, the registration is formalized.
When the debt is settled after the protest, the municipality issues a letter of consent, and the taxpayer must pay the cancellation fees at the notary office.
The cancellation is usually registered in credit systems within five business days, and the annotation is removed from the property registration, freeing it for new transactions.
Changes in Tax Legislation
The Complementary Law 208/2024 amended the Article 174 of the National Tax Code, including the protest as one of the hypotheses that interrupt the statute of limitations for tax collection.
As a result, municipalities will have additional time to recover owed amounts without the immediate need to resort to the judiciary.
Impacts Under Discussion
Studies by specialists in tax law indicate that the model may contribute to greater efficiency in recovering public revenues.
However, there are also reports of criticism regarding proportionality, especially when notary fees exceed the amount of the overdue tax.
The topic remains under discussion among municipalities, class entities, and scholars in the fiscal area.
Given the national adoption of this mechanism, the discussion continues: will the immediate protest of IPTU debts, even in small amounts, be sufficient to increase compliance without generating disproportionate effects for low-income taxpayers?
Incrivel o lobby dos Cartorios.
Agora e mais despesas para o cidadao comum.
O cidadao, em vez de pagar o alto iptu, compra comida para casa.
Agora tera seu nome cadastrado, negativado e, alem de pagar o debito na prefeitura COM HONORARIOS AOS PROCURADORES MUNIVIPAIS, tera q pagar CUSTAS DE CARTORIOS PARA CANCELAMENTO DO DEBITO.
O contribuinte é oprimido por todos lados, ninguém pensa nas razões pelo qual deixou de pagar, pois tdm alimentos, água, luz e outris, vamos falar agora sobre os favelados que fazem gato de td, d sobra pra quem pagar? Pra **** q paga tds as contas tendo que fazer por vezes escolhas: oago essz conta ou compro comida?
Acho um fim da picada , pagam uma miséria de salário mínimo e jogam para o cartório , estes governantes são uma vergonha. Eles só sabem suga o povo .