D-SUP 2025: Deadline for submitting the declaration

Uniprofessional companies have until December 30 to prove their compliance with the special ISS (Service Tax) payment regime.

SF/Surem Ordinance No. 63/2025, published on August 28, established the deadline for submitting the Electronic Declaration of Uniprofessional Companies (D-SUP) for the fiscal year 2025. According to the regulation, the submission period began on September 1 and will end on December 30.

All uniprofessional companies in the city of São Paulo are required to submit the declaration. This includes societies formed by professionals who engage in the same activity and provide services personally, with individual responsibility in the name of the legal entity. This group includes doctors, lawyers, accountants, among others.

According to Law 13.701/2003, these companies are subject to a special regime for the collection of the Service Tax (ISS), in which the tax base is a fixed monthly amount, proportional to the number of qualified professionals.

The classification under this regime requires an annual declaration to confirm that the conditions set out by the law are still being met. If the declaration is not submitted within the deadline, an automatic disqualification occurs.

Recent change in the D-SUP legislation

Regulatory Instruction SF/SUREM No. 9/2025, published in July 2025 with immediate effect, altered the rule for uniprofessional companies that fail to submit the D-SUP within the established deadline.

Previously, not submitting the declaration resulted in the disqualification from the special regime starting in January of the following year. With the recent regulation, this penalty has been replaced by a fine equivalent to 10% of the ISS (Service Tax) that would have been due if the company were not in the special regime. Before the fine is applied, the taxpayer will be notified and will have 60 days to regularize the situation by submitting the declaration.

Another change is related to the issuance of Electronic Service Invoices (NFS-e) with service codes incompatible with the regime, a practice that also previously led to automatic disqualification. The possibility of exclusion from the regime remains, unless the NFS-e is canceled or replaced within the regulatory deadline.

It is important to note that the regulation stipulates that the application of the fine does not prevent the conduct of inspections to verify the fiscal and registration regularity of the company.

Specialized assistance

DPC has a team of specialists ready to support your business's compliance. Count on this support: dpc@dpc.com.br.