Challenging the Accident Prevention Factor (FAP) for the period 2026 represents an important opportunity for companies that wish to reduce social security costs and correct any inconsistencies that may have negatively impacted the index applied to the RAT/SAT rate.
As established by Interministerial Decree MPS/MF No. 10/2025, the deadline for administrative appeals will be exclusively between November 1st and 30th, 2025, with no possibility of extension.
The procedure must be carried out entirely electronically before the Social Security Appeals Board (CRPS), using a specific form provided by the competent authorities.
Appealing is especially recommended for companies whose FAP (Factor of Adjustment for Accidents at Work) has experienced a significant increase due to the registration of accidents, absences, or the granting of accident benefits allegedly related to the work environment. This is because, in practice, many of these occurrences result from incorrectly assigned employment relationships, registration errors, or erroneous classifications generated by the Epidemiological Technical Link in Social Security (NTEP), directly impacting the calculation of the index.
In these situations, administrative review can result in a reduction of the FAP (Factor of Adjustment for Accidents at Work), with a direct and immediate impact on decreasing social security costs on the payroll.
To enable analysis and substantiate the challenge, it is necessary to gather some essential information and documents beforehand, such as: complete CNPJ (head office and branches), FAP consultation and detailed establishment file, list of accident benefits (B91 and B94), history of Work Accident Communication (CAT), data on absences subject to challenge and, if applicable, electronic power of attorney enabled in e-CAC.
Based on these elements, it is possible to identify any inconsistencies and prepare a technical defense that demonstrates the impropriety of records that may have contributed to the increase in the index.
In a scenario of high payroll taxes and increasing scrutiny, contesting the FAP (Factor of Adjustment for Accidents at Work) is a strategic measure for tax management and social security compliance. In addition to reflecting a proactive stance by the company, it contributes to financial stability and legal certainty in its relationship with Social Security.
Therefore, it is recommended that companies begin organizing the documentation and conducting the technical analysis now, considering that the deadline for contesting the decision is short and final.