Brazil court halts part of new voucher rules

A federal court in Brazil has suspended, on a provisional basis, part of the new regulatory framework for food (vale-alimentação) and meal (vale-refeição) vouchers. On 9 November 2026, Judge Frederico Botelho de Barros Viana of the Federal Court in the Federal District granted a preliminary injunction that halts implementation of several provisions of a decree governing the sector. The decision applies exclusively to companies associated with the Associação Brasileira das Empresas de Benefícios ao Trabalhador (ABBT), which represents leading operators in the market.

Among the firms covered are Alelo, Pluxee, Ticket, VR and ValeShop, identified as some of the largest brands in the benefits segment. For these companies, the ruling temporarily restores the previous rules of the Programa de Alimentação do Trabalhador (PAT) until there is a definitive judgment in the case. The federal government has been ordered to be notified urgently and must present its defense, while the case will also be sent to the Federal Prosecution Service.

The injunction suspends several elements of the decree whose rules began to take effect on 7 November 2026. It also suspends the cap of 3.6% on merchant discount rates charged to establishments such as restaurants and supermarkets, and the 2% ceiling on interchange fees. In addition, the maximum deadline of 15 days for passing on voucher payments to merchants is suspended, along with the deadlines for adapting to the new requirements.

With the decision, ABBT-associated firms can temporarily maintain their existing business models, fees and payment timelines set in prior contracts. The Union and the Ministry of Labor and Employment must refrain from applying penalties, opening or continuing sanctioning procedures, or imposing operational restrictions on the covered companies based solely on the suspended provisions. The judge considered there were indications that the executive branch exceeded its regulatory authority by imposing economic restrictions through a decree without sufficient legal backing in PAT legislation.

While several economic restrictions were set aside, the injunction explicitly preserves the requirement for interoperability between voucher card networks. This obligation, established in law, aims to ensure that payment terminals accept cards from different voucher operators, so that benefits can be used regardless of the brand of the card. Reports from supermarket, restaurant and payment sectors indicated that, despite the legal deadline, meal and food voucher cards were still not accepted on all enabled terminals.

The maintained interoperability rule seeks to reduce cases in which a restaurant, supermarket or snack bar accepts vouchers but not a specific brand. The Ministry of Labor and Employment argues that it is up to the companies themselves to make the necessary technical and operational adjustments, while its role is limited to regulation and oversight of the sector. Companies represented by ABBT, including Ticket, Pluxee, VR and Alelo, have cited difficulties finalizing integration and have requested clearer operational rules for the system. The injunction is provisional and may be contested by the federal government as the legal dispute progresses.