New PAT Regulations 2026: What You Need to Know

Significant updates to the Worker Food Program (PAT) officially took effect this Tuesday, February 10, introducing a new era of transparency and competition. Established by Decree No. 12,712, these new PAT regulations 2026 aim to modernize the 50-year-old program, ensuring that meal and food vouchers serve their primary purpose: worker nutrition.

The federal government designed these changes to balance the scales between voucher operators, commercial establishments, and the millions of Brazilian workers who rely on these benefits.

Immediate Changes to Fees and Payouts

The most immediate impact of the new decree involves the financial relationship between voucher operators and the establishments—such as restaurants and supermarkets—that accept them. These measures are designed to reduce operating costs and improve cash flow for small businesses.

The 3.6% Merchant Discount Rate (MDR) Cap

Under the new rules, the “taxa de desconto” (MDR) that operators charge establishments is now capped at 3.6%. Additionally, the interchange fee is limited to 2%. By setting these ceilings, the government prevents predatory pricing and encourages a more competitive marketplace.

Faster Payment Cycles

Previously, establishments often waited up to 30 days to receive reimbursement for voucher transactions. The new PAT regulations 2026 slash this timeframe. Operators must now credit payments to establishments within 15 calendar days, providing immediate relief to business liquidity.

Future Interoperability and Market Openness

The decree outlines a phased transition toward a fully “open” system. Currently, many cards only work on specific terminals. This is set to change through a strict modernization timeline:

  • May 2026 (180 Days): Large operators (those serving over 500,000 workers) must transition to open systems.
  • November 2026 (360 Days): Full interoperability becomes mandatory. This means any PAT card must be accepted at any payment terminal across Brazil, regardless of the card issuer.

Prohibited Practices

To ensure fair competition, the decree explicitly prohibits “rebates” or indirect advantages between operators and employers. This includes:

  • Cashback offers.
  • Administrative fee discounts.
  • Sponsorships or marketing “bonuses.”
  • Exclusivity clauses in open arrangements.

Benefits for Workers and Employers

The modernization of the PAT framework provides specific advantages for every stakeholder in the ecosystem.

For the Worker

The primary goal is freedom of choice. With full interoperability, workers will no longer be restricted to specific restaurants based on their card brand. Furthermore, the decree reinforces that these funds are exclusive to food. Usage for gyms, pharmacies, or streaming services is strictly prohibited to ensure the health and well-being of the workforce.

For the Employer

Companies providing these benefits will see increased legal certainty. While the cost of providing the benefit remains unchanged, the new rules eliminate market distortions. Employers are now also responsible for educating their staff on the correct usage of these funds to remain compliant with the program’s nutritional goals.

Note on Legal Injunctions: While some companies currently hold court injunctions (liminares) protecting them from specific sanctions regarding fees, the Ministry emphasizes that the decree is in full effect. All companies are encouraged to align their operations immediately to avoid future legal complications.