Autonomous Fiscal Agents

Detection criteria

1. 1Procurement via no-bid waiver above the threshold for civil works and engineering services — R$ 130,984.20 (Law 14.133/2021, Art. 75, Inc. I; Decree 12.807/2025, effective 01/01/2026).
2. 2Procurement via no-bid waiver above the threshold for other services and goods — R$ 65,492.11 (Art. 75, Inc. II; same decree).
3. 3Multiple waivers to the same supplier within a short period, with values individually below the threshold — indication of contract splitting prohibited under Art. 75, §1º.

Exclusion by regularity

• Waiver grounded in urgency (Art. 75, Inc. VIII) with documented justification in the published act.
• Values below the legal thresholds with no history of splitting to the same supplier.

Legal basis

Law 14.133/2021, Art. 75, Inc. I and II; §1º (prohibition of contract splitting). Values updated by Decree 12.807/2025.

Detection criteria

1. 1Contract amendment with an addition exceeding 25% of the original contract value, for civil works, services and goods in general (Law 14.133/2021, Art. 125, §1º, Inc. I).
2. 2Contract amendment with an addition exceeding 50% of the original value in building renovation or equipment contracts (Art. 125, §1º, Inc. II).
3. 3Continuous-service contract with total accumulated duration exceeding 10 years (Art. 107, caput).

Exclusion by regularity

• Qualitative amendments (technical specification changes without value addition) do not constitute this type.
• Extensions within the legal limits and with documented public-interest justification.

Legal basis

Law 14.133/2021, Art. 125, §1º, Inc. I and II; Art. 107, caput.

Detection criteria

1. 1Contract with a legal entity whose incorporation date at the Federal Revenue Service is less than 180 days before the contract signing date — indicative of a company with no operating history.
2. 2Supplier representing more than 40% of the total contracted value by a municipal department over the past 12 months, suggesting abnormal concentration.

Exclusion by regularity

• New CNPJ in small-value contracts (below the Art. 75 thresholds).
• Concentration in a single supplier when the nature of the object justifies exclusivity (documented sole-source justification).

Legal basis

Federal Constitution, Art. 37, caput (equal treatment); Law 14.133/2021, Art. 9º (principle of competitiveness). Company data via Federal Revenue API (BrasilAPI).

Detection criteria

1. 1Five or more political appointments in the same month, within the 90 days before the municipal election — a period prohibited by TSE Resolution No. 23.570/2018.
2. 2Dismissal and new appointment for the same political position within an interval of less than 90 days, with a different holder — a pattern indicative of motivated turnover.

Exclusion by regularity

• Appointments of civil servants approved in public competitive exams (permanent civil service positions are not covered).
• Dismissals at the servant's own request, with no subsequent appointment to the same position.
• Appointments outside the electoral window defined by the TSE.

Legal basis

Federal Constitution, Art. 37, II; TSE Resolution No. 23.570/2018 (prohibition of appointments during the electoral period). Windows defined by electoral cycle (2024, 2026, 2028).

Detection criteria

1. 1An uncommon surname shared between a server appointed to a political position and the mayor, a department head, or a city councilor identified in the same act or in acts from the same period.

Exclusion by regularity

• High-frequency surnames nationally (Silva, Santos, Oliveira, Souza, Lima, among others) do not constitute this type.
• Career civil servants (permanent positions) are expressly excluded — Binding Precedent 13 does not apply to competitive-exam appointees.
• The Agent never asserts kinship. It reports exclusively a surname coincidence — verification is the responsibility of the competent authority and the citizen.
• This is the only Agent with a minimum confidence of 0.95 (instead of the standard 0.70). Findings below this threshold are discarded without issuing an alert — the reputational risk of an incorrect assertion justifies the elevated threshold.

Legal basis

Supreme Court Binding Precedent 13 (prohibition of nepotism in Public Administration); Federal Constitution, Art. 37, caput (impersonality and morality).

Detection criteria

1. 1Contract, budget commitment, or commitment note for institutional advertising services, propaganda, media placements, or official communications, dated within the 90 days before the first round of the municipal election.
2. 2Aggravation when the advertising material nominally mentions the mayor or the current administration — a multiplying factor for the risk score.

Exclusion by regularity

• Notices of grave and urgent public necessity, with express authorization from the Electoral Court (Law 9.504/97, Art. 73, §12).
• Advertising outside the electoral window defined by the TSE.
• Legally mandatory notices (compulsory publication of official acts).

Legal basis

Law 9.504/97, Art. 73, Inc. VI, subparagraph "b" (prohibition of institutional advertising in the 3 months before the election). Windows calculated by election date (cycles 2024, 2026, 2028).

Detection criteria

1. 1Property lease contract on a sole-source basis (inexigibilidade) with no reference to a valuation report or market value in the published act — requirements of Art. 74, Inc. III.
2. 2Contracts with an estimated annual value above R$ 240,000 (equivalent to R$ 20,000/month) without the required justifications.

Exclusion by regularity

• Contracts that explicitly cite a property valuation report or a documented market value reference.
• Leases with a value below the relevance threshold defined by the Agent.

Legal basis

Law 14.133/2021, Art. 74, Inc. III (sole-source for property lease with specific characteristics). The R$ 240,000/year threshold is heuristic — it will be calibrated by city when local real-estate market data is integrated.

Detection criteria

1. 1Per diem with a unit value above R$ 1,500.00, regardless of destination — a value above the cap practiced by the most generous state decree.
2. 2Travel authorization with a departure date coinciding with a national holiday (fixed and variable calendar 2024–2028) or weekend, with no documented urgency justification.

Exclusion by regularity

• Trips with urgency or service-necessity justification duly documented in the act.
• Per diems within the limit set by the current municipal decree for the city under analysis.

Legal basis

Municipal per diem decrees (vary by city — the Agent uses R$ 1,500.00 as a conservative reference; it will be parameterized by city when local decrees are catalogued). National holiday calendar: fixed and variable (Easter, Carnival, Corpus Christi) 2024–2028.

Detection criteria

1. 1Cooperation or support agreement with a civil society organization (OSC/OSCIP) with no mention of a public call for proposals, a documented waiver (Art. 29), or a sole-source justification (Art. 30), when the value exceeds R$ 600,000.
2. 2Three or more transfers to the same CNPJ within a 12-month period without a new formal instrument — a pattern indicative of de facto continuation outside the regulatory framework.

Exclusion by regularity

• Public call for proposals conducted and cited in the act.
• Waiver expressly grounded in Art. 29 (urgency, calamity, education, health, or social assistance services).
• Sole-source justification expressly grounded in Art. 30 (uniqueness of the object or a legally accredited specific entity).

Legal basis

Law 13.019/2014 (Civil Society Organizations Regulatory Framework), Art. 24 (public call as the general rule), Art. 29 (waiver), Art. 30 (sole-source); Arts. 33 and 35 (recurring transfers). Federal Decree 8.726/2016. Reference of R$ 600,000 observed in municipal decrees from RS, SP and MG — not a rigid statutory cap.