Compliance and company details

This page exists for the onboarding, KYB and AML review of banks, payment institutions and partners. Updated on September 11, 2026.

1. Identification

The CNPJ certificate, articles of association and the officers' documents are sent to the analyst on request, through the email above.

2. What PagusPay does

PagusPay provides collections management under mandate: it receives from another company (the principal) the power to collect, in the principal's name, the invoices owed by the principal's customers; reconciles the payments received; keeps the commission set in the contract; and settles the rest to the principal with a statement of account.

The activity of "collecting invoices and debts for clients and transferring the payments received to the clients" is the description of CNAE subclass 8291-1/00 (Atividades de cobranças e informações cadastrais) in the Brazilian statistics office (IBGE) classification.

3. What PagusPay is not

PagusPay is neither a financial institution nor a payment institution under Law 12.865/2013. Specifically, it performs none of the activities listed in art. 6, item III, of that law:

• it holds no payment accounts in the name of end users (art. 6, IV);
• it issues no payment instruments and does not acquire merchants;
• it does not remit funds and does not convert money into electronic money;
• it does not lend and does not advance receivables.

Pix and boleto charges are issued by institutions authorized by the Central Bank of Brazil, of which PagusPay is a customer, into an account held in PagusPay's own name. PagusPay also carries out no foreign exchange operations or international transfers: charging, receiving and settling happen in reais, in Brazil.

4. Legal basis of the mandate

"A mandate exists when a person receives from another the power to perform acts or manage interests in that other's name. The power of attorney is the instrument of the mandate." (Original: "Opera-se o mandato quando alguém recebe de outrem poderes para, em seu nome, praticar atos ou administrar interesses. A procuração é o instrumento do mandato.")Brazilian Civil Code (Law 10.406/2002), art. 653

"The agent is bound to account for its management to the principal, transferring to the principal the benefits arising from the mandate, under whatever title." (Original: "O mandatário é obrigado a dar contas de sua gerência ao mandante, transferindo-lhe as vantagens provenientes do mandato, por qualquer título que seja.")Civil Code, art. 668

Each principal signs a collections services agreement with a grant of powers that sets the commission, the settlement term, the destination account and the frequency of the statement of account. A template of the agreement is sent to the analyst on request.

5. Tax and accounting treatment of third-party funds

Amounts received from payers belong to the principal and are booked as third-party funds in transit, separate from PagusPay's own revenue. PagusPay's revenue is the commission, for which it issues a service tax invoice. Brazil's Federal Revenue Service has settled this reading:

"Funds received for administration on behalf of and for the benefit of third parties do not form part of gross revenue." (Original: "Recursos recebidos para administração por conta e ordem e em benefício de terceiros, não compõem a receita bruta.")Consultation Ruling Cosit no. 40, of January 16, 2017 (corporate income tax and social contribution; Decree-Law 1.598/1977, art. 12; Law 12.973/2014, art. 2)

In the provision of third-party receivables collection services, gross revenue "corresponds to the price of the service" (Original: "corresponde ao preço do serviço"), as set in the contract.Consultation Ruling Cosit no. 276, of September 27, 2024 (corporate income tax, social contribution, PIS/Pasep and Cofins)

6. Flow of funds

1. The principal invoices its customer. The matching Pix or boleto charge is issued in the principal's name with a unique invoice identifier.
2. The payment enters PagusPay's account at the authorized institution and is automatically reconciled against the originating charge. A payment with no match is not kept: it is returned to the payer.
3. PagusPay keeps the contractual commission and issues the service tax invoice to the principal for that amount.
4. The remaining amount is settled by Pix, in reais, to the account held in the principal's name and designated in the contract, within the contractual term. The holder of the destination account is checked against the Pix registry before settlement.
5. The principal receives the statement per charge (amount received, commission, amount settled, date) in the dashboard and at the frequency set in the contract.

Practical consequence for the bank serving PagusPay: the volume passing through the account is always larger than PagusPay's revenue, because the revenue is the commission. The tax invoices issued correspond to the commissions; the settlements correspond to the rest, and each one is tied to a mandate agreement and to identified charges.

7. Principal onboarding (KYB)

Before the agreement is signed, the principal is verified on:

• incorporation documents and proof of existence and good standing in the country of origin or in Brazil;
• identification of officers and beneficial owners;
• business activity, website, product and target customers;
• ownership of the settlement destination account, checked against the Pix registry.

Principals in unlawful activities, gambling, adult content, virtual assets, or without a verifiable commercial relationship with the payers are not accepted. Accounts of principals that cease to meet the criteria are closed and funds in transit are returned or settled as the contract provides.

8. Anti-money laundering

PagusPay maintains an internal anti-money laundering and counter-terrorist financing policy, with principal onboarding checks, monitoring of charges and settlements outside the declared pattern, ownership verification on settlements and record keeping for every operation. The policy is sent to the analyst on request. PagusPay cooperates with information requests from the institutions it works with and from the competent authorities.

9. Data protection

Personal data of payers and of principals' representatives is processed under Law 13.709/2018 (LGPD, Brazil's data protection law), to the extent needed to issue, reconcile and account for the charges. Details in the privacy policy.

10. Documents available on request

• CNPJ certificate and consolidated articles of association
• Officers' documents
• Template collections services agreement with grant of powers
• Anti-money laundering policy
• Description of the operating flow and of settlement controls

Requests by email to suporte@paguspay.com.