O Regulamento do Sistema de Sustentabilidade Financeira (Fair Play Financeiro) da CBF – Confederação Brasileira de Futebol inaugura uma nova lógica de controle no futebol brasileiro.
Não se trata de boas práticas recomendáveis, mas de sistema normativo com efeitos diretos e sancionatórios, que impactam a governança, a gestão financeira e a capacidade competitiva dos Clubes.
Nas próximas semanas, compartilharei breves observações sobre os requisitos do Fair Play Financeiro.
A escolha por iniciar pelo Requisito de Solvência é objetiva: é o primeiro a produzir efeitos práticos imediatos a partir de janeiro de 2026 e funciona como ponto de partida do modelo regulatório.
Seu conceito é simples: o Clube não pode possuir pagamentos em atraso, considerados como qualquer valor não quitado nos termos contratuais ou legais.
Isso abrange obrigações perante outros Clubes, atletas, comissão técnica, funcionários, prestadores de serviços e autoridades públicas, incluindo tributos e encargos sociais.
As obrigações (dívidas) assumidas a partir de 01/01/2026 já estão integralmente sujeitas às regras do Fair Play Financeiro, sem qualquer carência (para aquelas vencidas até 31/12/2025, há regime de transição que se encerra em 30/11/2026).
O impacto, portanto, é próximo e concreto.
A inadimplência deixa de ser apenas um problema financeiro e passa a ser um problema regulatório, sobretudo quando cruza o calendário oficial de verificação.
Com efeito, nas respectivas datas de verificação, o Clube deve declarar que não possui débitos vencidos, por meio de documento assinado pela Alta Direção e submetido à Agência Nacional de Regulação e Sustentabilidade do Futebol (ANRESF), órgão regulador vinculado à CBF:
📅 Calendário regulatório
31/03 (débitos até 28/02)
31/07 (débitos até 30/06)
30/11 (débitos até 31/10)
Veja a seguir o infográfico que resume bem esse cenário:
IMPORTANTE REFORÇAR: O silêncio ou informações imprecisas agravam o risco regulatório.
Havendo inadimplência, a ANRESF, caso seja provocada, intimará o Clube para comprovar a quitação ou apresentar defesa no prazo regulamentar. Essa defesa não é automática nem ampla. Só é admitida quando houver litígio formal (Poder Judiciário, centro arbitral ou órgão jurisdicional do futebol), sustentado por evidência substancial e sem decisão que imponha pagamento imediato.
Esse desenho normativo do deixa claro que a responsabilidade do Clube é objetiva. O cumprimento do requisito sob análise independe da apuração de dolo ou culpa. Com o mero descumprimento, a infração se caracteriza, ainda que a origem do atraso seja atribuída a terceiros, falhas operacionais ou dificuldades financeiras conjunturais.
E as sanções são severas: advertência pública, multa, bloqueio de registro de atletas, retenção de receitas, dedução de pontos, exclusão de competições e, em casos graves, não concessão ou cassação da licença para disputar torneios organizados no âmbito da CBF e rebaixamento.
Ainda há previsão de responsabilização pessoal. Dirigentes, administradores, empregados, conselheiros e controladores (pessoas naturais) que, por ação ou omissão, contribuírem para a infração podem ser punidos individualmente. As sanções vão de advertência e multa até suspensão, inelegibilidade para cargos de direção e, nos casos mais graves, banimento do futebol.
Em suma, o Fair Play Financeiro deixa uma mensagem clara: 2026 não é o começo do debate, é o começo da cobrança.
Quem trata o Requisito de Solvência, base operacional do Fair Play Financeiro, como um tema “para depois” corre o risco de descobri-lo, em breve, como um problema esportivo, institucional — e pessoal.
*David Figueiredo é Compliance Officer do Santos Futebol Clube, responsável pela coordenação do programa de compliance e fortalecimento de práticas de ética, integridade e transparência na gestão esportiva. Com experiência jurídica e foco em conformidade no futebol, atua também em iniciativas de fair play financeiro e governança institucional..
Linkedin: https://www.linkedin.com/in/figueiredodavid/
94 respostas em “Requisito de Solvência: o primeiro teste do Fair Play Financeiro em 2026”
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