Letter from the Table: A Permit Clock Must Start with a Clear Question

To the Red Tape Council

I support the purpose of RT-001, but my position is amend. At our last council session, I understood more clearly why the same word, “delay,” can describe very different experiences. A clock is useful only if a small business can tell when it starts, what has stopped it, and who is responsible for the next step. I ask the Council to make those points explicit in the draft.

My case is from Recife. I am a member of this Assembly, and I will not name my business. It is a small service operation, and I needed to establish what permissions applied to its address and activity before I could begin operating there. I used the integrated registration and viability route available through REDESIM in Pernambuco, which is connected with the state commercial registry, JUCEPE. I also had to seek information from the Prefeitura do Recife about municipal land-use and operating requirements. These are related steps, but they are not the same decision, and knowing which office had the next action was part of the problem.

On 6 February 2026, I began checking whether the activity and location could proceed. On 11 February, I sent the information I had been asked to provide. On 19 February, I received a request to clarify the activity and how the space would be used. I supplied that clarification on 2 March. On 16 March, the online status still showed the matter as under review. I do not present this as proof that an official acted improperly. The difficulty was that I could not see a published service time for this kind of review, or a reliable way to know whether my file was complete and which authority held it.

While I waited, costs continued. My monthly rent was R$1,480. I paid R$350 for an accountant’s time to help me understand the registration and licensing questions, and I set aside R$420 for a scheduled setup task that I could not carry out as planned. Those amounts are not a claim about a government fee. They are the ordinary cost to a very

small operator of keeping a decision open while trying not to proceed without the necessary approvals.

I tried to solve the problem in the way a careful applicant is expected to solve it: I checked the online route, sent the requested information, clarified the activity, and sought help to understand which process applied. What I needed was not a promise that every permit would be granted. It was a clear statement of the applicable process, a list of complete requirements, and a date or time range for the next decision. If another authorization—such as fire-safety approval, where applicable—was separate from the municipal review, I needed that distinction made visible rather than having to infer it.

The lesson I took from the council session was that our proposed “one-stop” process must not merely place several offices behind one web page. It should let an applicant see the responsible authority, the next action, and the status of each part of the application. A service-time promise should also distinguish time spent by the administration from time when an applicant is waiting to answer a specific request. If the clock pauses, the applicant should receive a dated notice explaining what is missing, why it is needed, and how to submit it. After the response is received, the clock should resume without the applicant having to begin again.

I ask the Council to amend RT-001 in four ways:

• Require each process to publish its scope, required documents, responsible office, service time and a way to check status, in language a small operator can understand.

• Start the service clock when the application is received, and allow it to pause only for a specific, written request for information. Record both the pause and the date the applicant responds.

• Make the one-stop process coordinate offices without suggesting that one approval replaces another. It should show separate decisions when municipal land use, fire safety or other applicable requirements are handled separately.

• Keep “silence is consent” as a possible remedy for a defined class of low-risk permits, but require clear exceptions and a review route. It should not override rules protecting public safety, environmental health, or land-use decisions where an automatic approval would put others at risk.

A predictable process would have changed my experience even if the final answer had been the same. I could have planned rent and setup costs with better information, and I could have corrected an incomplete file sooner. For the Council’s Days to Open work, I hope we measure not only the number of days until an approval, but also how many days an applicant spends without knowing who has the file or what is expected next.