Letter from the table: A permit with no clock

Letter from the table

To the Red Tape Council — 1 March 2026

I support the proposed Small Business Impact Standard. I write from Recife, where I see owners lose working days not because they refuse to follow rules, but because it is difficult to know which step is still open, which office has the file, and when an answer should come.

In my own case, I had arranged a modest workspace for a small service business. I will not describe the business further; the point is the licensing experience, which is familiar to owners around me. The lease began on 12 January. I had already completed the business-registration steps involving the Junta Comercial de Pernambuco and the federal registration process. I then turned to the municipal licensing route at the Prefeitura do Recife to establish whether the premises and activity could proceed.

I submitted the documents requested in the digital process on 16 January. I understood that municipal review could include questions such as whether the address and activity were compatible with local requirements. I was not asking to avoid that review. I was asking to understand its progress. The status remained pending, and the online process did not give me a service time or a date by which I should expect either a decision or a request for correction.

On 3 February, I checked again. I also sought help from people who assist small owners with municipal procedures. On 12 February, I followed up through the available contact route. I received no decision that resolved the application. On 24 February, I learned that one document showing the address needed correction. I supplied the corrected document on

27 February. As I write on 1 March, I still do not know how long the next review will take.

The financial cost is not dramatic in one line, but it accumulates. My rent is R$1,850 per month. I spent R$620 on professional help to prepare and check the paperwork, and R$1,440 on scheduled labour while trying to get ready to operate. These are amounts I had to carry before I could plan with confidence. An owner with more cash can wait longer. An owner with less may give up, move, or begin under uncertainty. Around me, I hear the same kind of account: a file submitted, a status that does not explain what is happening, and repeated visits or messages to discover the next step.

This is why I support the Council’s request for a small-business impact test whenever a new rule affecting businesses is proposed. A rule may be sensible and still impose a heavy burden if it requires duplicate documents, unclear sequencing, or a process that assumes the applicant can spend hours chasing updates. The test should ask who must provide each document, whether government already holds it, how much time and money compliance is likely to take, and whether a very small firm can realistically complete the process without paid help.

I also support a one-stop digital process, provided it is genuinely one process for the applicant and not just a single screen that sends the owner to several disconnected offices. The owner should be able to see which authority is responsible for each step, what is outstanding, and how to ask a question. Recife’s procedures may involve different public responsibilities; that should be coordinated behind the service, rather than left to each applicant to reconstruct.

Published service times would make a meaningful difference. They need to say when the clock starts, what pauses it, and when the clock restarts after an applicant supplies a missing item. A status such as “pending” is not a service standard. A dated update and a named next step would let an owner plan rent, staffing and opening costs with more care.

I support a silence-is-consent deadline for permits, with clear safeguards. For a complete application in a low-risk category, the public body should either decide within the published period or explain, before the deadline, what lawful issue prevents a decision. Where health, fire, environmental or other serious risks require a specific review, the standard should make that exception visible and time-bound; it should not become an unlimited exception for every file. The applicant should not be left to guess whether silence means approval, refusal, or simply that nobody has opened the file.

These are not requests to remove public protections. They are requests for rules and services that treat an owner’s time as real, and that make government responsibility visible. A business can comply more reliably when it knows what is required and when the decision will come. For these reasons, my position is support.