Yes. The CBF Financial Sustainability System is already valid in 2026, but it is not valid with the same intensity in all of its pillars. The most important difference is this: overdue debts linked to obligations assumed from January 1, 2026 are already in full application, while sustainability, roster costs and short-term debt are still undergoing adaptation schedules. Therefore, just saying that fair play is "already valid" or that "the ceiling is 45%" produces an incomplete picture.
For Corinthians, Palmeiras, São Paulo and Santos, the practical question is not just how much each club owes. It is necessary to identify which requirement is being analyzed, when the obligation was created, which financial year will be measured and whether that rule is in transition or in full application. The recent case of São Paulo shows that this distinction already has concrete consequences.
The short answer: the SSF is two-speed in 2026
The Financial Sustainability System Regulation, administered by the CBF and supervised by ANRESF, separates implementation into a Transition Period and a Full Application Period. In the transition period, art. 90 establishes an educational nature and exclusively provides for warnings for non-compliance with the requirement. In full application, the sanctions of the regulation come into play, depending on the process and the seriousness of the case.
The solvency rule is the exception that matters most in 2026. Obligations assumed before January 1, 2026 are in transition until November 30, 2026. Obligations assumed from January 1, 2026 come into full application immediately. This includes, among other points, transfer payments, salaries, image rights and obligations with public authorities within the perimeter monitored by the regulation.
In the other three most mentioned axes when talking about fair play - sustainability, squad costs and short-term debt - 2026 is a year of measurement and adaptation. The results for the 2026 exercise will be delivered to ANRESF on April 30, 2027. For this exercise, non-compliance with the requirements is still within the educational phase provided for by the regulations.
What could already generate sporting consequences in 2026
Overdue debt is the most sensitive point now
The solvency requirement obliges clubs to prove, on March 31st, July 31st and November 30th, the absence of late payments on the fronts covered by the SSF. ANRESF includes obligations with other clubs in transfers, debts with employees and commitments to public authorities. The creditor can also report a registered default.
For new obligations, assumed since January 1, 2026, there is no transition shield. Default can open a sanctioning procedure and, in certain situations, lead to blocking in the National Registry System, preventing new registrations until regularization or until an agreement is formally communicated by the creditor.
This is different from the short-term debt indicator. A club can have a heavy balance sheet and still not be in default on a specific obligation; can also suffer a solvency consequence for an overdue installment without the debate depending on reaching 45% of any indicator. These are different regulatory tests.
The São Paulo x Novorizontino case shows the rule working
On August 12, 2026, ANRESF upheld, in the first instance, Grêmio Novorizontino's complaint against São Paulo for a transfer obligation contracted on January 7, 2026. According to the Agency's statement, São Paulo did not deny the debt nor did it prove payment or hypothesis that would rule out the characterization of the delay.
The decision determined full payment, with the expected charges, within 45 days. If the issue is not resolved within this period, the club will be prevented from registering new athletes until payment is made or until the creditor formally communicates an agreement. The decision allows appeal to the ANRESF Plenary.
The regulatory point is more important than the name of the club: as the obligation was assumed after January 1, 2026, it fell directly into the full application of the solvency requirement. This is the best example, so far, of why the SSF can already have a concrete effect in 2026 without waiting for the final debt ceiling.
What is valid, but still undergoing transition
Operational balance: 2026 is measured, but it is still an educational phase
The sustainability requirement compares relevant revenues and relevant expenses to determine the Operation Result. The regulation allows specific adjustments and treats long-term investments separately, such as grassroots, women's football, social projects and infrastructure, within the conditions set out in the technical annex.
The calculations for the years 2025 and 2026 are in the Transition Period. For 2026, compliance will be assessed based on the Operating Result of that year and delivery will take place on April 30, 2027. As this investigation is still in the educational phase, any failure to comply with the requirement in 2026 subjects the club to a warning, not the full menu of penalties.
As of the 2027 calculation, delivered in April 2028, the regulation has already left this transition phase for the requirement. This is when history begins to gain greater regulatory weight and operational balance stops being just a sign of adaptation.
Casting cost: 2026 cap is 90%, not 70%
The squad cost indicator adds up expenses with relevant people in the main team, amortization and athlete registration costs and certain costs of agents, intermediaries and related parties. The denominator combines operating revenues, average net result from transfers and equity contributions, in accordance with the technical definitions of the regulation.
For Serie A clubs, the structural ceiling provided for in art. 60 is 70%. However, this is not the limit applied to the 2026 financial year. The transitional rule sets 90% for the 2026 assessment, to be delivered on April 30, 2027. This assessment is still in the period in which the consequence for non-compliance with the requirement is a warning.
For the 2027 financial year, delivered in April 2028, the Series A ceiling drops to 80% and the transition has already ended. Afterwards, the structural limit of 70% will prevail. Therefore, a number that appears definitive when read in isolation in the regulation should not be applied retroactively to 2026.
Short-term net debt: why 45% does not automatically punish in 2026
Here is the main source of confusion. The art. 63 establishes 45% as the structural limit for the Short-Term Debt Indicator. But the art. 94 creates a specific ladder: 70% for the 2026 fiscal year, 60% for 2027, 50% for 2028 and 45% for 2029.
In addition, the calculation for 2026 will only be delivered on April 30, 2027 and is still part of the Transition Period. Therefore, exceeding the limit applicable to the 2026 exercise does not automatically mean receiving loss of points, transfer ban or other sporting punishment in that year. For the requirement in transition, the regulation reserves the warning.
From the 2027 financial year onwards, the scenario changes. The limit is now 60%, delivery takes place in April 2028 and the educational phase has already ended for this requirement. In 2028, the reference drops to 50%. In 2029, it will reach 45% structural. When some public chronologies appear to shift these percentages by one year, the reason is usually the difference between the year of the measured exercise and the year of delivery: the photograph of 2029, for example, is presented in April 2030.
The SSF account is not current liabilities divided by revenue
Another common mistake is to take the current liabilities from the balance sheet, divide it by the published revenue and conclude that the club "has breached fair play". The regulation does not make this simplified account.
Short-Term Net Obligations, or OLCP, takes short-term general obligations and transfer obligations and subtracts short-term liquid assets. The methodology excludes, for example, current operational liabilities that have not yet expired, such as current month's payroll or regular suppliers, and includes specific categories such as loans, labor debts due or agreed, taxes within defined conditions, agreements and transfers.
The denominator also requires care. RSSF's Relevant Revenues are not limited to sponsorship, box office and TV. The annex to the regulation includes operating revenues, financial revenues and revenue from athlete transfers, minus the expected adjustments. Therefore, the official indicator can only be calculated with the complete regulatory classification, reconciled with the audited financial statements.
This difference is decisive when comparing the four big cities in São Paulo. Public balance sheets help to see cash pressure and debt structure, but they do not authorize, alone, to state that a club is above or below 70%, 60%, 50% or 45% of the SSF.
Corinthians: the immediate pressure is cash and default, not a 45% trigger
The 2025 balance sheet taken to Corinthians bodies recorded a deficit of R$143.4 million and gross debt of R$2.723 billion, according to the numbers released by ge based on the document. Net operating revenue was R$810.1 million. This data shows the extent of the financial pressure, but does not, in itself, form the RSSF's debt indicator.
The discussion with Memphis Depay made this point more visible. On August 17, UOL reported that the club's financial area saw a renegotiation as a way of reducing and lengthening the pressure of the player's debt on short-term obligations. On the evening of the same day, President Osmar Stabile confirmed the renewal of Memphis until mid-2028, with reduced values compared to previous negotiations.
For the SSF, however, the effect cannot be deduced solely from the advertised nominal value. What matters is how the obligation is formalized, which installments are due in each period, which amounts fall into the regulatory categories and whether there is a delay in an obligation covered by solvency. A renegotiation can change the temporal profile of the debt, but it is not possible to transform the news into an official percentage without regulatory data.
In 2026, Corinthians' most immediate exposure is precisely the same that applies to any club: if an obligation assumed from January 1, 2026, within the perimeter of solvency, becomes due without regularization or valid agreement, the regime is already complete. The 45% ceiling does not function as an automatic punishment button in this exercise.
Palmeiras: strong numbers do not dispense with regulatory calculation
Palmeiras' annual report reports gross operating revenue of R$1.7 billion and an accounting surplus of approximately R$292 million in 2025. The document also records Total Debt of approximately R$1.13 billion and states that, on December 31, 2025, the liabilities were fully recorded and renegotiated, with no outstanding debt, with the current liabilities provisioned in the 2026 cash flow.
This statement is relevant to the solvency photograph at the balance sheet date, but does not act as a permanent certificate of compliance. New obligations assumed in 2026 remain subject to the full regime if they are delayed. Likewise, the fact that the published current assets are smaller than the current liabilities does not allow concluding a violation of the short-term indicator, because the ANRESF formula makes its own inclusions, exclusions and compensations.
For Palmeiras, therefore, the reading of 2026 is less about applying the 45% to the published balance sheet and more about monitoring three fronts: maintaining compliance with new obligations, evolution of the roster cost within the regulatory ladder and official calculation of the OLCP when ANRESF receives the assessment for the year.
São Paulo: the most concrete exposition has already appeared in solvency
São Paulo ended 2025 with a surplus of R$56.981 million. In the published statements, current assets were R$605.656 million and current liabilities were R$1.038 billion. This difference shows a short-term structure that deserves attention, but it also illustrates why the accounting balance cannot be confused with the SSF formula: current liabilities include items that need to be treated according to ANRESF definitions, and the indicator still deducts eligible liquid assets.
The regulatory exposure effectively proven in 2026 came through another door. The obligation with Novorizontino was born in January, entered the full solvency regime and generated the decision of August 12th. If there is no payment or formal agreement under the terms of the decision, the expected effect is to block new registrations. It is a concrete and separate consequence of the debate about 45% debt.
This case also serves as a warning to other clubs: in the SSF, an overdue installment of a 2026 contract may be more urgent, in the short term, than a structural indicator whose exercise is still in the educational phase.
Santos: the swing draws attention to the trajectory, does not prove an infraction
Santos' audited statements show a picture that requires careful reading. The management report recorded total revenues of R$678.5 million in 2025 and a final accounting deficit of R$79.396 million. In the balance sheet, current assets were R$232.448 million and current liabilities were R$470.741 million. Net equity was negative at R$609.367 million.
The report itself distinguishes between operational debt and historical debt, which helps to understand the composition of obligations. Still, these internal club categories are not automatically the same as the OLCP in the regulations. To assert a violation of the ANRESF requirement, it would be necessary to redo the classification according to Annex C, identify the eligible liquid assets and use the RSSF Relevant Revenues.
For Santos, the numbers make the trajectory of operational balance and liquidity especially important as limits tighten and the regime leaves the educational phase. But the rule remains the same: in 2026, a new overdue debt can trigger solvency immediately; the 2025 balance sheet, in isolation, does not authorize saying that the club has already suffered or will suffer punishment due to the final ceiling of 45%.
What ANRESF can apply when the rule is in full operation
The sanctions regime does not work like an automatic table in which each percentage generates a fixed penalty. ANRESF informs that each case is analyzed individually, with proportionality, progressiveness, aggravating and mitigating factors.
The regulation provides for a scale that may include public warning, fine, withholding of revenue, restriction of athlete registration, deduction of points, exclusion from competitions and revocation of license with demotion. The existence of this menu, however, does not mean that all of these penalties are available for any non-compliance on any date. During the Transition Period of a requirement, art. 90 limits the consequence to warning.
That's why the calendar matters as much as the number. A transfer debt assumed in January 2026 and due today may fall into the full solvency regime. The calculation of short-term debt for the year 2026 uses the transitional limit of 70% and remains in the educational phase.
The three dates that organize the rest of 2026
On November 30, clubs carry out the third annual solvency test and the transition granted to obligations assumed before January 1, 2026 also ends. On December 15, the first mandatory budget delivery, referring to the 2027 season, expires. And on April 30, 2027, the calculations relating to the 2026 financial year for sustainability, squad costs and debt.
These dates show why 2026 is not a year without fair play nor a year of full application of all final ceilings. The system already produces consequences in what the CBF and ANRESF decided to put into full operation, while measuring and forcing adaptation in structural indicators.
So, what can reach every São Paulo resident now?
Corinthians, Palmeiras, São Paulo and Santos are subject to the same regulatory architecture. What changes is the financial picture and the existence, or not, of overdue obligations in each case. Today, the most direct gateway to sanction is the solvency of commitments made since January 1, 2026. São Paulo has already received a decision on this axis; the others need to keep their new obligations regularized so as not to enter into the same type of procedure.
Operational balance, squad costs and short-term debt are important for planning and adaptation now, but should not be presented as if all final ceilings already generate punishments in 2026. For squad costs, the exercise reference is 90%. For net short-term debt, it is 70%. And both 2026 assessments are still in the period in which non-compliance with the requirement leads to a warning.
The synthesis that avoids ambiguity is simple: the CBF's financial fair play is already valid in 2026, but the 45% is the structural target for short-term debt for the 2029 financial year, not an automatic punishment trigger in 2026. To know the real risk of each club now, we first need to ask which pillar, which obligation and which fiscal year we are talking about.
