On November 11, 2025, Decree No. 12,712/2025 was published, introducing new rules to the Worker’s Food Program, especially regarding payment arrangements, interoperability between card brands, and operator fees.
The changes affect companies in the benefits sector, employers, and, to a lesser extent, workers who use food vouchers and meal vouchers. For workers, there is no financial impact: costs remain the same. The main change is the increased freedom of choice, with an expansion of accredited networks and accepted brands, always preserving the food-related purpose of the benefit.
For employee benefits companies, the impacts are greater. Initially, we would like to point out that closed arrangements remain possible, but operators/facilitators with more than 500,000 workers served must migrate to open arrangements within a period of up to 180 days. Full interoperability between flags must be implemented within 360 days. Employers have a duty to oversee compliance with the rules of the Worker’s Food Program, as well as to provide guidance to workers.
Thus, we highlight 5 points of attention regarding the provisions of the aforementioned Decree:
1. Food Purpose Preserved: The Food Assistance Program continues to be exclusively intended for the purchase of food items and meals.
2. Reinforced prohibitions: The following are prohibited: cashback, discounts, bonuses, undue discounts, exclusivity contracts with establishments, and any anti-competitive practice.
3. Employer’s Duty to Provide Guidance: The employer must instruct its employees on the correct use of payment arrangements. It is recommended to review internal materials, benefits policies, and contracts with payment providers.
4. Employer liability for irregularities: The employer will be responsible for any irregularities caused by them in the execution of the Worker’s Food Program.
5. Standardization of rates, deadlines and interoperability: The decree establishes maximum rate limits, reduces the transfer period to 15 days and sets parameters for interoperability between card brands (integration between systems, allowing the use of the benefit on different networks and payment terminals). The deadline for compliance is 90 days.
The changes focus on the business model of the operators and the contractual structure between companies and facilitators, generating indirect impacts on the management of benefits by employers. For companies in the benefits sector, employers, and employees, the new decree establishes an environment that combines relevant regulatory requirements with opportunities for competitive differentiation. The changes require a review of arrangements, products, and business practices, but they tend to generate positive impacts for workers, who will have greater freedom and scope in using the food benefit, within the purposes foreseen by the Worker’s Food Program.
