compliance teamCONAI regularisation and autodenuncia: conditions and evidence
Step 1
Reconstruct periods and data
Step 2
Confirm no control has begun
Step 3
File disclosure and declarations
Step 4
Pay and retain every record
| Control | Evidence to retain |
|---|---|
| Scope | Entity, product, channel, stream and source |
| External action | Version, date, authorised filer and issued receipt |
| Maintenance | Source data, approval, invoice and next deadline |
Reconstruct the facts before contacting CONAI
Identify the responsible entity, activities, sales channels, packaging components, quantities, available invoices and periods. Separate measured data from estimates and document every assumption.
Do not backdate membership, mandates or receipts. The purpose is to disclose a true historical position and correct the present file.
Autodenuncia has strict conditions
A member can disclose a consortium-rule infringement spontaneously before CONAI controls begin. Interest remains due, but CONAI sanctions under its consortium rules are not applied when the stated conditions are satisfied.
The due declarations must be sent within thirty days of the disclosure and the resulting CONAI invoices paid by their deadlines. Missing a condition can remove the benefit, and the procedure does not promise immunity from statutory or state sanctions.
The facilitated route still requires full cooperation
CONAI's facilitated procedure can limit the examined period to the previous five years and permit instalments of contribution and interest for up to thirty-six months.
These are conditional consortium procedures, not guarantees from a private provider. Preserve the disclosure, filings, payment plan, invoices and receipts.
Conclusion
Scope comes before a form. Connect the legal entity, product, sales channel and EPR stream to the rule that actually applies.
Evidence must remain traceable. Keep source data, versions, approvals, filings, receipts and every record issued by an external body.
Third-party decisions are never guaranteed. CONAI, public registers, collective systems and marketplaces control their own procedures, timing and decisions.