| PROVISIONS FOR TAX, SOCIAL SECURITY, LABOR, CIVIL AND ENVIRONMENTAL RISKS AND JUDICIAL DEPOSITS |
| 22. | PROVISIONS FOR TAX, SOCIAL SECURITY, LABOR, CIVIL
AND ENVIRONMENTAL RISKS AND JUDICIAL DEPOSITS |
Claims of different nature are being challenged at the
appropriate courts. The details of provisioned values and respective judicial deposits related to these actions are presented below:
| Schedule
of accrued amounts and judicial deposits |
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Consolidated |
| |
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Accrued liabilities |
|
Judicial deposits |
| |
|
12/31/2025 |
|
12/31/2024 |
|
12/31/2025 |
|
12/31/2024 |
| Tax |
|
89,522 |
|
130,755 |
|
182,569 |
|
176,086 |
| Social security |
|
13,533 |
|
1,546 |
|
|
|
|
| Labor |
|
486,045 |
|
387,612 |
|
372,571 |
|
294,233 |
| Civil |
|
224,984 |
|
815,180 |
|
34,361 |
|
134,609 |
| Environmental |
|
60,092 |
|
42,609 |
|
6,317 |
|
3,723 |
| Deposit of a guarantee |
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|
|
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25,194 |
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24,299 |
| |
|
874,176 |
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1,377,702 |
|
621,012 |
|
632,950 |
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| Classified: |
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| Current |
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61,455 |
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132,112 |
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|
| Non-current |
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812,721 |
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1,245,590 |
|
621,012 |
|
632,950 |
| |
|
874,176 |
|
1,377,702 |
|
621,012 |
|
632,950 |
The changes in tax, social security, labor, civil and
environmental provisions in the year ended December 31, 2025, can be summarized as follows:
| Schedule
of changes in the provision for tax, social security, labor, civil and environmental risks |
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Consolidated |
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Current + Non-current |
| Nature |
|
12/31/2024 |
|
Additions |
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Accrued charges |
|
Acquisition of stakes in subsidiaries (note 3) |
|
Net utilization of reversal |
|
12/31/2025 |
| Tax |
|
130,755 |
|
22,647 |
|
6,460 |
|
12,691 |
|
(83,031) |
|
89,522 |
| Social security |
|
1,546 |
|
11,997 |
|
66 |
|
|
|
(76) |
|
13,533 |
| Labor |
|
387,612 |
|
93,263 |
|
95,814 |
|
12,093 |
|
(102,737) |
|
486,045 |
| Cívil (1) |
|
815,180 |
|
10,270 |
|
25,418 |
|
44 |
|
(625,928) |
|
224,984 |
| Environmental |
|
42,609 |
|
24,036 |
|
2,203 |
|
|
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(8,756) |
|
60,092 |
| |
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1,377,702 |
|
162,213 |
|
129,961 |
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24,828 |
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(820,528) |
|
874,176 |
| (1) |
Action to discuss ruling handed down against CSN by Brazilian antitrust authorities (CADE) regarding alleged formation of cement cartel
risk classified as follows: possible in the 2nd quarter of 2025, in accordance with the current jurisprudential understanding on the
subject and opinion issued by the Company's legal advisors. " The value of these proceedings exclusively caused a reversal of R$493,000. |
Provisions for taxes, social security, labor, civil and
environmental matters have been estimated by management and substantially substantiated by legal counsel, and only those causes that are
considered probable of loss are recorded. These provisions also include tax liabilities arising from actions taken at the Company's initiative,
plus SELIC (Special System for Settlement and Custody) interest.
Tax Proceedings
The main legal proceedings considered by external legal
consultants as having a probable loss probability, in which CSN or its subsidiaries are parties, of a tax nature are: (i) some ISS tax
infraction notices (ii) divergences between calculated and collected ICMS (iii) Compensation requests not approved due to lack of credit
rights.
Labor Lawsuits
The Group appears as a defendant in labor claims. Most
of the claims in these lawsuits relate to subsidiary and/or joint liability, equal pay, hazard and danger pay allowances, overtime, health
plans, compensation claims for alleged occupational diseases or work accidents, intra-day break periods, and differences in profit sharing
for the years 1997 to 1999 and 2000 to 2003.
During the year ended December 31, 2024, there were additions
and write-offs of labor proceedings due to definitive closures, in addition to the Company's ongoing review of accounting estimates related
to provisions and contingencies. These reviews consider the different types of claims involved, as established in the Company's accounting
policies.
Civil Lawsuits
Among the civil lawsuits in which he appears as a defendant,
there are mainly lawsuits with a claim for compensation. Such processes, in general, result from work accidents, occupational diseases,
contractual discussions related to the Group's industrial activities, real estate actions, health plans.
Environmental Processes
The main environmental proceedings considered by external
legal consultants as having probable loss probability, in which CSN or its subsidiaries are parties, are (i) administrative violation
notices for alleged environmental infractions (ii) annulment lawsuits and tax foreclosures resulting from environmental fines and (iii)
procedural fines for alleged non-compliance with court orders.
Among the environmental administrative/judicial proceedings
in which the Company is a defendant are administrative procedures aimed at verifying possible environmental irregularities and regularizing
environmental licenses. In the judicial sphere, there are actions to enforce fines imposed due to such alleged irregularities and public
civil actions seeking regularization combined with compensation, which consist of environmental restoration in most cases. Such processes
are generally derived from discussions of supposed environmental impacts related to the Company's industrial activities.
Administrative and Judicial Proceedings
The Company does not make provisions for legal proceedings
whose expectation of the Management, based on the opinion of legal advisors, is of possible loss. The following table shows a summary
of the balance of the main matters classified as possible risk compared to the balance as of December 31, 2025, with December 31, 2024.
The Company is involved in other legal proceedings classified
by the legal advisors as a possible loss and therefore represent present obligations for which the outflow of funds is not probable. As
of December 31, 2025, these proceedings involved a total of R$47,419,219 (R$48,454,570 on December 31, 2024), R$2,894,042 of which involve
labor proceedings (R$2,580,452 on December 31, 2024), R$3,845,589 civil proceedings (R$2,964,501 on December 31, 2024), R$38,597,353 tax
proceedings (R$41,326,595 on December 31, 2024), and R$2,082,235 environmental proceedings (R$1,583,021 on December 31, 2024).
| Schedule
of legal matters with possible risk of loss |
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Consolidated |
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12/31/2025 |
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12/31/2024 |
| Notice of Violation and Imposition of Fine (AIIM) / Tax Foreclosure - RFB - IRPJ/CSLL - Capital Gain for alleged sale of equity interest in subsidiary NAMISA(1) |
|
6,554,452 |
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10,246,424 |
| Assessment Notice and Imposition of fine (AIIM) - Income tax and Social contribution - Disallowance of deductions of goodwill generated in the reverse incorporation of Big Jump by NAMISA.(2) |
|
3,512,216 |
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4,346,118 |
| Notice of Violation and Imposition of Fine (AIIM) / Tax Enforcement - RFB - IRPJ/CSLL - Disallowance of prepayment interest arising from iron ore supply and port services contracts |
|
2,264,620 |
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2,284,914 |
| |
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| Notice of Violation and Imposition of Fine (AIIM) / Writ of Mandamus - RFB - IRPJ/CSLL - Profits earned abroad in 2008, 2010, 2011, 2012, 2014, 2015, 2016, 2017 and 2018 (3) |
|
5,858,583 |
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6,239,017 |
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| Unapproved compensation - RFB - IRPJ/CSLL, PIS/COFINS and IPI |
|
2,319,108 |
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2,169,108 |
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| Unapproved compensation - RFB - Disallowance of credits from topic 69/STF (ICMS in the calculation base of PIS/COFINS) (4) |
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751,209 |
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| Assessment Notice - SEFAZ/RJ - ICMS- questions about sales for incentive area (5) |
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1,309,079 |
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1,460,763 |
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| Notice of Violation and Imposition of Fine (AIIM) - RFB - Disallowance of PIS/COFINS Credits for inputs and freight |
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1,875,734 |
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1,499,578 |
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| CFEM – difference of understanding between CSN and ANM on the calculation basis |
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1,715,523 |
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1,570,733 |
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| Notice of Infraction and Imposition of Fine (AIIM) - RFB - Collection IRRF - Business Combinations CMIN 2015 |
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221,203 |
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205,621 |
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| ICMS - SEFAZ/RJ - ICMS Credits for acquisition of Electric Energy Industrialization |
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43,716 |
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39,939 |
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| Notice of Violation and Imposition of Fine (AIIM) - IRPJ/CSLL - Disallowance of deductions of goodwill generated in the acquisition of Cimentos Mauá |
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434,203 |
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422,499 |
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| ICMS - SEFAZ/RJ- Disallowance of the ICMS credits - Transfer of iron ore (6) |
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705,480 |
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779,093 |
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| ICMS - SEFAZ/RJ - Disallowance of credits on purchases of intermediate products |
|
497,950 |
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488,238 |
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| Disallowance of tax loss and negative calculation base resulting from adjustments in SAPLI - RFB |
|
871,652 |
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798,226 |
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| Infraction and Fine Imposition Notices (AIIM) - RFB - IRPJ/CSLL - Transfer Pricing (7) |
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73,556 |
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389,919 |
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| ICMS - SEFAZ/RJ - Transfer of imported raw material for a value lower than the TECAR import document |
|
458,694 |
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422,807 |
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| Assessment Notice and imposition of fine (AIIM)/ Action for annulment - IRRF- Capital Gain of CFM vendors located abroad (8) |
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163,996 |
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338,273 |
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| Other tax lawsuits (federal, state, and municipal) |
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8,357,638 |
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6,977,524 |
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| Social security lawsuits |
|
751,191 |
|
647,801 |
| Action to discuss the balance of the construction contract – Tebas |
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650,979 |
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621,724 |
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| Action related to power supply payment’s charge - Light |
|
551,756 |
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492,535 |
| Action that discusses Negotiation of energy sales - COPEN - CEEE-G |
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247,883 |
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229,983 |
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| Action to discuss the condenation applied by Brazilian antitrust authorities (CADE) to CSN Company about (9) |
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510,404 |
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| Other civil lawsuits |
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1,958,195 |
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1,620,259 |
| Labor and social security lawsuits |
|
3,001,846 |
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2,580,452 |
| Tax Execution Traffic Ticket Volta Grande IV |
|
168,746 |
|
152,322 |
| ACP Landfill Márcia I |
|
306,389 |
|
306,389 |
| Notice of IEF Commitment Term |
|
337,951 |
|
337,951 |
| Other environmental lawsuits |
|
894,523 |
|
786,360 |
| Impact from acquisition of shareholding in Grupo Estrela (10) |
|
50,745 |
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| |
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47,419,220 |
|
48,454,570 |
| (1) |
Notice of Violation and Imposition of Fine (AIIM) - IRPJ/CSLL - Capital Gain for alleged sale of equity interest in subsidiary NAMISA:
On 12/29/2025, a mandatory fine and interest were canceled through the application of Federal Law 14.689/2023, which lead to a reduction
of R$4 billion in liabilities. |
| (2) |
Notice of Violation and Imposition of Fine (AIIM)- IRPJ/CSLL - Disallowance of goodwill deductions generated in the reverse incorporation
of Big Jump by Namisa. On 09/05/2025, the Company succeeded in requesting a mandatory debt review for the cancellation of a fine and
interest under Law 14.689/2023. |
| (3) |
Notices of Violation and Imposition of Fine (AIIM) / Writ of Mandamus - RFB - IRPJ/CSLL - Profits earned abroad in 2008, 2010, 2011,
2012, 2014, 2015, 2016, 2017 and 2018 Adjustments were made to contingencies so that they accurately reflect the updated values according
to the indexes determined by the Public Treasury, contained in the statements issued by the Government. |
| (4) |
Unapproved compensation - RFB - Disallowance of credits under 69/STF theme (ICMS in PIS/COFINS calculation basis) in March 2025, CSN
was informed of the rulings that partially approved the compensations executed with credits arising from the final and unappealable lawsuit
recognizing the unconstitutionality of the inclusion of ICMS values in the PIS and COFINS contribution calculation basis. According to
the federal supervisory body, approximately 20% of the credit authorized by the company would lack sufficient liquidity and certainty
and therefore, could not compose the amount to be offset. Given these rulings, CSN presented a manifestation of non-conformity to demonstrate
the inappropriateness of the premises adopted by the supervisory body and liquidity and legal certainty underpinning complete authorized
credits. |
| (5) |
ICMS - SEFAZ/RJ - Questions about sales for Incentive Area Adjustments were made to contingencies so that they accurately reflect the
updated values according to the indexes determined by the Public Treasury, contained in the statements issued by the Government. |
| (6) |
ICMS - SEFAZ/RJ - Disallowance of credits on Transfer of Iron Ore Adjustments were made to contingencies so that they accurately reflect
the updated values according to the indexes determined by the Public Treasury, contained in the statements issued by the Government. |
| (7) |
Notices of Violation and Fine Imposition (AIIM) - RFB - IRPJ/CSLL - Transfer Pricing the Company partially succeeded in the Appeal filed
in Case 16682.720.529/2023-56, closing a possible contingency of R$212,691. |
| (8) |
Notice of Violation and Imposition of Fine (AIIM) /Annulment Action - RFB - IRRF - Capital Gain of CFM company sellers located abroad
with support in legal opinion, the prognosis of possible remote loss on mandatory fine and interest was reclassified, as the disallowance
determined by Federal Law 14.689/2023 is applicable to the case |
| (9) |
Action to discuss ruling handed down against CSN by Brazilian antitrust authorities (CADE) regarding alleged formation of cement cartel
risk classified as possible in the 2nd quarter of 2025, in accordance with the current jurisprudential understanding on the subject and
opinion issued by the Company's legal advisors. |
| (10) |
Reflection of the acquisition of equity interest in Grupo Estrela regarding the acquisition of a stake in Grupo Estrela on April 1, 2025.
According to CPC 15 (R1) – Business combination, the Company has one year, as of this date, to form the respective business combination,
which may impact the recorded fair value within this period based on an appraisal report. The acquisition of this company generated a
possible contingency increase on December 31, 2025. |
In the 1st quarter of 2021, the Company was notified
of the start of an arbitration proceeding based on an alleged breach of iron ore supply contracts. The opposing party's claim at that
time totaled approximately US$1 billion, and the Company understands the allegations presented to be unfounded by the complete absence
of damages, based on the assessment of its legal advisors. The Company wishes to inform that it has prepared, together with its legal
advisors, a response to the arbitration request and is currently preparing its defense. It also wishes to clarify that discussions involve
ongoing arbitration disputes initiated by both parties. It is also estimated that the arbitration will be completed in approximately 12
months. The relevance of the proceedings for the Company is related to the value attributed to the case and the possible financial impact.
The Company has offered judicial guarantees (Surety Bond/Letter
of Guarantee) in the total and updated amount as of December 31, 2025, of R$11,020 (R$10,620 as of December 31, 2024), as determined under
current procedural legislation.
The evaluations carried out by legal advisors define
these administrative and judicial proceedings as a possible risk of loss and are not provisioned in accordance with Management's judgment
and accounting practices adopted in Brazil.
Accounting Policy
Provisions are only recorded when classified as probable
loss risk, estimated and considered by Management, substantially based on the assessment of its legal advisors, and when resources will
be necessary to settle the obligation. This obligation is updated according to the evolution of the lawsuit or financial charges incurred
and may be reversed if the estimated loss is no longer considered probable due to changes in circumstances or written off when the obligation
is settled.
Contingent liability recognized under a business combination
is initially measured at its fair value. It is subsequently measured at the higher of the amount that would be recognized in accordance
with the provision requirements above or the amount initially recognized less (when appropriate) accumulated amortization recognized in
accordance with revenue recognition requirements.
|