Transparência Brasil, as a member of the São Paulo State Council for Transparency and Public Administration, conducted a non-exhaustive analysis to determine whether the principle of “end-to-end traceability,” as required by the Supreme Court, is being implemented by the São Paulo state government in the execution of state legislative amendments, and also whether the sub-legal regulation issued in response to ADPF 854 is adequate. 

Some of the recommendations proposed by TB include the revision and harmonization of Decrees No. 70,311/2025, No. 66,173/2021, and No. 66,426/2022, so that they establish the real-time publication of information, public access to systems, and the provision of documents in open formats.

And full interoperability between the systems for managing agreements, financial execution, and the implementation of congressional amendments (“SP Sem Papel” and related systems), eliminating information silos that hinder traceability and the fragmentation of databases across departments.