On September 25th, 2020, ANATEL has issued an official document announcing another extension to the exception for renewals due to COVID-19. This regulation was last published on June 22nd and can be found here. The following was said: For all renewals (with no changes in the equipment) in which the technical certificate will expire from March 06, 2020, until December 31st, 2020, the renewal can be processed only with the Renewal Letter (no pictures and any other document is needed).
