In March 2024, the Ministry of Health published Ordinance GM/MS No. 3,232, setting new technical requirements for the information systems used in Primary Health Care (APS). For municipal managers, the rule raises a direct question: is the system my department uses today compliant?
This article explains what changed, what the ordinance requires in practice and what paths are available to become compliant.
What Ordinance 3,232 is and why it matters
Ordinance 3,232/2024 is part of the SUS Digital program - the Ministry of Health's strategy to modernize and integrate the country's health information systems. It defines the minimum requirements that software used by APS teams must meet to ensure the quality of the data sent to SISAB (the Health Information System for Primary Care).
In practice, the rule has three central objectives:
- Standardize the collection of clinical data in primary care, ensuring that records are comparable across municipalities and auditable by the Ministry
- Ensure interoperability between municipal systems and the RNDS (National Health Data Network) - learn more about HL7 FHIR and the RNDS
- Tie federal funding for APS to the quality and completeness of the data municipalities send - understand how to maximize Saúde Brasil 360 funding
This last point is the most critical for managers: municipalities that do not meet the technical requirements risk losing part of the federal funding linked to Saúde Brasil 360.
What the ordinance requires in practice
Compliance with e-SUS APS
The system used by the municipality must be compatible with e-SUS APS - the Ministry of Health's clinical record platform for primary care. This means that the medical records, care forms and procedures performed by family health teams must be recorded in a format compatible with e-SUS.
Interoperability with the RNDS via HL7 FHIR R4
One of the most relevant technical requirements of the ordinance is the ability to send and receive data in the HL7 FHIR R4 standard - the international interoperability standard adopted by the Ministry of Health for the RNDS. Systems that do not support this standard are left out of the national integration network. Read our complete guide to HL7 FHIR R4.
Data quality and completeness
The ordinance defines minimum completeness criteria for the records sent to SISAB. Municipalities with completeness rates below the required level may have their data invalidated for the purpose of calculating federal funding.
Security and data protection
Systems must meet the requirements of the LGPD (Brazil's General Data Protection Law) and adopt information security controls consistent with recognized standards - such as ISO 27001 or equivalent.
Technical Note 12/2025: the most recent requirements
In December 2025, the Ministry of Health published Technical Note 12/2025, complementing the requirements of Ordinance 3,232 with updated technical specifications for integration with the RNDS. The note details the mandatory submission modules, the compliance deadlines and the evaluation criteria that will be used in the 2026 funding cycles.
Municipalities that have not yet started the compliance process should do so urgently - the evaluation cycles are already under way.
How to check whether your current system is compliant
A basic checklist for managers:
- Is the system compatible with e-SUS APS and does it send data to SISAB regularly?
- Does the system support HL7 FHIR R4 for integration with the RNDS?
- Is the completeness rate of the data sent within the required limits?
- Does the system have LGPD compliance documentation?
- Does the vendor hold a Special Certificate from ABES (the Brazilian Association of Software Companies)?
If the answer to any of these items is negative or uncertain, the municipality may be at risk of losing federal funding.
What to do if your current system is not compliant
Compliance can follow two paths:
Updating the existing system: some vendors have already released updated versions that comply with Ordinance 3,232. Ask your current vendor for its compliance timeline and require supporting documentation.
Migrating to a certified system: municipalities with outdated legacy systems can consider migrating to platforms built natively for SUS Digital, which are born compliant with current regulations and are able to keep up with future regulatory updates.
DHF and Ordinance 3,232
The DHF platform was developed to be natively compliant with Ordinance 3,232/2024 and Technical Note 12/2025. This includes integration with e-SUS APS, HL7 FHIR R4 support for sending data to the RNDS, and information security in line with ISO 27001.
The platform's technical uniqueness is attested by a Special Certificate issued by ABES - an entity recognized by the TCU (Brazil's Federal Court of Accounts) for purposes of proving exclusivity in direct public software procurement.
Need help assessing the compliance of your municipality's current system? Talk to our technical team - the initial analysis is free. See also how we implemented the DHF platform in municipalities in the semi-arid region.
