PisoGate — freight-floor gate for Brazilian shippers

1. One-liner

Prices a truckload against the ANTT floor before your billing clerk releases the vehicle, so the CIOT never blocks.

2. Trend signal — why now?

Three things landed in Brazil between March and August 2026 that turned freight-floor compliance from an ignorable formality into a hard operational gate:

• The CIOT became a blocking filter on 24 May 2026. Under Portaria SUROC nº 6/2026 and Resolução ANTT nº 6.078/2026, if the declared freight value is below the minimum floor, the system refuses to generate the CIOT. ANTT’s own announcement is blunt about it: “o sistema bloqueia o registro, o CIOT não é gerado e a operação não existe.” No CIOT means no MDF-e, which means the truck legally cannot leave.
• Lei nº 15.485/2026 was sanctioned on 5 August 2026 — nineteen days before this writing. It makes CIOT mandatory for every remunerated transport operation, mandates CIOT-to-MDF-e linkage (R$ 10,500 fine per failure, cumulative), caps freight payment at 30 business days, closes the TAC-agregado loophole, and creates a reincidence penalty tier reaching R$ 1,000,000 plus RNTRC suspension (5–30 days preventive, 15–45 days as penalty) and cancellation up to 24 months for repeat offenders.
• Enforcement is already at scale and electronic. ANTT applied R$ 932.4 million in minimum-floor fines in 2026 through 30 June alone, driven by automated cross-referencing of CIOT, MDF-e, CT-e and other fiscal documents. This is not a “they’ll never check” regime.

Two more facts sharpen the timing. The floor table itself moved hard — Resolução nº 6.084/2026 updated the coefficients, and the displacement coefficient (CCD) for a 5-axle truck went from R$ 3.3706 (2020) to R$ 6.6983 (2026), roughly doubling. Loading/unloading coefficients (CC) similarly jumped from R$ 451.84 to R$ 903.32 for general cargo and R$ 520.07 to R$ 1,067.06 for refrigerated or heated loads. Whatever freight rate a shipper had memorized is now wrong.

And critically, the obligation reaches beyond logistics companies: “sempre que uma empresa contratar um transportador autônomo (TAC) ou equiparado, terá que gerar o CIOT e pagar o frete por um meio homologado, mesmo que a empresa não tenha como atividade fim o transporte.” The factory, the grain co-op, the building-materials distributor — none of them are transport companies, and all of them are now on the hook.

Provenance:

• Signal 1: ANTT turns CIOT into a blocking filter — freight below the floor cannot be registered, effective 24 May 2026 — https://www.gov.br/antt/pt-br/assuntos/ultimas-noticias/frete-irregular-e-barrado-antes-de-existir-antt-transforma-ciot-em-filtro-obrigatorio-e-reforca-o-cumprimento-do-piso-minimo — August 2026
• Signal 2: Lei nº 15.485/2026 sanctioned 5 Aug 2026 — mandatory CIOT, CIOT/MDF-e linkage at R$ 10,500 per failure, fines to R$ 1M, RNTRC suspension and cancellation — https://www.mattosfilho.com.br/unico/lei-descumprimento-pisos-frete-rodoviario/ — August 2026
• Signal 3: ANTT applied R$ 932.4 million in minimum-floor fines in 2026 through 30 June, via electronic cross-checking of CIOT, MDF-e and CT-e — https://mundologistica.com.br/noticias/antt-aplicou-quase-1-bilhao-multas-piso-minimo-do-frete-2026 — August 2026 Category: Regulatory arbitrage

3. The opportunity

The gap is between who the software serves and who the law now punishes.

Freight software in Brazil is built for people whose business is freight. nstech, Target Bank, Bsoft, Frete.center (Embarcador plan at R$ 197/mês), the TMS vendors — they sell to transportadoras and to logistics departments that have a logistics department. Their products assume a freight desk, a fleet, a dispatcher, and someone who already knows what a CCD coefficient is.

Lei 15.485/2026 does not care whether you have a logistics department. If you hire an autonomous trucker, you are the contratante: you issue the CIOT, you verify the floor, you link it to the MDF-e, you pay inside 30 business days, and you eat the fine when any of that slips. The company most exposed is precisely the one with the least tooling — a mid-sized industrial or agricultural business that ships 20–200 truckloads a month, hires TACs on the spot market, and handles the paperwork with a billing clerk, a browser tab open on calculadorafrete.antt.gov.br, and a spreadsheet someone built in 2021.

That clerk now faces a new failure mode. The trade press describes it exactly: “o setor de faturamento precisa ter muita atenção aos cálculos antes de liberar o caminhão… o sistema trava a emissão do CIOT… para evitar que o veículo fique parado no pátio.” Before May 2026, guessing the freight rate wrong produced a theoretical fine that probably never arrived. Now it produces a truck stuck in the yard, a driver who cannot legally start the trip, a customer’s delivery slipping, and demurrage. The cost of being wrong moved from “someday, maybe” to “right now, in front of everybody.”

What the incumbents do badly for this buyer:

• ANTT’s official calculator is free but single-shot. You type in axle count, cargo type and distance, and it gives you one number. It doesn’t know your lanes, doesn’t remember last month, doesn’t warn you that a resolution changed the coefficients, doesn’t produce a defensible record, and doesn’t sit inside your hiring workflow.
• TMS platforms are priced and shaped for freight operators. R$ 197/mês is not the barrier — the barrier is that onboarding assumes you run transport as a business line. A furniture factory shipping 40 loads a month will not implement a TMS to solve a pricing question.
• Accountants and despachantes handle this reactively. They see the problem after the autuação arrives, which is the expensive end.
• Nobody is selling the defense file. Every citation goes through an administrative process with full right of defense. Whether you win depends on whether you kept the floor calculation, the contract, the CIOT, the linked MDF-e, and the payment proof for that specific trip. Almost nobody is keeping that bundle per-trip today.

The 10× is not the arithmetic — the formula is public and simple (Piso = (CCD × km) + CC). The 10× is doing it at the moment of hire, from the messy inputs a non-logistics company actually has, and leaving behind a record that survives an ANTT process.

4. Target market

• Primary customer: The billing/faturamento or supply lead at a Brazilian industrial, agricultural or distribution company with R$ 10M–R$ 300M revenue, shipping 20–200 truckloads/month, hiring autonomous truckers (TACs) on the spot market, with no TMS and no dedicated logistics department. Think: grain and input co-ops in Mato Grosso, Paraná and Goiás; ceramics and furniture plants in Santa Catarina; building-materials and steel distributors in São Paulo interior; sugar/ethanol suppliers; fertilizer and packaging distributors.
• Why they buy: Because the truck is at the dock and the CIOT won’t generate. The immediate pain is not the fine — it’s the vehicle idle in the yard while somebody re-does the math, plus the compounding exposure that at R$ 10,500 per CIOT failure, cumulative across separate infractions on a single freight, a bad month is a real number. Layered on top: under Lei 15.485/2026 a shipper who contracts below the floor owes the trucker indemnity of up to twice the floor value — a private-law liability entirely separate from the administrative fine, and one a trucker’s union will happily pursue.
• Rough TAM reasoning: ANTT’s registry records roughly 823,000 autonomous transporters and ~161,000 transport companies. Every remunerated hire of a TAC now needs a contratante-issued CIOT. I’m not chasing the 823k truckers — I’m chasing the companies that hire them. Conservatively, Brazil has tens of thousands of non-transport firms shipping at meaningful volume; 8,000–15,000 fit the profile of “enough loads to feel the pain, too small to run a TMS.” At R$ 400–900/mo that’s a R$ 40M–160M/yr addressable band. I only need a low-single-digit share.
• Why now for them: Three dates. 24 May 2026 (CIOT starts blocking), 5 August 2026 (Lei 15.485 hardens the penalties and closes the agregado loophole), and Resolução 6.084/2026 (coefficients roughly doubled versus 2020). Any internal rate table older than this year is now actively dangerous.

5. Product sketch (MVP)

• Pre-hire floor check. Enter origin, destination, cargo type and axle count — get the ANTT floor for that operation, plus the delta against the rate you were about to agree. Answers the only question that matters before the driver is booked: can I legally hire at this price?
• Lane memory. Your recurring routes are saved with their distances and cargo profiles, so the recurring 80% of trips is one click, not a fresh calculator session. This is where the daily habit forms.
• Resolution watch. When ANTT publishes a new floor resolution, every saved lane is re-priced automatically and the user gets a diff: “these 14 lanes are now below floor — your standard rate on Rondonópolis→Santos no longer clears.”
• CIOT-ready packet. Assembles the fields the CIOT requires (parties, freight value, payment terms, cargo, origin/destination) so the value submitted to the issuing platform is the one that will clear, and flags the mandatory MDF-e linkage before it becomes a R$ 10,500 omission.
• Payment clock. Tracks the 30-business-day payment deadline per trip and warns before it lapses.
• Trip defense file. Every check is stored as a timestamped record — the floor calculation with the coefficients in force that day, the agreed value, the CIOT reference, the MDF-e link, the payment proof. Exportable as a single PDF per trip or per period. This is what you hand your lawyer when the autuação arrives.
• WhatsApp check. The dock supervisor sends the route and truck config to a WhatsApp number and gets the floor back in seconds. Brazil runs on WhatsApp; the person standing next to the truck is not going to open a web app.
• Exposure summary. A monthly view: trips checked, trips that would have been below floor, estimated fine and indemnity avoided. This is the renewal argument, in the customer’s own numbers.

6. AI angle — what’s load-bearing

Remove the AI and this product still exists as a calculator — so I need to be honest about where the AI actually carries weight, and it’s not the formula.

Piso = (CCD × km) + CC is arithmetic. The AI does the two things that are genuinely hard for a non-logistics company:

1. Turning mess into parameters. The inputs to the formula are a specific cargo classification, an axle count, and a road distance. What the customer actually has is a WhatsApp message saying “carreta de adubo pra Rondonópolis, 3 eixos ou 4?”, a nota fiscal PDF, and a purchase order. Extracting cargo type, inferring the correct ANTT cargo category (general vs. refrigerated/heated vs. bulk vs. dangerous — categories with materially different CC values), resolving the origin/destination to a routed road distance, and asking a clarifying question when the axle configuration is ambiguous — that’s the load-bearing work. It’s document extraction plus a natural-language front door in Portuguese, and it’s what makes the WhatsApp channel viable at all.

2. Reading the regulation as it changes. ANTT publishes resolutions and portarias that shift coefficients, categories and procedural rules — 6.077/2026, 6.078/2026, 6.084/2026, Portaria SUROC 6/2026, and MP 1.343/2026 all landed within months. Parsing each publication into “which coefficient changed, for which cargo class and axle count, effective when” and pushing that diff into every customer’s saved lanes is ongoing AI-assisted work that a static calculator never does.

The AI is not the product’s headline. The gate is the headline. But without the extraction layer the product degrades into another form to fill out, and the whole wedge is that the clerk doesn’t have to fill out a form while a truck idles.

7. Localization angle

This is a Brazil-only product by construction, which is the point.

• The regulation is the product. ANTT floor tables, CIOT, MDF-e, CT-e, RNTRC and the PNPM-TRC framework exist nowhere else. There is no global version to be out-competed by.
• Language: Portuguese-only. Every user-facing string, every extracted document, every regulatory diff.
• WhatsApp is the interface. Brazilian SMB operations run on WhatsApp; a dock-side check has to happen there or it doesn’t happen.
• Payment rails: Pix and boleto for subscriptions. Monthly billing, no annual contracts — this buyer will not sign a year up front for a compliance tool they met last week.
• Pricing in reais at local norms. Frete.center’s Embarcador tier at R$ 197/mês is the visible anchor for “freight software for shippers.” I’m positioned above it on value (the gate + the defense file) and can justify R$ 400–900 because the comparison is a R$ 10,500 fine, not a competitor’s feature list.

The flip side: this is unexportable. Mexico’s Carta Porte, Argentina’s regime and the EU’s rules share nothing with it. That caps the ceiling — appropriately, since I’m hunting R$ 5–25M ARR, not a global platform.

8. Business model — path to $1M–$5M ARR

• Pricing: Three tiers by monthly trip volume.
  • Base — R$ 397/mo, up to 50 checked trips/month, WhatsApp + web, defense file export.
  • Pro — R$ 897/mo, up to 250 trips, lane memory, resolution watch, payment clock, multi-user.
  • Grupo — R$ 1,900/mo, multi-CNPJ (co-ops and groups with several plants), consolidated exposure reporting.
• ACV: Blended ~R$ 700/mo = R$ 8,400/year (~US$ 1,550 at ~R$ 5.4/USD).
• Rough math to R$ 5M ARR (~US$ 925K): 595 customers × R$ 700/mo × 12. Out of an 8,000–15,000 company target pool, that’s 4–7% penetration. Reachable by a two-person team over 24 months with the channel plan in section 9.
• Rough math to R$ 27M ARR (~US$ 5M): ~3,200 customers, or roughly a quarter of the target pool — which I do not consider realistic on this product alone. The honest R$ 27M path runs through adjacency: adding CIOT issuance itself (via partnership with a licensed issuing institution, taking a per-CIOT fee on top of subscription), then the trucker side (helping TACs verify they were paid at or above floor and pursue the 2× indemnity). I’d rather state that plainly than pretend the core SKU scales to $5M by itself.
• Expansion path: Trip-volume tiers create natural expansion as customers grow. Multi-CNPJ upsell for co-ops. Per-CIOT transaction fees once an issuing partnership exists. A per-autuação “defense pack” as a paid add-on when a citation actually lands — the moment of maximum willingness to pay.
• Margin note: Costs are document extraction and routed distance lookups per trip — cents per check at Base-tier volumes. Gross margin comfortably above 85%. The real operating cost is regulatory monitoring, which is fixed, not per-customer, and improves with scale.

9. Go-to-market wedge — first 100 customers

• Ride the August law. Lei 15.485/2026 was sanctioned nineteen days ago and the sector press, SETCESP, SETCERGS, SETCOM-MG, FETRANSUL and Sindicamp are all publishing explainers right now. Publish a free, genuinely good floor calculator with lane memory in Portuguese, pitch it into those association newsletters and the logistics trade sites (MundoLogística, Blog do Trecho, Roda Viva) as a tool their readers can use today. The free calculator is the top of funnel; the paid product is the record-keeping and the gate.
• Target the sindicatos and co-ops, not the truckers. Brazilian agricultural co-ops and industrial associations aggregate exactly the profile I want — dozens of member companies, each shipping 20–200 loads, each newly liable, none with a TMS. One workshop for a co-op’s member companies (“what the 5 August law changed for whoever signs your freight contracts”) puts the product in front of 30–60 qualified buyers at once. Run these in the ag belt: Mato Grosso, Paraná, Goiás, Rio Grande do Sul.
• Scrape the autuação trail. ANTT administrative proceedings are public. Companies that have already been cited for minimum-floor violations are a named, addressable list of buyers with proven exposure and an active defense need. Cold outreach to that list with a specific message — “here is the record you’ll need for the process you’re already in” — should convert far above cold-market baseline. This is the highest-intent list available and it grows every month the agency keeps fining.
• Partner with contadores and despachantes serving industrial clients. They’re the ones getting the panicked call when a CIOT blocks. Revenue share or referral fee; they keep the relationship, I take the subscription. Brazil’s accounting-firm channel is well-trodden for SMB compliance software and these firms already carry 30–100 industrial clients each.
• WhatsApp-native trial. The free calculator lives as a WhatsApp number. No signup to get the first answer — send a route, get a floor. Conversion prompt appears once someone checks their fifth trip, at which point the tool is already in their daily workflow. Removes the “install software” objection entirely.

Realistic math on channel three: if ANTT is issuing minimum-floor citations at a rate that produced R$ 932M in six months, the cited-company list is large. Even 2,000 reachable cited contratantes at a 5% conversion is 100 customers from that channel alone.

10. Build complexity — justification

Low. The floor formula is published and simple. The coefficient tables are public data that need to be ingested and versioned. Routed road distance comes from an off-the-shelf mapping API. Document extraction and the Portuguese WhatsApp front door are standard model API work. Storage is a trip record with an audit trail — no exotic infrastructure.

The two things that need real care are not technical: getting the cargo-classification logic right (the CC coefficient differs materially by class, and a wrong class produces a confidently wrong answer, which is worse than no answer), and keeping current with ANTT publications. A solo builder with a Portuguese-speaking domain advisor ships a credible v1 in 6–8 weeks. Adding actual CIOT issuance later is a different animal — it requires partnering with a licensed institution — which is exactly why v1 stops at “get the number right and prove you got it right” and leaves issuance to the platforms that are already authorized.

11. Gating checklist

Gate	Pass?	Note
Legal in target market	✅	Helping companies comply with ANTT rules. No licence needed to calculate a published formula or store records. Issuing CIOT would need a licensed partner — deliberately out of v1 scope.
Ethical — no harm / dark patterns	✅	The product pushes shippers toward paying truckers the legal floor. The policy exists to protect autonomous drivers’ income; this makes compliance easier, not avoidable.
Market exists (evidence above)	✅	R$ 932.4M in fines in six months, CIOT blocking live since 24 May, new law 5 Aug, existing paid tools at R$ 197/mo for an adjacent buyer.
1–5 person team can build this	✅	Solo builder + domain advisor, 6–8 weeks to v1.
Launchable with <$50K / ₹40L	✅	Well under. Main costs are the advisor and travel to co-op workshops.

12. Feasibility score

Axis	Weight	Score	Notes
Problem intensity	20	17/20	A blocked CIOT stops a loaded truck from legally departing — felt immediately, at the dock, with a driver waiting. Add R$ 10,500 cumulative per-failure fines, a R$ 1M reincidence ceiling, RNTRC suspension, and a 2× floor indemnity owed to the trucker. Not 19–20 only because the highest-volume shippers already have a TMS handling it, so the acute pain concentrates in the mid-band I’m targeting.
Demand evidence	15	12/15	Strong regulatory and enforcement evidence (R$ 932.4M in fines; ANTT’s own blocking announcement; a law sanctioned 19 days ago) plus a priced adjacent competitor at R$ 197/mo. Held below 13 because I have trade-press description of the pain rather than verbatim buyer complaints — no forum thread of a specific shipper describing their blocked CIOT. That’s the gap the validation sprint closes.
Build feasibility	15	13/15	Public formula, public tables, off-the-shelf routing and extraction. 6–8 weeks solo. Docked for cargo-classification correctness risk and the ongoing regulatory-ingestion burden.
Distribution clarity	15	11/15	The public autuação list is a genuinely named, high-intent channel and the co-op/sindicato route is concrete. Docked because I haven’t verified how easily the citation data can be pulled at volume, and workshop-led sales is slower per-unit than pure inbound.
Revenue mechanics	15	11/15	Pricing anchored against a visible R$ 197/mo competitor and a R$ 10,500 fine. R$ 5M ARR (BRL) math is credible at 4–7% penetration. Docked because the honest path to US$5M needs the CIOT-issuance adjacency, which depends on a partnership I don’t control.
Time to first revenue	10	8/10	The law is 19 days old and the blocking is already live — urgency is maximal right now. WhatsApp trial with no signup shortens the funnel. First paying customer plausible 4–8 weeks post-launch. Not 9–10 because the co-op channel runs on workshop scheduling, which has its own calendar.
Defensibility	10	4/10	This is the weak axis and I won’t dress it up. The formula is public and a competitor can ship a calculator in a fortnight. What accumulates is lane memory, the per-trip defense archive (which is switching-cost — you don’t leave the system holding your evidence), and the association relationships. That’s a 6–12 month head start, not a moat. An incumbent TMS deciding to serve down-market would be a real threat.
Total	100	76/100

13. Qualitative modifiers

Founder-fit tags

technical-heavy · domain-expertise-required

Portuguese fluency is non-negotiable — for the product, the sales motion, and reading ANTT publications. A Brazilian co-founder or a deeply embedded advisor in the logistics/fiscal space is required, not optional. The build is light; the domain is not.

Key assumptions to validate (3–5)

1. Assumption: Mid-sized non-transport shippers are actually experiencing blocked CIOTs and trucks held at the dock — not just reading about the risk in trade press. How to test: 20 structured interviews with faturamento leads at industrial and ag companies in MT/PR/SC. Ask directly: “since 24 May, how many times has a CIOT failed to generate on the first attempt?” If the median answer is zero, the acute pain isn’t where I think it is and this becomes a slower compliance-hygiene sale.
2. Assumption: They’ll pay R$ 400–900/mo when ANTT’s own calculator is free. How to test: Price-test at the workshops. The pitch is not “we calculate” — it’s “we keep the record that wins your defense and we stop the truck from waiting.” If they anchor hard on the free calculator and won’t move, reprice at R$ 197–297 and re-run the ARR math.
3. Assumption: The ANTT autuação record is scrapeable at useful volume with company identifiers. How to test: One week attempting to pull the administrative-proceeding data. This channel carries a large share of the distribution score — if it’s inaccessible, distribution drops to ~8 and the total to ~73.
4. Assumption: Cargo classification can be inferred accurately enough from a nota fiscal and a free-text description. How to test: Collect 100 real freight descriptions, classify them, and have the domain advisor grade the output. Below ~95% accuracy the product needs a mandatory human confirmation step, which slows the dock-side flow that is the entire value proposition.
5. Assumption: Co-ops and sindicatos will host member workshops for an unknown vendor. How to test: Approach five in the ag belt within the first fortnight. The August law is the door-opener; if none bite, the channel thesis needs rework.

Risk flags

1. Regulatory reversal: Brazil’s freight-floor policy has been litigated and politically contested since 2018. The ADIs against the original tabelamento, and continuing pressure from shipper lobbies against the floor, mean the rules could soften. Per this repo’s own lobbying-as-scope-signal heuristic, the shipper associations pushing back is confirmation the segment is in scope — but a materially weakened floor would gut the product’s urgency.
2. Incumbent moves down-market: nstech, Target Bank, Bsoft and the TMS vendors already have the domain knowledge and the customer relationships. Any of them can add a floor-gate module. The bet is that they won’t prioritise a segment that doesn’t look like their ICP — a bet with a 12-month clock on it.
3. Platform dependency on ANTT data: Coefficient tables and resolution publications are the product’s raw material. If ANTT changes publication format, or launches its own richer shipper-facing tool, the ingestion layer and part of the value both take damage. ANTT building a better free calculator is a live risk given they already run one.
4. Wrong answer liability: A confidently incorrect floor that leads a customer into a below-floor contract creates real exposure — both the fine and the 2× indemnity to the trucker. Terms of service, conservative rounding, and a visible confidence indicator on inferred classifications are mandatory from day one, not v2 polish.

14. Structured verdict

Score:                  76/100
Verdict:                GO
Confidence:             Medium
Best-fit builder:       Technical solo founder, Portuguese-fluent, with a
                        Brazilian logistics/fiscal domain advisor on equity
Time to revenue:        6–10 weeks (6–8 week build, overlapping pre-sales
                        into co-op workshops)
Capital to launch:      R$ 60–100K (~US$ 11–18K) — advisor equity plus cash,
                        API costs, travel to ag-belt workshops
Top 3 assumptions to validate first:
  1. Blocked CIOTs are actually happening at mid-sized non-transport shippers
     — 20 interviews with faturamento leads in MT/PR/SC, asking for incident
     counts since 24 May 2026, not opinions
  2. R$ 400–900/mo clears against a free official calculator — price-test live
     at two co-op workshops before writing the billing code
  3. ANTT autuação records are pullable at volume with usable company
     identifiers — one week of data-access work
Kill criteria:
  - Abandon if fewer than 6 of 20 interviewed shippers report a CIOT that
    failed to generate on first attempt since 24 May 2026
  - Abandon if the ANTT floor regime is materially weakened or suspended by
    court or legislative action before v1 ships
  - Abandon if an established TMS vendor launches a shipper-facing floor-gate
    with a defense archive before month 6
  - Abandon if fewer than 15 paying customers by month 6 post-launch

15. Next step — 1-week validation sprint

• Day 1–2: Build the list. Pull 60 mid-sized non-transport shippers in Mato Grosso, Paraná and Santa Catarina that hire TACs on the spot market — via co-op member directories, industrial association rosters and RNTRC-adjacent public data. In parallel, spend half a day attempting to extract ANTT autuação records to settle assumption 3 early, because it moves the score.
• Day 3–4: Twenty interviews with faturamento or supply leads, structured around one counting question: “Since 24 May, how many times did a CIOT fail to generate on the first attempt, and what did that cost you in waiting time?” Then, and only then, show a clickable mock of the WhatsApp floor check plus the trip defense file, and ask the price question directly at R$ 397 and R$ 897.
• Day 5: Decide. Go requires: ≥6 of 20 report at least one first-attempt CIOT failure since 24 May, and ≥5 of 20 say yes to R$ 397/mo with a specific start date attached, and at least one co-op or sindicato agreeing to host a member workshop. Anything less than all three and this drops to VALIDATE and waits for the enforcement data to mature through Q4 2026.

The falsifiable core is the incident count. If mid-sized shippers aren’t getting CIOTs blocked, then the acute dock-side pain I’ve built the whole wedge on doesn’t exist yet, and what remains is a slower, less urgent compliance-records sale — a different, worse business that I would not fund at this price.