This article examines the governance of social assistance in the City of São Paulo by considering the interplay between the federal normative acts that conform to the Unified System of Social Assistance (SUAS) and the decisions taken at the municipal level, in order to better understand multi-level governance in federal contexts. We demonstrate that federal-set policy parameters matter but they are not sufficient to understand how policies are implemented at the local level. Hence, the article revises some established assumptions about the local implementation of social policies in federal contexts. We argue that the governance of social assistance at the municipal level can be understood by the combination of the following aspects: 01. the power resources, capacities and constraints available for state and civil society actors; 02. the interactions and disputes between these actors in formal and informal arenas; 03. the main ideas supported by relevant actors and the instruments they use to transform ideas into policy actions. Our results show that agency at the local level matters even for nationally regulated policies. Moreover, the historical process of capacity building matters not only to state actors, but also to civil society organizations.