Najila Trindade filed a rape complaint with Sao Paulo police upon her return from a trip to Paris in May in which she said she was assaulted by Neymar following a pre-arranged meeting.
A judge dismissed the case in August, citing insufficient evidence.
Instead, Sao Paulo prosecutors said in a statement that investigators had found "indications of slanderous denunciation and extortion" in the woman's accusation.
A final decision on whether to prosecute Trindade will be left to a judge.
Neymar, the world's most expensive footballer, has always protested his innocence, saying their relations were consensual.
The case complicated an already tumultuous year for the 27-year-old Brazil star, who has yet to play for his club Paris Saint-Germain this season following injury and reports of an aborted return to previous club Barcelona.
On Friday, Neymar played his first game since suffering an ankle injury in June, grabbing a second-half equalizer for Brazil in a 2-2 friendly draw with Colombia.