Brazil’s Federal Revenue Service (Receita Federal) established the Digital Ultimate Beneficial Owner Form — e-BEF, a new ancillary obligation aimed at identifying the individuals who, directly or indirectly, own, control, or exercise significant influence over Brazilian or foreign entities registered with the CNPJ.
The obligation stems from Normative Instruction (IN RFB) No. 2,290/2025, which amended IN RFB No. 2,119/2022, and took effect as of January 1, 2026.
Who must be reported as an ultimate beneficial owner?
As a general rule, the individual who must be identified is the one who:
holds, directly or indirectly, more than 25% of the share capital or voting rights; or exercises, directly or indirectly, significant influence, including preponderance in corporate resolutions or the power to elect the majority of the administrators.
If no individual meeting these criteria can be identified, the individuals who hold administrative authority over the entity must be reported.
Filing Deadlines
The e-BEF must be filed:
within 30 days of CNPJ registration, for initial reporting; within 30 days of any change to the ultimate beneficial owners; within 30 days when an exempt entity becomes subject to the obligation; and annually, by the last day of the respective calendar year, if no prior event requiring an update has occurred.
Phase-In of the Requirement
The obligation will be phased in progressively, but some groups must already assess whether they are covered starting in 2026.
Starting in 2026:
Limited liability companies with at least one legal entity as a partner, and other entities subject to the requirement not covered by the phase-in, regardless of revenue.
Starting in 2027:
Simple or limited liability companies with revenue above R$78 million in the prior year; certain entities domiciled abroad with holdings in the financial and capital markets; and nonprofit entities receiving public funds, subject to legal exceptions.
Starting in 2028:
Simple or limited liability companies with revenue above R$4.8 million in the prior year, as well as certain pension entities, pension funds and similar structures.
Documentation and Practical Precautions
To comply with the requirement, companies must review their corporate structure, identify the chain of control down to the ultimate individuals, and validate percentages, voting rights, administrative powers and supporting documents.
The Federal Revenue Service may require the documentation underlying the filing or any exemption claimed, which must be kept available for the applicable minimum retention period.
Penalties
Failure to file the e-BEF, filing it with omissions or inaccuracies, or lacking supporting documentation when requested, can result in significant consequences, including suspension of the CNPJ, operational restrictions, fines and other applicable sanctions.
Given the new rules, companies are advised to review their corporate and documentary structure now to avoid registration inconsistencies and regulatory risks.
Our team is available to help assess whether the requirement applies, map the corporate chain, identify ultimate beneficial owners and prepare the information needed to file the e-BEF.
