Brazil’s Federal Revenue Service (Receita Federal) established the Digital Ultimate Beneficial Owner Form \u2014 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.<\/p>\n\n
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.<\/p>\n\n
Who must be reported as an ultimate beneficial owner?<\/p>\n\n
As a general rule, the individual who must be identified is the one who:<\/p>\n\n
![\"✅\"](\"https:\/\/s.w.org\/images\/core\/emoji\/17.0.2\/svg\/2705.svg\"\/)
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.<\/p>\n\n
If no individual meeting these criteria can be identified, the individuals who hold administrative authority over the entity must be reported.<\/p>\n\n
Filing Deadlines<\/p>\n\n
The e-BEF must be filed:<\/p>\n\n
![\"📌\"](\"https:\/\/s.w.org\/images\/core\/emoji\/17.0.2\/svg\/1f4cc.svg\"\/)
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.<\/p>\n\n
Phase-In of the Requirement<\/p>\n\n
The obligation will be phased in progressively, but some groups must already assess whether they are covered starting in 2026.<\/p>\n\n
Starting in 2026:
Starting in 2027:
Starting in 2028:
Documentation and Practical Precautions<\/p>\n\n
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.<\/p>\n\n
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.<\/p>\n\n
Penalties<\/p>\n\n
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.<\/p>\n\n
Given the new rules, companies are advised to review their corporate and documentary structure now to avoid registration inconsistencies and regulatory risks.<\/p>\n\n