🇧🇷 Registry1 Jan 2026
Brazil requires companies to re-file beneficial owners on a new annual form
Brazil's Normative Instruction RFB no. 2,290/2025, in force from 1 January 2026, replaces the old process for reporting ultimate beneficial owners with an electronic form (e-BEF). Companies and other entities with a CNPJ must re-file their beneficial owners, generally by the end of 2026, then file every year even without changes and within 30 days of any change. Failure can lead to suspension of the CNPJ.
Brazil's Federal Revenue Service (Receita Federal) collects beneficial ownership information through the national company register (CNPJ). Normative Instruction RFB no. 2,290/2025 overhauls the process from 1 January 2026.
What changed
- Beneficial owners are reported on a new electronic form, the e-BEF.
- Who files: Brazilian companies, associations, cooperatives, foundations and investment funds that need a CNPJ, and foreign entities and trusts that hold assets or act in Brazil.
- Beneficial owner: a person who holds more than 25% of capital or votes, directly or indirectly, or otherwise controls the entity.
- Re-filing: every entity in scope must file again, even if it reported before. The deadline is generally the end of 2026, and the end of 2027 or 2028 for some smaller companies.
- Ongoing: an annual filing even without changes, and a new e-BEF within 30 days of CNPJ registration, any change in beneficial owners, or the end of an exemption.
- Exemptions include listed companies, sole traders and small companies below BRL 4.8 million revenue with no corporate shareholders.
- Penalties include suspension of the CNPJ, which blocks banking.
What to do
Map each Brazilian entity's ownership chain to its individuals and diarise the re-filing deadline.