The publication of Normative Instruction No. 2,290 of 2025 introduces important changes to the identification of ultimate beneficial owners (UBO) in Brazil, effective in 2026. These measures aim to enhance transparency and strengthen anti-money laundering efforts.
The e-BEF and Mandatory Identification The standout update is the e-BEF, a standardized digital form integrated directly into the CNPJ system. Crucially, entities are no longer allowed to declare the absence of an ultimate beneficial owner. Identifying the individuals who ultimately control or exercise significant influence over the entity is now mandatory.
Who is Impacted? The scope includes civil and commercial companies, associations, and foundations domiciled in Brazil. Notably, the rules now extend to investment funds, including multi-layered complex structures. Foreign funds generally remain subject to these obligations, with few exceptions for highly transparent structures.
Deadlines and Compliance Risks Starting in 2026, identification must be completed within 30 days and will become an annual requirement per the Brazilian Federal Revenue Service schedule. Failure to comply may lead to:
- CNPJ suspension.
- Operational restrictions.
- Legal penalties.
ORGATEC specializes in accounting for foreign companies. Contact us to review your information and ensure your business stays ahead of the new regulations.