In connection with Normative Instruction RFB No. 2,290/2025, which updated the rules for the identification and disclosure of ultimate beneficial owners (UBOs) in Brazil, effective generally as of January 1, 2026, the Brazilian Federal Revenue Service (Receita Federal) has adopted a more proactive approach to monitoring compliance with this obligation.
Among the key changes introduced by the new regulation is the creation of the Digital Ultimate Beneficial Owner Form (e-BEF), which has centralized the submission of UBO information through an electronic platform.
Recently, companies have begun receiving informational notices from the Brazilian Federal Revenue Service through the e-CAC electronic mailbox, providing specific guidance on completing the e-BEF. These notices emphasize that, following the submission of the e-BEF, obligated entities must have at least one active ultimate beneficial owner reported in the system. The consequences of non-compliance are significant: failure to report UBO information may result in the suspension of the entity’s registration with the CNPJ (National Registry of Legal Entities), preventing the entity from conducting banking transactions — including current account operations, financial investments, and obtaining loans — in addition to the imposition of fines for each month or fraction of a month of delay.
As the e-CAC centralizes messages, communications, and electronic notifications from the Brazilian Federal Revenue Service, heightened attention to the monitoring of these notices and the verification of each obligated entity’s registration status is strongly recommended.
In light of this regulatory landscape, it is important for companies to review their corporate structures and UBO data in advance, in order to assess any need to submit, update, or regularize information with the Brazilian Federal Revenue Service, particularly in view of the deadlines and penalties set forth in the regulation.