e-BEF and Final Beneficiary: New Deadlines and Procedures at the RFB

The Brazilian Federal Revenue Service (RFB), through Normative Instruction (IN) 2.119/2022, established regulations governing the obligation of legal entities that conduct or carry out activities in Brazil to identify and report their respective ultimate beneficial owners.

The declaration aims to identify the ultimate beneficial owners of domestic or foreign legal entities registered with a CNPJ in Brazil—that is, the individuals who ultimately own, control, or exercise significant influence over a legal entity or benefit from it. The measure seeks to promote transparency in corporate structures and prevent their use for illicit activities, such as money laundering, corruption, and tax evasion.

This requirement is not new; it has been in place in Brazil since 2016, with the aim of bringing the country into line with international practices and the recommendations of the Organization for Economic Cooperation and Development (OECD).

The issue, however, gained prominence with the publication of IN 2.290/2025, which took effect in early 2026 and introduced significant changes to IN 2.119/2022, among which the following stand out:

• A change to the rule governing the completion of the declaration in the absence of a natural person who qualifies as a beneficial owner, in which case the individuals managing the reporting entity must be identified;
• The creation of the Digital Beneficial Owner Form (e-BEF), which becomes the official and exclusive channel for filing the declaration; and
• The requirement for annual reporting.

Under the current rule, “significant influence” is defined as holding more than 25% of the capital or voting rights, or having the power to prevail in corporate resolutions and to elect a majority of the directors.

As a general rule, in addition to domestic entities, the obligation to declare ultimate beneficiaries applies to entities and legal arrangements domiciled abroad that conduct business or engage in legal acts or transactions in Brazil subject to CNPJ registration.

However, for certain situations—such as publicly traded companies, limited partnerships, and trusts—there are specific rules that must be followed…

The declaration must be filed by completing and submitting the e-BEF form through a gov.br account by the individual authorized to represent the entity (as legal representative or attorney-in-fact).

Declarations must be submitted via e-BEF by the following deadlines:

• Within 30 days of the entity’s registration with the CNPJ;
  Within 30 days of any change in the respective ultimate beneficial owners, including changes in the percentage of ownership or voting rights; and
  Annually, by December 31, regardless of whether any changes have occurred with respect to the reporting entity.

IN 2.290/2025 also established specific deadlines for certain entities to comply with the new rule. Starting January 1, 2027, the following entities must submit a list of ultimate beneficiaries:

• General Partnerships or Limited Liability Companies with revenue exceeding R$ 78,000,000.00 in the year prior to the submission of the Form;
• entities domiciled abroad whose purpose is to invest funds in the financial and capital markets; and
• nonprofit entities that receive public funds, except for entities of the Autonomous Social Service (SSA).

In turn, the following entities must submit a list of ultimate beneficiaries as of January 1, 2028:

• Simple or limited liability companies with revenue exceeding R$ 4,800,000.00 in the year prior to the submission of the Form;
• investment funds established and designated to hold assets from supplemental pension plans or personal insurance plans domiciled abroad; and
• pension entities, pension funds, and similar institutions domiciled in Brazil or abroad.

For all other entities, the obligation to report ultimate beneficial owners through e-BEF is subject to the general rule and will therefore take effect in 2026.

Failure to file the report by the deadline, or filing it with omissions or errors, may result in the suspension of the legal entity’s CNPJ registration. A delay may also result in a fine of R$ 1,500.00 per month.

Therefore, it is recommended that the declaration be filed with appropriate legal counsel.

The KVTS team is available to assist you in analyzing and complying with obligations related to the declaration of ultimate beneficial owners.