Foreign investors operating in Brazil should take note: Normative Instruction No. 2,290/2025, effective January 2026, significantly overhauls the country’s beneficial owner identification and reporting framework. The new regulation introduces the Digital Beneficial Owners Form (e-BEF), revises ultimate beneficial owner (“UBO”) criteria, sets new filing deadlines and triggers, and adopts a phased implementation model based on revenue thresholds. Non-compliance carries severe consequences, including Corporate Taxpayer Registration Number (“CNPJ”) suspension of the foreign entities operating in Brazil and Brazilian subsidiaries and the inability to transact with financial institutions, potentially disrupting business operations in Brazil.
Authors:
João Carlos Anderson Corrêa de Mendonça – Partner of Corporate and M&A
Cindy Massesine Pimentel Canova – Attorney
Pedro Henrique Santi – Intern