e-BEF: companies must report ultimate beneficial owners to the Federal Revenue Service

This new ancillary obligation is already mandatory for some companies in 2026, while others are subject to a phased implementation

The e-BEF (Digital Final Beneficiary Form) is a acillary obligation required by the Federal Revenue Service, the purpose of which is to identify the individuals who, directly or indirectly, own, control, or exercise significant influence over a company or entity.

In practice, this means disclosing who is behind the corporate structure, even if that ownership is not immediately apparent.

The requirement took effect on January 1, 2026, pursuant to Federal Revenue Service Regulatory Instruction No. 2,290/2025. Given that this is a recent change, it is recommended that you pay close attention to the need to comply with this procedure.

The Revenue Service has been sending messages to the email inboxes of taxpayers subject to this obligation.

Who is required to file the e-BEF?

This requirement applies to civil and commercial partnerships, associations, cooperatives, and foundations headquartered in Brazil that conduct business or engage in legal acts or transactions in the country and are required to have a CNPJ (National Register of Corporate Taxpayers).

This also includes foreign entities, such as trusts, that conduct business or engage in legal acts or transactions in Brazil and are also required to register for a CNPJ.

However, the law also provides for exceptions to the requirement to report to e-BEF. See below for the cases where reporting is waived:

Deadlines and submission method

The information must always be submitted by the parent company within 30 days of specific events, such as registration with the CNPJ, changes in the final beneficiaries, or when the company becomes required to provide this information.

If none of these situations occur, the obligation remains and must be fulfilled annually, by the last day of the calendar year, i.e., December 31, 2026. However, as this is the holiday season, we recommend that those required to file the statement submit it by December 18, 2026, at the latest.

The legislation that introduced e-BEF establishes several phases of mandatory implementation:

Phase 1: as of January 1, 2027

• simple partnerships or limited liability companies with revenue exceeding BRL 78 million in the year prior to the filing of the form;
• entities headquartered abroad whose purpose is the investment of funds in the financial and capital markets; and
• non-profit entities receiving public funds, except for entities of the Autonomous Social Service (SSA).

2nd phase: as from January 1, 2028

• simple partnerships or limited liability companies with revenue exceeding BRL 4.8 million in the year prior to the filing of the form;
• investment funds established and intended to receive funds from supplementary pension benefit plans or personal insurance plans domiciled abroad; and
• pension entities, pension funds, and similar institutions headquartered in Brazil or abroad.

Important: Limited liability companies with a legal entity partner in their QSA and other obligated entities not included in the phased implementation schedule will be required to submit information starting in 2026, regardless of revenue.

What happens if the company fails to submit the e-BEF?

Failure to submit the e-BEF can result in consequences such as suspension of the CNPJ, as well as late filing penalties. This situation directly impacts business operations, hindering essential activities such as issuing invoices and conducting financial transactions.

Read more: Federal Revenue Service changes rules and establishes a new requirement for identifying ultimate beneficial owners

Compliance with ancillary obligations

Domingues e Pinho Contadores offers comprehensive solutions, from the preparation to the filing of ancillary obligations, including data corrections when necessary. For assistance, please contact us by email at: paralegal@dpc.com.br.