e-BEF: deadline for reporting ultimate beneficial owners is December 31

DPC recommends early submission to avoid issues at year-end

The e-BEF (Digital Final Beneficiary Form) is an ancillary obligation established by Regulatory Instruction No. 2,290/2025 and required by the Federal Revenue Service to identify individuals who own, control, or exercise significant influence, directly or indirectly, over a company or Entity.

Its annual deadline for submitting information is December 31. Since this period coincides with the year-end holidays, we recommend completing the submission by November 30 to avoid setbacks, including potential instability on the Brazilian Federal Revenue Service’s website.

Who must submit the e-BEF in 2026?

As of January 1, 2026, this obligation applies to obligated entities that are not included in the phased implementation provided for in the legislation.

These include:

• civil and commercial companies, associations, cooperatives, and foundations headquartered in Brazil that carry out activities or perform legal acts or transactions in the country and are required to register with the CNPJ (National Register of Corporate Taxpayers);
• legal entities or arrangements (trusts) domiciled abroad that hold rights, carry out activities, or perform legal acts or transactions in Brazil and require CNPJ registration.

It is important to note that other categories will become subject to this obligation in the coming years:

• As of January 1, 2027: simple partnerships or limited liability companies with revenue exceeding BRL 78 million in the year prior to the submission, certain entities domiciled abroad, and non-profit entities receiving public funds, subject to the exceptions provided for in the legislation.
• As of January 1, 2028: simple partnerships or limited liability companies with revenue exceeding BRL 4.8 million in the year prior to the submission, as well as certain pension and insurance entities and funds.

The legislation also provides for exemption cases. Therefore, it is important to verify whether the entity is subject to this obligation.

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

In what other cases is the e-BEF required?

In addition to the annual requirement, the parent company must submit the information within 30 days of certain events:

• registration with the CNPJ;
• a change in the ultimate beneficiaries; or
• the company becoming subject to the requirement to provide this information.

Even if none of these events occur, the requirement must be met annually, by the last day of December.

What are the consequences of a late filing?

Failure to file the e-BEF may result in fines and suspension of the company’s CNPJ registration, with potential impacts on its operations, such as the issuance of invoices and financial transactions.

Support in complying with ancillary obligations

If you would like assistance with filing this return, our paralegal team is available to assist you with this process via email at: paralegal@dpc.com.br.