What is e-BEF?
The e-BEF (Formulário Digital de Beneficiários Finais, or Digital Beneficial Ownership Form) is a filing with Brazil’s Federal Revenue Service (Receita Federal). It identifies the individuals who ultimately own, control or exercise significant influence over an entity, or on whose behalf a transaction is conducted. Introduced by IN RFB No. 2,290/2025, it has been completed online through the Receita Federal service portal since 1 January 2026.
Significant influence includes holding more than 25% of the capital or voting rights, directly or indirectly. It also covers individuals who, alone or jointly, have a predominant role in corporate decisions and the power to appoint a majority of the directors or managers, even without formal control. All individuals who meet the criteria must be identified. Management is reported only if no individual qualifies; missing documents do not justify substituting management for the beneficial owners.
A shareholder and a beneficial owner are not necessarily the same person. Where the shareholder is another company, the ownership chain must be traced to the individuals. If a Brazilian limitada is wholly owned by an Italian S.r.l. whose shareholders hold 60%, 30% and 10%, the first two meet the ownership threshold. The third may qualify through other rights conferring influence, which must also be examined.
Who needs to file?
The requirements depend on the entity’s legal form, ownership structure, exemptions and applicable timetable. Brazilian limited liability companies (sociedades limitadas) with at least one legal entity in their shareholder and management register (QSA), whether Brazilian or foreign, fall outside the phased start based on turnover. Unless an exemption applies, they must report from 2026 regardless of revenue. The annual deadline of 31 December does not override the 30-day deadlines.
For sociedades simples and sociedades limitadas covered by the phased timetable, reporting starts in 2027 where gross revenue in the previous year exceeds BRL 78 million; the 2028 phase covers revenue exceeding BRL 4.8 million. The exemption for revenue of up to BRL 4.8 million requires, among other conditions, that no legal entity appears in the QSA.
Exemptions also include, among others, individual microentrepreneurs (MEI), sole traders, single-member limited liability companies and single-lawyer legal practices under Brazilian law. Having a corporate shareholder does not, by itself, remove every exemption. Other entities and special regimes require separate assessment.
Companies with a foreign corporate shareholder
The Brazilian company’s obligation and that of its foreign corporate shareholder must be assessed separately. A foreign entity holding rights or carrying out transactions in Brazil that require CNPJ registration may have its own reporting obligation, subject to the exceptions in Article 55. CNPJ registration alone does not mean that immediate filing is mandatory in every case.
A Brazilian single-member limited liability company is among the exempt entities. Its exemption does not automatically extend to the foreign shareholder, nor does it establish that the shareholder must file without checking its own circumstances. Certain financial and capital market investors are subject to specific exemptions, reporting on request or phased implementation.
Signatures and documents
Article 55-A(3) requires a digital signature from the entity and its beneficial owners registered in the CPF, Brazil’s individual taxpayer register. However, page 38 of the e-BEF Manual, version 2.0, states that, at this stage of the system, foreign nationals do not need to digitally sign to confirm their designation, even if they have a CPF. The legal rule should be distinguished from this operational guidance, and the procedure in force should be checked when filing.
Foreign nationals without a CPF must provide the personal and contact details specified in the regulation, including an identity document or passport, issuing country, country of tax residence and tax identification number (NIF), together with the documents required by the system. The representative or attorney-in-fact must have the necessary authority and access. A legal entity’s filing is centralised through its head office.
Annual and 30-day deadlines
The filing must be submitted within 30 days of CNPJ registration for the initial information; of a change in beneficial owners; or of an exempt entity becoming subject to reporting.
If none of these events occurs, filing is annual and due by the last day of the calendar year. For existing entities subject to reporting in 2026, the annual deadline is 31 December 2026. This date does not allow an event subject to a 30-day deadline to be deferred.
Consequences of non-compliance
Late filing is subject to the penalties in Article 57(I) of Provisional Measure No. 2,158-35/2001, as referenced in Article 56(4) of IN RFB No. 2,119/2022. The amount and conditions depend on the reporting entity’s classification.
Failure to file, or a filing containing omissions or inaccuracies, may lead to suspension of the CNPJ registration and the banking restrictions set out in the regulation. Suspension is preceded by a notice allowing 30 days to remedy the issue or prove an exemption. Statutory exceptions to the banking restrictions include transactions needed to repatriate an investment and to fulfil obligations assumed before suspension. False information may also have criminal consequences.
What to do now
Start the assessment early: check each group entity’s reporting obligation, review the ownership chain and rights conferring influence, collect documents, and confirm powers of attorney, access and signature procedures. Documents held abroad may require additional coordination.
Buccioli & Partners’ corporate team can advise on the applicable requirements, beneficial ownership identification and filing procedures. Contact: societario@bcbo.com.br.