International interest in Brazilian football has grown exponentially, and much of this capital flows into the country through Brazilian Football Corporation [Sociedades Anônimas do Futebol – SAFs]. According to the survey prepared by Rodrigo Monteiro de Castro, lawyer, professor of Commercial Law at IBMEC-SP, and co-author of the SAF Law, in 2025, 117 Brazilian clubs already operated under this model. Now, with more foreign investors assuming management positions, the cases of non-resident administrators in charge of these corporations are also growing.

In June 2026, Law No. 15.427/2026 was enacted, amending the SAFs Law; among several provisions, it included a specific statute of limitations on administrators domiciled abroad. For foreign investors who see Brazilian football as a business opportunity, understanding this requirement is no longer a technical detail but a prerequisite for taking office.

What has changed in the SAF law?

Before the enactment of the new rule, SAFs were guided, in this matter, by the Corporations Law (Law No. 6.404/1976), applied in a subsidiary manner. The general rule, established by Law No. 14.195/2021 when it amended article 146 of the Corporations Law, already allowed non-residents to occupy management positions. To do so, it was enough to appoint a representative in Brazil with powers valid for at least three years after the end of the term of office.

Law 15.427/2026 inserted a specific provision in the SAFs Law, dealing exclusively with non-resident administrators of this corporate type. The rule gains its own weight, separate from the general regulation governing corporations. This confirms the legislator’s intention to treat the governance of SAFs in a specific way, in line with the volume of foreign capital that this business model attracts.

Do you need a legal representative for the non-resident administrator of SAF’s?

The new wording determines that the administrator resident or domiciled abroad must, before assuming the position, appoint a representative resident in Brazil. Such representative must be empowered to receive service of process, subpoenas or summons relating to actions, administrative proceedings or arbitration and judicial proceedings brought against the administrator.

This is not a one-time formality. The requirement applies throughout the entire term of office and extends for 6 years after its end. Therefore, the choice of the representative requires planning and cannot be treated as a last-minute detail.

Why is the term six years for SAFs?

This is the point that most differentiates the new rule from the general regulation governing corporations. While the Brazilian Corporations Law requires representation for at least three years after the end of the term of office, the new SAFs Law establishes a period of six years.

In practice, the foreign administrator who leaves office remains exposed, for six years, to lawsuits, administrative proceedings and arbitration proceedings related to his/her management. Throughout this period, the administrator must keep someone qualified to receive these communications on his behalf in Brazil. It is not enough to appoint a representative at the taking of office; it is necessary to ensure the continuity of representation long after the administrator leaves office and possibly the country.

What does the representative guarantee in practice?

The representative does not manage the SAF or participate in corporate decisions. Its function is strictly procedural, but that doesn’t make it any less sensitive. A single oversight could mean that the non-resident administrator simply cannot be located when he or she needs to be held accountable for actions taken during his or her tenure. The absence of a representative authorized to receive communications can lead to significant procedural problems for the administrator and expose SAF to governance-related questions.

The appointment of a duly qualified trust representative assures the non-resident administrator the tranquility necessary for the conduct of corporate decisions, ensuring their adequate representation before the competent authorities and bodies in Brazil.

A service that requires trust and continuity

The six-year term of post-mandate representation shows that this is not a simple service. It is necessary to have a reliable partner who is professionally qualified and has a robust corporate structure that ensures the validity of the representation throughout the period, even after the administrator has terminated direct contact with the operation in Brazil.