Obligations to the Central Bank of Brazil: A practical guide to declarations, requirements and deadlines

Companies with operations involving foreign investment in Brazil and/or Brazilian capital abroad must manage a series of periodic obligations required by the Central Bank of Brazil (“BCB”). These filings are designed, among other objectives, to map the volume of investments into and out of Brazil. While each declaration has its own specific rules, the most common source of confusion is the logic of the regulatory calendar. In practice, it is common for teams to struggle with varying base dates, distinct periodicities, and different reporting systems—especially the alternation between annual, quarterly, and quinquennial (five-year) declarations. This article objectively outlines the primary declarations, submission deadlines, and how they should be organized throughout the year. A significant portion of notices and penalties related to BACEN obligations does not stem from technical errors, but rather from missing deadlines. This typically occurs when: • a empresa não observa que é obrigada a declarar; • confunde a periodicidade aplicável à sua data-base; ou • entende que uma obrigação substitui a outra, quando isso não ocorre. Ter uma visão consolidada ajuda a estruturar rotinas internas e a evitar retrabalho, sobretudo em períodos de transição de equipe ou de reorganização societária. The following is a summary of the most frequent types of declarations and censuses:   • Censo de Capitais Brasileiros no Exterior (CBE)   • O CBE reúne informações sobre ativos, direitos e valores mantidos fora do País por residentes no Brasil, com periodicidade aplicável dependendo do valor total dos ativos no exterior. A obrigação pode ser:   • Anual, com data-base em 31 de dezembro; ou   • Trimestral*, para datas-base intermediárias, quando atingido os critérios definidos pelo BACEN. Importante destacar que, não há declaração trimestral do CBE para a data-base de 31 de dezembro, pois essa data está vinculada à declaração anual. Focused on foreign investment within Brazil, this census takes two forms Annual: Applicable every fiscal year, except when the quinquennial census is required; and Quinquennial: Required every five (5) years, featuring a broader reporting scope. The DEF is part of the reporting system for foreign direct investment (SCE-IED–Foreign Capital Information Reporting System–Foreign Direct Investment). Its purpose is to update the economic and financial data of companies receiving foreign capital. Submissions are made periodically throughout the year, according to the base dates defined by the Central Bank The table below consolidates the declarations mentioned above and their respective filing windows:     Implementing best practices is essential to mitigating risks: 1. Map out, in advance, which declarations apply to the company and deadlines; 2. Link each obligation to its correct base date; 3. Maintain oversight of corporate changes, reorganizations, and/or foreign exchange and financial operations that may impact your filing status; and 4. Periodically review mandatory information registered within the Central Bank’s systems Beyond fulfilling formalities, BCB obligations require strict consistency between accounting, corporate, and financial data. An integrated view of the regulatory calendar allows a company not only to avoid penalties or inquiries from the Central Bank but also to gain predictability and regulatory security. PLBrasil Paralegal assists in monitoring these obligations, helping companies correctly identify their filing requirements, meet deadlines, and organize the information required by the Central Bank—always in alignment with the operational reality of each business. Leave the annual update and mapping of complex structures to those who understand it We transformed the bureaucracy of IN 2,290/2025 into corporate security for your business. Don’t miss the Central Bank filing deadlines Managing CBE, DEF, and CCEP requirements requires technical precision and strict adherence to the regulatory calendar. Leave your filing compliance to our experts. The PLBrasil Group’s Foreign Capital team is available to assist you with the registrations required by the Central Bank of Brazil through the channels below: +55 (11) 3292-5050 nn@plbrasil.com.br

2026 Ultimate Beneficial Owner: Mandatory annual update and new rules for Investment Funds

The Brazilian Federal Revenue Office (RFB) Normative Ruling (IN) No. 2,290/2025 represents a significant update to the identification regime of final beneficiary which was provided for in the RFB IN No. 2,119/2022. Published in October 2025, the new regulation expands the transparency and traceability requirements for business structures and investment funds, focusing on combating money laundering, tax evasion, and unlawful practices. This change occurs within a thematic context already covered in previous publications, such as: “Do not have your National Register of Legal Entities (CNPJ) suspended for failing to designate the ultimate beneficial owner”,and “Designation of ultimate beneficial owner with the Federal Revenue Office” However, it now introduces practical innovations that deserve the attention of companies and managers. RFB IN No. 2,290/2025 does not create a new concept of ultimate beneficial owner, but expands the universe of obligated entities, redefines reporting procedures and establishes new deadlines and penalties. Among the main advances is the creation of Digital Form for Beneficial Owners (e-BEF), an electronic tool that standardizes the provision of information about who, directly or indirectly, owns, controls, or benefits from a legal entity. The e-BEF allows the pre-filling with data already existing in the Federal Revenue Office’s registry, facilitating the cross-referencing of information, real-time monitoring, and data integration in the CNPJ. RFB IN No. 2,290/2025 brought about a significant change by ruling out the possibility of state the absence of the ultimate beneficial owner, previously allowed by the wording that amended article 55, in the IN of October 2025. Previously, taxpayers could disclose their ultimate beneficial owners, or their absence. The new rule now treats the provision of this information as a positive covenant, without exception. In effect the Brazilian Federal Revenue Office system no longer offers the option to “not designate” the ultimate beneficial owner, requiring the accurate completion of the data. Thus, the absence of identification ceases to be a valid statement and becomes a failure to comply with registration requirements, which is particularly relevant for entities domiciled abroad and complex corporate structures. One concrete change is the requirement to designate ultimate beneficial owners in investment funds, including in complex structures such as funds whose shareholders are other funds or similar arrangements, something that was previously handled primarily within the scope of the Brazilian Securities and Exchange Commission (CVM). The new normative ruling incorporates this obligation within the scope of the Federal Revenue Office, integrating the information into the tax registry. For foreign funds, the requirement has been maintained, with a specific transition phase. Some funds domiciled abroad are exempt from the requirement only if they meet transparency criteria in regulated markets and do not have significant influence over Brazilian entities, but the general rule requires that data on ultimate beneficial owners be provided based on the new digital form. The new deadlines generally apply from January 1, 2026, the date on which the rule comes into effect. To wit: The designation must be made within 30 days as from the enrollment with the CNPJ, the change of ultimate beneficial owners, or the date on which the entity becomes obligated to provide such information; and Updating the ultimate beneficial owners will now be done annually, its deadline being up to the last day of each calendar year, even if there have been no changes in the beneficial owners profile. The ruling also establishes a progressive transition phase of mandatory measures for specific groups, imposing different dates according to the size, nature, and revenue of the entities. The Sole Exhibit to the standard stipulates that some categories will only be fully achieved in later phases: From January 1, 2027, simple and limited liability companies with high annual revenue, foreign entities that invest in financial and capital markets, and entities that receive public funds will now have a formal obligation to designate the ultimate beneficial owner; and From January 1, 2028, other simple and limited liability companies with intermediate revenue, as well as pension and retirement funds, must also comply with the obligation. Meanwhile, smaller companies may be exempt from the requirement until subsequent phases come into effect, but it’s important to verify each case individually. Failure to comply with the obligations to identify and update the ultimate beneficial owner is not merely a formality. The rule provides for explicit penalties, including Suspension of CNPJ enrollment and operational restrictions, such as blocking bank transactions, and the application of fines for late payment or omission. Furthermore, the express provision for criminal liability for misrepresentation in intentionally incorrect or incomplete statements highlight the requirement of good faith in the provision of registration information. The expansion of ultimate beneficial ownership rules reinforces that this obligation is no longer an isolated act, bonded only to the enrollment with the CNPJ, but has become part of a continuous registration control. Corporate changes, shareholding reorganizations, the entry or exit of shareholders or partners, and structural changes must be promptly reflected in the information provided to the tax authorities, ensuring compliance and avoiding future risks. For already established companies, it is essential to review their registration status, identify any gaps in the ultimate beneficial owner information, and prepare internal processes for data collection and updating. For new companies, the designation at the time of the CNPJ enrollment must be made immediately, within the legal 30 days. PLBrasil Paralegal provides technical support for adapting ultimate beneficial owner information, integrating the new reality of RFB IN No. 2,290/2025 with governance, compliance, and corporate management practices. With preventative analysis, it’s possible to correctly structure the process of collecting, validating, and reporting ultimate beneficial owners, reducing the risk of inconsistencies that could affect the CPNJ enrollment or future operations. Leave the annual update and mapping of complex structures to those who understand it We transformed the bureaucracy of IN 2,290/2025 into corporate security for your business. Leave the annual update and mapping of complex structures to those who understand it We transformed the bureaucracy of IN 2,290/2025 into corporate security for your business.   The PLBrasil Group’s is available

Shelf company: Is it worth buying a company ready to operate in Brazil?

A shelf company is a company that has already been incorporated and is kept inactive until the moment it is sold to a new owner. In theory, the buyer acquires a company with an  active CNPJ without having to deal with the process related to a new registration. This option emerged in a context in which the process of setting up companies was slow and bureaucratic, and many businessmen were looking for ways to enter the market quickly. However, the streamlining of processes in recent years, as well as the risks involved, suggests caution when using this option. The advantages of the shelf company were mainly linked to agility and credibility. Speed of operation: When buying an existing company, the new owner could start activities immediately, without waiting for the incorporation and CNPJ issuance process. CNPJ with history: companies with longer lifespans were seen as more reliable, which facilitated access to bidding processes, bank credit, and corporate contracts. Time saving: During periods of high bureaucratic demand, the shelf company offered a way to reduce steps and start businesses faster. However, with the modernization of digital processes, these advantages have become increasingly less relevant. Today, the incorporation of companies in Brazil is much faster and simplified thanks to the National Network for Simplifying Registration and Business Legalization (REDESIM). The process is fully digital, with integration between Boards of Trade, the Federal Revenue Office, state bodies, and city halls. In many cases, the opening of an Ltda. [limited liability company] or an S.A. [corporation] . takes only a few days. In this scenario, shelf companies have lost relevance, since incorporating a new company has become faster than—or even more efficient than—transferring an existing company. When acquiring a shelf company, the new partner takes full liability for the legal, tax, and accounting history of the company. This includes potential tax, labor, and ancillary obligations not fulfilled, which become the responsibility of the buyer. Furthermore, it is necessary to consider that the operation involves an acquisition value, corresponding to the purchase of quotas or shares of the company, which represents a significant initial cost. To this amount are added the expenses for contractual amendments, certificates, and registrations, resulting in an investment superior to the incorporation of a new company and with greater exposure to past risks. Today, it is possible to open a digital company with safety and technical support from start to finish. Integrated systems guarantee traceability, transparency, and compliance with the advantages of shelf companies being—such as speed and simplicity—achieved through more modern, economic and legally secure means, without the risk of inheriting liabilities from third parties. The decision between acquiring a shelf company or incorporating a new company should consider the business profile and the risks involved. In an increasingly digital and regulated environment, document security and legal compliance are determining factors. PLBrasil Paralegal supports companies and investors in the incorporation and regularization of companies, ensuring fast, transparent processes that are fully compliant with current legislation. Open your business safely and quickly! Request a proposal for the registration of a new CNPJ. Open your business safely and quickly! Request a proposal for the registration of a new CNPJ. The PLBrasil Group’s Foreign Capital team is available to assist you with the registrations required by the Central Bank of Brazil in the channels below: +55 (11) 3292-5050 nn@plbrasil.com.br

Liquidator of foreign companies: representation after dissolution of the company

Dissolving a company in Brazil involves more than just registering the termination agreement or requesting the cancellation of the CNPJ. The process of dissolution, liquidation, and extinction is formal, and even after it is completed, the company may remain subject to pending obligations. Tax notices, requests for documents, retroactive audits, and even outstanding credits may arise after the business is dissolved. Therefore, the law stipulates the need for a liquidator, responsible for representing the legal entity during this period. This precaution is especially relevant for foreign companies or entities whose members leave the country, a situation in which there are no resident administrators to legally answer for the dissolved company. The liquidator is the legal representative of the company during the liquidation period and after its dissolution. Their role is not to manage the business, but to ensure residual representation, acting before public bodies and administrative authorities when necessary. The liquidation is regulated by federal legislation, according to the company type: Brazilian Civil Code – Articles  1102 to 1112, for limited liability companies and other entities; and Brazilian Corporations Law – Articles 208 to 219. for publicly held and closely held companies. Both statutes reinforce the need for representation until the complete fulfillment of responsibilities. Brazilian companies with members who have returned abroad often cease to have resident administrators or proxies. That said, formal claims can still be made after the entity has been dissolved. Common situations include: Notifications from the Brazilian Federal Revenue Service; Audits of past periods; Judicial notices; Requests for clarification from regulatory bodies; Accounts receivable, such as reimbursements or PER/DCOMP (tax refund requests). and Requests for submission of documentation from previous periods. Without a representative in the country, the company is unable to carry out such acts, which creates legal uncertainty and may expose the former members to unnecessary risks. Although the act of dissolution formally ends the company’s existence, the liquidator’s liability remains in force for approximately five years, which corresponds to the main statute of limitations for tax, civil, and labor obligations. Appointing a liquidator is essential to: Avoid missing deadlines; Ensure the receipt of outstanding payments; and Ensure that the company is protected until the definitive settlement of its obligations. For companies with foreign members or administrators located outside Brazil, representation is essential to ensure regularity and security during the dissolution process. PLBrasil Legal Representation has a solid track record in legal representation, working to ensure that the company is protected during the liquidation period and after its dissolution. We are dedicated to offering precise and reliable assistance, making the dissolution process and post-dissolution period secure, predictable, and without undue risks for the members. Are you closing your company but still have PER/DCOMP credits to receive? At times like these, having a trustworthy liquidator makes all the difference. Talk to our experts! Are you closing your company but still have PER/DCOMP credits to receive? At times like these, having a trustworthy liquidator makes all the difference. Talk to our experts! The PLBrasil Group’s is available to assist you through the following channels: +55 (11) 3292-5050 nn@plbrasil.com.br

NIRE (Company Register Identification Number): What it is, what it’s for, and why it still matters

The Company Register Identification Number (NIRE) is a unique code assigned by the Commercial Registry to a company at the time of its incorporation, to prove its legal existence. It functions like a “corporate ID,” while the CNPJ plays a role similar to that of a “business CPF” (individual taxpayer ID). Despite legislative changes aimed at simplifying registration procedures, the NIRE remains an essential element for the organization and identification of business registrations. The NIRE is a numerical sequence created to allow for the identification and categorization of the company. Its coded structure aims to indicate, in an organized manner, information such as the registration status, the type of company, and the existence of branches, in addition to allowing sequential control and validation of the assigned number. Therefore, this is a system designed not only to individualize companies, but also to facilitate the administrative management of registrations by the Commercial Registries. With the enactment of Law No. 13,874/2019 (Economic Freedom Law), the national requirement for the NIRE was made more flexible, especially in the context of simplifying the procedures for opening and registering companies. The proposal was to reduce redundant formalities and make the business environment more agile. In theory, the CNPJ has come to fulfill, in many cases, the identifying function previously assigned to the NIRE. In practice, however, reality shows that this number remains relevant, especially in the Commercial Registries, which continue to use the NIRE as a central element in their controls, namely: Filing and monitoring of corporate documents with the Commercial Registry; Opening, modifying, and closing branches; Corporate reorganizations, such as mergers and spin-offs; Legal and corporate audits; and Obtaining certificates and proof of business compliance. It is important to distinguish the NIRE from other business registrations. It neither replaces nor is it confused with: the CNPJ, which is a federal and tax-related matter; state registration, aimed at tax control by the states; and municipal registration, linked to activities at the local level. Each of these registrations serves its own specific function, and a correct understanding of this distinction is fundamental to avoiding documentary inconsistencies throughout the life of the company. Even though it is no longer mandatory in all contexts, the NIRE remains a sensitive element in many business registrations. Changes in legal status, the opening of branches, or corporate reorganizations require attention to this information, as inconsistencies can lead to formal obstacles and administrative issues. Companies that maintain a long history of changes or that operate with multiple branches tend to be more susceptible to irregularities related to the use and control of this number. Although the NIRE has a technical and bureaucratic origin, its effects are practical. Discrepancies, duplications, or failures in its management can directly impact the company’s compliance, hindering future procedures and creating situations that require careful administrative correction. It is precisely at this point that the most relevant risks arise, which will be explored in detail in the next article, dedicated to the consequences and operational problems associated with errors involving the NIRE. Knowing the role of the NIRE and understanding its function throughout the life of a company is essential to prevent inconsistencies and ensure safety in business registration. Careful analysis of the information from the incorporation stage avoids rework, corrections, and future obstacles with the Commercial Registry. PLBrasil Paralegal focuses on the organization and regularization of corporate structures, offering technical support in the analysis of records, historical review, and document adaptation, especially for companies that require special attention in their corporate acts. Our team is available to assist in preventative assessments and provide guidance on the proper management of this information, contributing to a safer and more organized business structure. Are you going to open a branch or carry out corporate reorganizations? Consult our experts and avoid obstacles in the process. Are you going to open a branch or carry out corporate reorganizations? Consult our experts and avoid obstacles in the process. The PLBrasil Group team is available to assist you through the following channels: +55 (11) 3292-5050 nn@plbrasil.com.br

The deadline to file the Quarterly Periodic Declaration with the Central Bank of Brazil expires on June 30, 2026 – Base date: as of March 31, 2026

Companies receiving foreign direct investment in the country in their corporate capital, regardless of the amount, and that have total assets equal to or greater than BRL 300 million, must be aware of the deadline for the Quarterly Periodic Declaration (DPT) referring to the base date of March 31, 2026. What is the Quarterly Periodic Declaration (“Declaration”) – Census of Foreign Capital in the Country (“Census”)? This Declaration refers to foreign investments and is known as the Census of Foreign Capital in the Country (“Census”). In addition to other Central Bank (“BACEN”) censuses, the Declaration also aims to compile statistics on the external sector, such as the balance of payments and the International Investment Position (IIP). This information allows the Central Bank of Brazil (BACEN) and the government to measure the participation of foreign investors in the Brazilian economy, contributing to the formulation of more effective economic policies. The consolidated disclosure of results also assists the activities of economic researchers and international organizations. Which recipient company with non-resident investors holding shares in its company’s capital is required to submit the Quarterly Declaration to the Central Bank of Brazil (BACEN)? Those that have total assets equal to or greater than BRL 300 million on the base date of the respective quarter; and Those that have acquired a stake through an organized market, even when none of them individually owns 10% or more of the recipient’s voting power. Base Dates and Delivery Deadlines The declarations follow a quarterly schedule, as follows: March 31: Delivery between April 1 and June 30. June 30: Delivery between July 1 and September 30. September 30: Delivery between October 1 and December 31. December 31: Delivery between January 1 and March 31 (annual periodic declaration). What are the penalties if a company fails to meet the deadlines for filing the Declaration? Companies that fail to file the declaration on time may have their Foreign Capital Information Reporting System – Foreign Direct Investment (“SCE-IED”) suspended, which will prevent them from settling foreign exchange transactions related to Foreign Direct Investment, and they will also be subject to a fine, following an administrative sanctioning process. Do you need to submit the Quarterly Economic-Financial Declaration? Count on us to submit the necessary documentation and register with the Central Bank of Brazil. Contact our sales team Do you need to submit the reports to the Central Bank? You can count on us to submit the necessary documentation and register with the Central Bank of Brazil.     The PLBrasil Group’s Foreign Capital team is available to assist you with the registrations required by the Central Bank of Brazil in the channels below: +55 (11) 3292-5050comercial@plbrasil.com.br

How the new Federal Revenue Office system impacts obtaining a Corporate Taxpayer’s ID (CNPJ) starting December 1, 2025

Image of a woman in a light gray dress, with curly hair and a smile, next to a message about the change in the flow of new business openings in Brazil.

In compliance with Supplementary Law no. 214/2025, which set the Tax Reform milestone, on December 1, 2025, the Federal Revenue Office implemented the new MAT (Tax Administration Module) system. This change modifies the process of starting a company, requiring entrepreneurs to define their tax regime prior to issuance of the CNPJ. Until then, the procedure allowed issuance of the CNPJ in sync with the registration of the organizational documents at the Commercial Registry, notary public offices, or the Brazilian Bar Association (OAB). With the new system, however, the corporate registration and issuance of the CNPJ no longer occur simultaneously but now depend on the choice of tax regime in the Tax Administration Module. This change directly relates to the requirement previously announced by the Federal Revenue Office, which now calls for the indication of the tax regime at the time of registration, as addressed in a previous article. When will the CNPJ be generated? Although the essential steps for opening a business remain similar, the new process changes the timing to obtain the CNPJ. Under the new process: Registration of the organizational documents; Issuance of the State Registration Identification Number (NIRE) and provision of the Certificate of Full Content; Indication of the tax regime in the Tax Administration Module; and Generation of the CNPJ takes between 5 and 60 minutes. Only after accessing the Federal Revenue Office’s Tax Administration Module and formalizing the choice of tax regime will the CNPJ be effectively generated. For this purpose, the company has up to 90 days to make the indication. Most significant impact: expectation of immediate CNPJ issuance The main practical effect of this change lays on the absence of a CNPJ at the time of registration, and this impacts the start of the following activities: Open a bank accounts; Registration of the company on financial platforms; Execution of preliminary agreements; and Maintain registrations with suppliers and business partners. This change requires new planning, especially for companies that operate on tight schedules or depend on having a CNPJ to start operational activities. Tax planning in advance Another significant effect is the mandatory advance tax study. While many previously postponed analyzing their tax regime, the system now requires this decision to be made right at the beginning, which tends to force a more informed and technically sound decision. Although this change represents an initial increase in formalities, the trend is that, in the medium and long term, this requirement will reduce problems arising from incorrect classifications that generate damaging tax impacts for the company. In practical terms, the model contributes to greater consistency between corporate planning and tax structure from the outset. Scope and reach of the change It is important to note that this new procedure applies exclusively to the organization of new companies. Subsequent changes, such as contractual amendments, corporate reorganizations, or registration adjustments, do not follow the new logic. Furthermore, this is a nationwide change resulting from regulations issued by the Federal Revenue Office, even though its implementation is carried out by the state Commercial Registries. Starting companies in a more technical setting Given this new context, starting a company now requires greater integration between corporate planning, tax analysis, and technical support of the procedural process. PLBrasil Group works to advise its clients on starting companies, guiding them through critical stages, ensuring correct compliance with requirements, and adaptation to the new operational model, both in the paralegal and tax areas, especially in more complex scenarios. With a preventative approach and strategic analysis from the outset, it’s possible to structure the start of a company with greater security, predictability, and alignment with new regulatory requirements. Are you going to start a company? PLBrasil Paralegal offers full support to ensure flexibility and compliance. Are you going to start a company? PLBrasil Paralegal offers full support to ensure flexibility and compliance. The PLBrasil Group New Business team is available to assist you through the following channels: +55 (11) 3292-5050 nn@plbrasil.com.br

BC Protege+: A new tool from the Central Bank of Brazil against unauthorized account openings

Homem sorridente segurando um celular, promovendo proteção contra fraude bancária ao proteger CPF ou CNPJ. Destaca o BC Protege+ bloqueando contas não autorizadas.

BC Protege+ is a free, voluntary tool launched by the Central Bank of Brazil that allows individuals and legal entities to proactively block the opening of new checking, savings, or payment accounts in their name. By activating the service, the Individual Taxpayer’s Register (CPF) or National Corporate Taxpayer’s Register (CNPJ) becomes part of a database that banks are required to consult before opening any account. Therefore, if there is an attempt to create an account without authorization, the institution must automatically reject the transaction. Why did the Central Bank launch BC Protege+? The rise in fraud involving the opening of bank accounts with forged identities or data stolen has prompted the creation of a preventative blocking mechanism. Especially with the rise of fintechs, digital banks, and online services, it has become urgent to offer users a tool that guarantees control over their CPF or CNPJ within the financial system. The Central Bank considered that simply requiring documents to open an account was not enough to avoid all scams, especially those that use leaked or tampered data. BC Protege+ acts as an entry barrier, preventing the fraudulent account from being created and shielding the user against the misuse of their data. How does this protection work in practice? Any individual or legal entity can join BC Protege+. When activated, the lock prevents: Opening New Accounts: It blocks the creation of checking, savings, or prepaid payment accounts in the name of the CPF or CNPJ; and Misrepresentation: It prevents the user from being listed as the account holder or representative on accounts opened by third parties. Please note that the activation does not interfere with existing accounts, nor with current transactions, Brazilian Instant Payment System (PIX), cards, or active payments. The protection is exclusively for new openings and is reversible. BC Protege+ Benefits Among the main advantages of BC Protege+ are: Fraud and scam prevention: It prevents names from being misused to open third-party accounts; Control over opening of accounts: The decision of who can open an account in their name or represent them returns to the citizen or company; Simplicity and autonomy: Online activation, without red tape, and with the possibility of reversal whenever you want; and Emphasizing the security of the financial system: It works as an additional barrier to prevent fraudulent accounts from entering the system. BC Protege+ Limitations On the other hand, the service does not rule out all risks, for example: The tool does not automatically prevent the opening of payment accounts. Protection depends on the user’s active participation. If the person or company does not activate the block, the risk remains. Who should consider activating it? Protection is especially recommended for individuals or companies that have: History of personal data exposure; Those who fear identity fraud; New or rarely used CNPJ, with no history of banking relationships; and Companies with foreign partners or subsidiaries, to prevent the improper opening of accounts by third parties. Step-by-step guide to joining BC Protege+ To activate protection, simply follow these steps: 1. Access the Central Bank (BC) web portal and log in to “Meu BC” with your gov.br account access (silver or gold level), using two-step authentication; Click on the “BC Protege+” service; Activate the protection to prevent new account openings or inclusions as a representative; and If you want to open an account in the future, simply return to the system and disable the protection. The entire process is free and can be done online, without needing to visit a bank branch or contact financial institutions directly. An important instrument for governance and financial protection BC Protege+ represents a substantial advancement in the policy of protecting citizens and businesses against fraud in the financial system. By allowing users to decide whether they want new accounts opened in their name, the Central Bank provides a direct control mechanism, something that previously depended exclusively on the document analysis of financial institutions. For those dealing with complex corporate structures, companies with multiple branches, or foreign partners, the tool adds a layer of institutional security. It also reflects a new regulatory reality: Fraud prevention begins before the account even exists. Does your company need to submit tax returns to the Central Bank of Brazil? Consult our specialists for guidance and regularization. Does your company need to submit tax returns to the Central Bank of Brazil? Consult our specialists for guidance and regularization. The PLBrasil Group’s Foreign Capital team is available to assist you with the registrations required by the Central Bank of Brazil in the channels below: +55 (11) 3292-5050nn@plbrasil.com.br

CNJ decides: notaries public cannot require a validity date for powers of attorney without a legal basis

Smiling man using a cell phone, highlighting the message about the validity of powers of attorney in Brazil.

The Full Session of the National Council of Justice (CNJ) understood that the generic requirement of a validity period for powers of attorney in notaries public in Minas Gerais may be illegal, except when there is a legal provision or a justified need. The judgment took place within the scope of Administrative Control Procedure 0007885-89.2023.2.00.0000 and resulted in a unanimous decision. The decision reinforces principles of legality and reasonableness, clarifying that a notary public cannot impose special conditions without legal backing or a solid need. The practice analyzed by the CNJ, which involved establishing a validity date for powers of attorney, implied additional costs and, at times, delayed the processing of cases. The Council makes it clear that, only in specific and well-founded cases, such as evidence of falsification or risk to third parties, it is possible to require an update of the document. Although originating in Minas Gerais, the CNJ’s decision will likely influence notaries public in other states, serving as a national guideline. For users, this means fewer barriers to using powers of attorney in notarial acts, reducing rejections based solely on automatic deadline requirements. Each state maintains its own routines, and notary practices may vary according to the interpretation of local oversight bodies. In some cases, additional requirements are still imposed, even after the CNJ’s decision. This is where specialized legal advisory in notarial and registry law makes all the difference: Understanding state regulations and adjusting the power of attorney format can prevent delays and undue requirements. CNJ’s decision is an important step forward in strengthening legal certainty and curbing disproportionate requirements for notaries public. However, it does not dispense with care regarding the content and form of the power of attorney. Details can be crucial in determining whether a document is accepted immediately or, conversely, becomes subject to requirements that delay the process. At PLBrasil Paralegal, we have a team of experts who closely monitor national regulations and local practices in each state, ensuring compliance and providing peace of mind to those who depend on these actions to advance their businesses. Do you need a power of attorney? Rely on our expertise to prepare powers of attorney that prevent rejections and delays in any state. Do you need a power of attorney? Rely on our expertise to prepare powers of attorney that prevent rejections and delays in any state.

ANAC reinforces the mandatory requirement of Individual Taxpayer’s Register (CPF) or National Corporate Taxpayer’s Register (CNPJ) for aircraft owners

Proprietário de aeronave no Brasil deve cumprir nova regra sem CPF ou CNPJ válido, o registro pode ser bloqueado. Imagem de um piloto com uniforme e boné de comandante.

In June 2025, the National Civil Aviation Agency (ANAC) issued Circular Memorandum No. 1/2025/GTRAB/SAR, reiterating that all owners and operators of civil aircraft registered in Brazil must keep their registrations updated with the Brazilian Aeronautical Registry (RAB), providing a valid CPF or CNPJ. A medida não altera a legislação, mas reforça a necessidade de cumprimento de normas já previstas, especialmente na Lei nº 14.129/2021 (Governo Digital) e nas Instruções Normativas RFB nº 2.119/2022 e 2.172/2024, que tratam, entre outras coisas, do Cadastro Nacional da Pessoa Jurídica (CNPJ) e da representação de pessoas físicas e jurídicas domiciliadas no exterior. The memorandum has as its main purpose to reinforce the obligation of identification of owners and operators of civil aircraft in Brazil, including individuals and legal entities domiciled abroad that hold rights over aircraft registered in the country. In such cases, it is mandatory to obtain a CPF (for individuals) or CNPJ (for legal entities), pursuant to the rules of the Federal Revenue Office. For foreign companies, Normative Instruction RFB No. 2.119/2022 also requires the appointment of an attorney-in-fact residing in Brazil, with express powers to receive summons and to manage assets and rights. Failure to comply with these formalities may result in the denial or suspension of the registration with the Brazilian Aeronautical Registry (RAB). ANAC explains that the use of CPF and CNPJ as standardized identifiers allows the RAB to be integrated with systems of other federal bodies, such as the Federal Revenue Office, the National Council of Justice (CNJ), the Department of Airspace Control (DECEA), and airport concessionaires. The measure strengthens ownership control, increases the traceability of information, and contributes to the fulfillment of international security and transparency requirements in the aviation sector. In practice, the memorandum functions as a regulatory reminder: without a valid CPF or CNPJ, it is not possible to carry out new registrations, property transfers, or registration updates. Ongoing proceedings may be suspended until the situation is regularized. More than a mere formality, ANAC’s reinforcement represents a step toward greater governance and oversight in the aeronautical sector. Complying with the requirements of identification and legal representation are essential to maintain the regularity of the registration and to avoid administrative obstacles. PLBrasil Paralegal supports owners, operators, and law firms in the regularization of aeronautical registrations, providing services such as obtaining CPF or CNPJ, legal representation of foreigners, and translation of official documents. Our objective is to ensure compliance and fluidity in proceedings with ANAC and the Federal Revenue Office. Regularize the registration of your aircraft safely! We offer complete support for obtaining CPF/CNPJ, legal representation of foreigners, and compliance with ANAC. Regularize the registration of your aircraft safely! We offer complete support for obtaining CPF/CNPJ, legal representation of foreigners, and compliance with ANAC.

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