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.