The enactment of RFB Normative Instruction No. 2,290/2025 brought immediate practical impacts on administrative proceedings for the disclosure of ultimate beneficial owners currently pending before the Federal Revenue Service. Chief among these is the automatic cancellation of all filings submitted through October 2025, requiring that information be resubmitted in accordance with the new regulations.

This administrative shift is directly linked to the restructuring of procedures and the implementation of the Digital Beneficial Ownership Form (e-BEF), which has centralized the submission of information within the National Registry of Legal Entities (CNPJ) framework.

Cancellation of Previously Filed Proceedings

With the entry into force of RFB IN No. 2,290/2025, all beneficial ownership filings that were under review or pending a decision as of October 2025 were cancelled by the Federal Revenue Service. This includes cases where:

• The beneficial owner had already been disclosed;
• The analysis was currently underway; and
• The filing was awaiting supplemental information or an administrative decision.

This measure stems from the need to align proceedings with the new regulatory and systemic model, as announced by the Federal Revenue Service in an institutional notice published on October 31, 2025, regarding the issuance of RFB IN No. 2,290/2025 and the expansion of registration transparency rules.

Resubmission of Information: Starting the Process Anew

Following the cancellation, taxpayers must initiate a new proceeding, ensuring full compliance with the requirements of RFB IN No. 2,290/2025. This means that:

• The procedure begins from scratch via the e-BEF;
• The option to declare the “non-existence” of a beneficial owner is no longer available; and
• The system now requires the effective identification of natural persons classified as ultimate beneficial owners.

Administrative update, not penalty

The cancellation of these filings should not be interpreted as a sanction, but rather as a natural consequence of a structural update to the Federal Revenue Service’s registration control mechanisms. Regulatory and technological shifts of this magnitude typically require the suspension of legacy workflows to ensure information consistency, security, and integrity.

The adoption of a new electronic form and the removal of previously permitted exceptions are part of a modernization process aimed at aligning with international transparency standards.

Technical support for new proceedings

Given the cancellation of prior filings, it is recommended that companies and entities, among other measures, review their corporate structures and chains of control; align the identification of beneficial owners with the new requirements; Properly prepare the resubmission of information through the e-BEF.

PLBrasil Paralegal is prepared to provide technical support in this new cycle, assisting in the analysis, structuring, and resubmission of beneficial ownership filings, with a focus on compliance, legal certainty, and operational efficiency.